Privacy Policy

This privacy notice tells you what to expect us to do with your personal information.

·       Contact details

·       What information we collect, use, and why

·       Lawful bases and data protection rights

·       Where we get personal information from

·       How long we keep information

·       Who we share information with

·       How to complain

Contact details

First Floor, 85 Great Portland Street, London, W1W 7LT, GB

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

·       Names and contact details

·       Occupation

·       Transaction data (including details about payments to and from you and details of products and services you have purchased)

·       Usage data (including information about how you interact with and use our website, products and services)

·       Video recordings

·       Audio recordings (eg calls)

·       Records of meetings and decisions

·       Account access information

·       Website user information

We collect or use the following personal information for the operation of client or customer accounts:

·       Names and contact details

·       Purchase or service history

·       Account information, including registration details

·       Marketing preferences

We collect or use the following personal information for information updates or marketing purposes:

·       Names and contact details

·       Addresses

·       Profile information

·       Marketing preferences

·       Purchase or account history

·       Website and app user journey information

·       IP addresses

We collect or use the following personal information to comply with legal requirements:

·       Name

·       Contact information

·       Client account information

·       Any other personal information required to comply with legal obligations

We collect or use the following personal information for dealing with queries, complaints or claims:

·       Names and contact details

·       Addresses

·       Payment details

·       Account information

·       Purchase or service history

·       Relevant information from previous investigations

·       Customer or client accounts and records

·       Financial transaction information

·       Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

·       Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

·       Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

·       Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

·       Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

·       Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

·       Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

·       Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

·       Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

·       Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interest is to effectively manage business relationships and deliver professional consulting services that meet the specific needs of our corporate clients.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

·       Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

·       Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

·       Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interest is to connect with relevant business professionals to offer services that may provide value to their specific role or organization, while maintaining a strictly business-to-business focus.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to comply with legal requirements:

·       Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

·       Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

·       Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interest is to ensure all professional inquiries and complaints are handled efficiently and to maintain a suppression list that honors 'Do Not Contact' requests.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

·       Directly from you

·       Publicly available sources

·       Market research organisations

·       Providers of marketing lists and other personal information

How long we keep information

We only retain your personal data for as long as necessary to fulfill the purposes we collected it for. In determining these periods, we consider the nature of the data, legal requirements (such as HMRC tax rules), and the necessity of the data for our business relationship.

Standard retention periods include:

·   Client Records: 6 years after the end of our contract to comply with UK tax and legal obligations.

·   Marketing Leads: 2 years from our last point of contact; after this, data is securely deleted if no business relationship is formed.

·   Suppression List: We keep a minimal record (email address only) indefinitely to ensure we honor your request never to be contacted again.

Who we share information with

Data processors

Data Processor 1: Cloud Infrastructure & Document Management

• Category of Processor: Cloud Productivity and Storage Providers.

• Industry/Sector: Technology / Software as a Service (SaaS).

• Location: UK / EU / USA

This data processor does the following activities for us: They provide the secure cloud environment where we store our CRM spreadsheets, project documents, and client records. They act as the primary host for our internal databases.

Data Processor 2: Communication & Email Services

• Category of Processor: Email and Communication Service Providers.

• Industry/Sector: Telecommunications / SaaS.

• Location: UK / EU / USA.

This data processor does the following activities for us: They manage our email systems and professional communication tools. They process contact information to enable us to send project updates, marketing information, and respond to queries.

Data Processor 3: Sales Automation & Lead Generation Tools

• Category of Processor: Marketing Automation and Sales Intelligence Platforms.

• Industry/Sector: Marketing Technology

• Location: UK / EU / USA.

They assist in the sourcing of business contact information and the automation of our outreach sequences. They help us manage our suppression lists to ensure we honor 'Do Not Contact' requests.

Others we share personal information with

We may share client testimonials or logos on our website only where explicit permission has been granted.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint