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

• Sharing information outside the UK

• How to complain

Contact details

Post

Office 16737, 182 - 184 High Street North, , London, , E6 2JA, 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)

• Audio recordings (eg calls)

• Records of meetings and decisions

• Account access information

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

• Names and contact details

• Addresses

• Purchase or service history

• Account information, including registration details

• Technical data, including information about browser and operating systems

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

• Names and contact details

• Addresses

• Profile information

• Marketing preferences

• 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

• Account information

• Call recordings

• 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 interests are:

• We collect and use client contact details, meeting records, call recordings and usage information to deliver our revenue operations and CRM consultancy services, and to improve how we deliver them. Understanding how a client\'s sales process works in practice, and reviewing our own engagements afterwards, is necessary for us to design systems that fit the business rather than applying a generic template. The benefit to clients is a system built around how they actually operate, and a service that improves as we learn from each engagement. The benefit to us is being able to deliver our services effectively and refine our methodology. The information involved is limited to business contact details and records of professional engagements. It is not sensitive, it relates to people acting in a professional capacity rather than a private one, and it is what those individuals would reasonably expect us to hold in order to carry out the work they have engaged us for. We keep it only as long as necessary, we do not use it for any purpose unconnected with the engagement, and anyone can ask us to stop or to delete their information at any time. On that basis the impact on individuals is minimal and does not outweigh the interests set out above.

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.

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 interests are:

• We collect and use business contact details, job titles and company information to contact organisations we believe may benefit from our revenue operations and CRM services. This is necessary for us to reach potential clients and generate new business, and direct outreach is the primary way we do so. Contacts are business people at businesses, approached in their professional capacity about a service relevant to their role. We target narrowly rather than at volume, so the people we contact are those for whom the service is likely to be genuinely relevant. The benefit to them is being made aware of a service that may address a problem their organisation has; the benefit to us is the ability to find clients. The information involved is limited to professional contact details and company information, most of it publicly available. It is not sensitive and does not relate to anyone\'s private life. We keep records of contact so we do not approach the same person repeatedly, we stop contacting anyone who tells us to, and we remove people from our records on request. Given the limited nature of the information and the professional context, the impact on individuals is low and does not outweigh our interest in contacting them.

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 interests are:

• We use client contact details, account records, call recordings and correspondence to investigate and resolve queries, complaints and claims. This is necessary for us to respond properly, to establish what happened, and to defend or resolve any dispute. It benefits the individual by ensuring their query is dealt with accurately, and benefits us by allowing us to manage our legal and commercial position. The information is limited to what is relevant to the matter, is held only as long as necessary, and its use is what anyone raising a query with us would reasonably expect.

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

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Who we share information with

Data processors

HubSpot, Inc.

This data processor does the following activities for us: They provide the CRM platform where we store and manage our client and prospect records, including contact details, call records, meeting notes and engagement history. They also host our call recording and email functionality.

Others we share personal information with

• Professional or legal advisors

• Organisations we’re legally obliged to share personal information with

Sharing information outside the UK

Where necessary, our data processors will share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Hubspot

Category of recipient: CRM and marketing software provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

Organisation name: Google LLC

Category of recipient: Email, storage and productivity software provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

Organisation name: Framer B.V.

Category of recipient: Website hosting and design software provider

Country the personal information is sent to: Netherlands

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Post: Office 16737 182 - 184 High Street North London E6 2JA