Privacy Policy

We are a ‘data controller’, as we determine the data that is collected from publicly available resources and what we make available to our customers and how we deliver this data to our customers.

Personal data: is information that relates to an identified or identifiable individual.

We may collect, use, store and disclose different kinds of personal data about you which we have listed below:

• Identity Data including first name, last name, title, nationality, date of birth and job title.
• Contact Data including billing address, delivery address, business address and email address.
• Professional Data including details about employees, retrieved from public resources.

We collect personal data in a variety of ways, including:

• Directly: We collect personal data which you directly provide to us, including when you enter your email address and when you enter our website and you want to create a commercial relationship with Condukt.
• Indirectly: We may collect personal data which you indirectly provide to us while interacting with Condukt via a representative of your organisation.
• From publicly available sources: We collect personal data from publicly available resources such as Companies House and other official and unofficial resources.

We collect and process personal data about you only where we have a legal basis for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

If you have consented to our use of your data for a specific purpose, you have the right to withdraw your consent at any time. However, this will not affect any processing that has already taken place. Where we are using your data based on legitimate interests, either ours or a third party's, you have the right to object to that use. In some cases, this may result in no longer being able to use our services. Further information about your rights is available below.

We may disclose personal data to:

• our employees, contractors and/or related entities;
• IT service providers, data storage, web-hosting and server providers;
• professional advisors, bankers, auditors, insurers and insurance brokers;
• our existing or potential agents or affiliates;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
• any other third parties as required or permitted by law.

When we disclose personal data to the third parties listed above, these parties may store, transfer, or access your data outside of the United Kingdom, including in the European Economic Area (EEA). The level of data protection in countries outside the UK may not be as comprehensive as that offered within the United Kingdom. When transferring your personal data internationally, we will use appropriate safeguards to comply with applicable data protection laws and will ensure that your data is protected according to this Privacy Policy. This includes:

• only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or
• including standard contractual clauses in our agreements with third parties that are overseas.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your choice: Please read this Privacy Policy carefully. If you provide personal data to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Privacy Policy. You do not have to provide personal data to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such a person’s consent to provide the personal data to us.

Access, correction, processing and portability: You may request details of the personal data that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal data to a third party and, in some circumstances, to have personal data relating to you transferred to you or another organisation.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We are committed to ensuring the security of the personal data we collect. To prevent unauthorized access or disclosure, we have implemented suitable physical, electronic, and managerial procedures to safeguard and secure personal data, protecting it from misuse, interference, loss, unauthorized access, modification, and disclosure.

While we are dedicated to maintaining security, we cannot guarantee the protection of any information transmitted to or from us over the Internet. The transmission and exchange of information is carried out at your own risk.

Our website may contain links to other parties' websites. We do not control these websites and are not responsible for the protection and privacy of any personal data you provide while visiting them. These websites are not governed by this Privacy Policy.

We may update this Privacy Notice from time to time. If we make significant changes to this Privacy Notice, we will notify you by contacting you through the details you have provided and by publishing an updated version on our website.

Condukt Ltd, a company registered in England and Wales, with company number 14526763.

Data Privacy Officer Contact: customer@condukt.co

Last update: 5 September 2024