Conductr Ltd Privacy Policy

Introduction

This is Conductr Limited's Privacy Policy.

Conductr Ltd respects the privacy and security of everyone it interacts with, and is committed to protecting your Personal Data. This Privacy Policy will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Policy informs you about the types of Personal Data which Conductr Ltd Limited collects from you when you interact with us through this website, or otherwise via e-mail, or social media. Please also use the Glossary below to understand the meaning of some of the terms which we use in this Privacy Policy.

1. Important Information And Who We Are

Purpose Of This Privacy Policy

This Privacy Policy aims to give you information on how Conductr Ltd Limited collects and processes your Personal Data through your use of this website or when you contact us by e-mail or via social media, including any data you may provide through this website when you make an enquiry via e-mail, or communicate with us about taking part in our initiatives through which we may collate and curate information about you.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notices or fair processing information which we may provide on specific occasions and in relation to specific situations (including campaigns and initiatives upon which we work on behalf of the brands we provide our services to) when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements any other specific privacy notices and fair processing information and is not intended to override them.

Controller

Conductr Ltd is, for the purposes of relevant UK Data Protection Legislation (including, without limitation, the UK GDPR and Data Protection Act 2018), the Data Controller and responsible for your Personal Data (collectively referred to as "Conductr", "we", "us" or "our" in this Privacy Policy).

If you have any questions about this Privacy Policy or how we use your Personal Data, including any requests to exercise your legal rights as referred to below, please contact our CEO, Peter Cliff or COO, Jos van der Steen using the details set out below.

Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact our CEO, Peter Cliff or COO, Jos van der Steen in the following ways:

Full name of legal entity: Conductr Ltd

Email address: peter@conductr.co.uk or jos.vandersteen@conductr.com

Postal address: Conductr, Unit F1, Longford Trading Estate, Thomas Street, Manchester, M32 0JT

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 do contact us in the first instance, using the information listed above.

Changes To The Privacy Policy And Your Duty To Inform Us Of Changes

We keep our Privacy Policy under regular review, and reserve the right to change or add to its terms. Please review the contents of this page periodically to ensure that you are aware of any changes, This version was last updated in June 2025.

Historic versions can be obtained by contacting us.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

2. The Data We Collect About You

In this Privacy Policy, “Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes invoicing address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes any username and password (if provided), your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Recruitment Data includes medical and healthcare information, timesheet information, employment history, driving licence and passport, disciplinary and grievance information, performance information, recruitment information, criminal offence data, race, ethnicity, religious beliefs, location of employment or workplace, employer’s details, compensation history, photographs and video images.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may need to collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

If You Fail To Provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to end our relationship with you, but we will notify you if this is the case at the time.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Identity, Contact Financial and Recruitment Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

Apply for a position with us;
Subscribe to our newsletters or publications;
Request marketing to be sent to you;
Enter a competition, promotion or survey; or
Give us feedback or contact us.

Third parties or publicly available sources.

We will receive Personal Data about you from various third parties and public sources, such as:

Technical Data from the following parties:

a) analytics providers such as PowerBi, Google Analytics, based outside the UK;

b) advertising networks such as X (previously Twitter), Instagram, Facebook, Tik Tok, LinkedIn; based outside the UK;

c) search information providers such as Google based outside the UK;

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK. 4. How We Use Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5. Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on activity or campaigns which may be of interest to you or in which you may want to participate.

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

We will always get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of any relationship into which we subsequently enter with you or any financial transactions.

Change Of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures Of Your Personal Data

We may share your Personal Data with the parties set out below for the purposes set out in the table “Purposes for which we will use your Personal Data” above.

Third Parties as set out in the Glossary below.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
All third parties to whom we disclose your Personal Data are obliged to respect its security and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

6. International Transfers

Many of our third parties are based outside the UK so their processing of your Personal Data will involve a transfer of data outside the UK.

Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give Personal Data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK. 7. Data Storage Locations

Our servers are hosted within the United Kingdom and the European Union. Any transfers of data outside these jurisdictions are managed under standard contractual clauses or equivalent safeguards to ensure compliance with UK and EU data protection laws.

Effective date: 12/6/2025