Privacy Policy

1 Who we are

GLOBALLNEX LIMITED is the controller of the personal data covered by this policy.

• Registered company number: 17193332
• Registered office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
• Website: [insert live website URL]
• General enquiries: [insert contact email]
• Privacy queries / data rights requests: [insert privacy email or contact form URL]

If you appoint a dedicated Data Protection Officer in future, the policy should be updated to include those contact details.

2 The personal data we collect

Depending on how you interact with us, we may collect the following categories of personal data:

• Identity and contact data, such as your name, employer, job title, email address, telephone number and postal address.
• Enquiry and correspondence data, including messages you send us, meeting notes, partnership enquiries, ambassador enquiries, investor relations enquiries and support requests.
• Account, profile and registration data, such as username, login details, challenge participation details, profile information and preferences, where we offer account or app functionality.
• Marketing and communications data, such as your preferences for receiving updates from us and your interactions with our campaigns.
• Technical and usage data, such as IP address, browser type, device identifiers, operating system, referral source, pages viewed, app events and approximate location derived from IP or device settings.
• Cookie and similar technology data, where you consent to or otherwise permit the relevant technology.
• Publicly available business information, where you interact with us in a corporate, media, ambassador, investor or commercial capacity.

3 How we collect personal data

• Directly from you when you complete forms, register interest, sign up for updates, request information, contact us, enter a challenge, join a waitlist, or otherwise communicate with us.
• Automatically when you browse our website or use related services, including through server logs, cookies, SDKs, pixels and analytics tools, subject to the choices you make.
• From third parties, such as hosting providers, analytics providers, CRM providers, social media platforms, app stores, publicly available sources, advisers, investors, commercial partners or introducers, where lawful.

4 How and why we use personal data

We use personal data for the following purposes and on the following lawful bases:

5 Marketing

We may send you marketing or promotional communications where you have asked to receive them, where you have consented, or where we otherwise have a lawful right to do so. You can opt out at any time by using the unsubscribe link in our emails or by contacting us using the details above.

If you plan to carry out direct electronic marketing to individuals in the UK, you should also ensure your sign-up journeys and consent wording are PECR-compliant.

6 Cookies and similar technologies

Our website may use cookies and similar technologies to operate the site, remember preferences, analyse usage and support campaigns. Where consent is required under PECR, we will ask for it before placing non-essential cookies or similar technologies on your device.

• Strictly necessary cookies may be used without consent where they are genuinely required to provide the service requested by the user or to maintain security.
• Analytics, advertising, personalisation and social media cookies should not be set until the user has given a valid choice, unless a specific legal exception applies.

You should maintain a separate Cookie Notice and a working cookie settings tool so users can review and change their preferences.

7 Sharing personal data

We may share personal data with trusted third parties where necessary for the purposes set out above, including:

• Website hosting, cloud storage, analytics, CRM, email delivery, customer support and software providers.
• Professional advisers, including lawyers, accountants, insurers, auditors and corporate finance advisers.
• Group companies and carefully selected commercial partners where this is necessary to provide the relevant service or progress a genuine business opportunity.
• Regulators, law enforcement bodies, courts or other authorities where disclosure is required or reasonably necessary.
• Potential investors, buyers or funders in connection with a proposed investment, financing, merger, acquisition or reorganisation, subject to appropriate confidentiality controls.

We do not sell personal data.

8 International transfers

Some of our suppliers or partners may process personal data outside the UK. Where that happens, we will take reasonable steps to ensure the transfer is lawful and that appropriate safeguards are in place, for example by relying on an adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another recognised safeguard.

9 Retention

We keep personal data only for as long as reasonably necessary for the relevant purpose, including to satisfy legal, regulatory, tax, accounting or reporting requirements. As a guide:

• General enquiries and prospective business communications: typically up to 24 months after the last meaningful contact, unless a longer period is justified.
• Marketing suppression records: for as long as reasonably necessary to respect opt-out requests.
• Account and service data: for the life of the account or service relationship and for a reasonable period afterwards.
• Contractual and corporate records: usually up to 6 years after the end of the relevant relationship, or longer where required by law or in connection with claims, investment due diligence or corporate record-keeping.

10 Data security

We use appropriate technical and organisational measures designed to protect personal data against accidental loss and unauthorised access, use, alteration or disclosure. However, no online transmission or storage system can be guaranteed to be completely secure.

11 Your rights

Subject to applicable law, you may have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request deletion of your personal data in certain circumstances;
• request restriction of processing in certain circumstances;
• object to processing based on legitimate interests or direct marketing;
• request transfer of certain personal data to you or another provider;
• withdraw consent at any time where we rely on consent; and
• complain to the Information Commissioner's Office (ICO) if you are unhappy with how we handle your personal data.

You can exercise your rights by contacting us using the details set out above. We may need to verify your identity before dealing with your request.

12 Children

If any part of our website, app or services is directed at or likely to be used by children, the relevant journey should be reviewed separately to ensure that privacy information, consent language and safeguarding controls are age-appropriate.

13 Third-party links

Our website may contain links to third-party websites, apps or services. We are not responsible for their privacy practices and encourage you to read their privacy notices.

14 Changes to this policy

We may update this Privacy Policy from time to time. The latest version will appear on our website together with its effective date.