Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important

information on who we are and how and why we collect, store, use and share your personal data. It

also explains your rights in relation to your personal data and how to contact us or supervisory

authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are

subject to the UK General Data Protection Regulation (UK GDPR).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

Personal data

Any information relating to

Special category personal data Personal data

revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation

Data subject

The individual who the personal data relates to

Personal data we collect about you

The personal data we collect about you depends on the particular services we provide to you. We will

collect and use the following personal data about you:

• your name and contact information, including email address and telephone number and

company details where applicable;

• location data, if you choose to give this to us;

• your billing information, transaction and payment card information;

• Information about how you use our website, IT, communication and other systems;

We collect and use this personal data for the purposes described in the section ‘How and why we

use your personal data’ below. If you do not provide personal data we ask for, it may delay or

prevent us from providing services to you.

How your personal data is collected

We collect most of this personal data directly from you—in person, by telephone, text or email and/or

via our website and apps. However, we may also collect information:

• from a third party with your consent, eg your bank or building society 1

• from cookies on our website—for more information on our use of cookies, please see our cookie policy which is available on our website

• via our IT systems, eg through automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email

and instant messaging systems;

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

• where you have given consent;

• to comply with our legal and regulatory obligations;

• for the performance of a contract with you or to take steps at your request before entering into a contract; or

• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so

long as this is not overridden by your own rights and interests. We will carry out an assessment when

relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

Personal data

Any information relating to an identified or identifiable individual

Special category personal data

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation.

Data subject

The individual who the personal data relates to

Personal data we collect about you

The personal data we collect about you depends on the particular services we provide to you. We will

collect and use the following personal data about you:

• your name and contact information, including email address and telephone number and

company details where applicable;

• location data, if you choose to give this to us;

• your billing information, transaction and payment card information;

• Information about how you use our website, IT, communication and other systems; We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you. How your personal data is collected We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:

• from a third party with your consent, eg your bank or building society 1

• from cookies on our website—for more information on our use of cookies, please see our cookie policy which is available on our website

• via our IT systems, eg through automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems; How and why we use your personal data Under data protection law, we can only use your personal data if we have a proper reason, eg:

• where you have given consent;

• to comply with our legal and regulatory obligations;

• for the performance of a contract with you or to take steps at your request before entering into a contract; or

• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so

long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. The table below explains what we use your personal data for and why.

Providing services to you

To perform our contract with you or to take steps at your request before entering into a contract

Preventing and detecting fraud against you or us

For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—in other cases, for our legitimate interests, ie to protect our business, interests and rights

Ensuring business policies are adhered to, eg policies covering security and internet use

For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests , ie to be as efficient as we can so we can deliver the best service to you at the best price

Ensuring the confidentiality of commercially sensitive information

Depending on the circumstances:

—for our legitimate interests, ie to protect trade secrets and other commercially valuable information;

—to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, eg in relation to financial performance, or customer base.

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

Protecting the security of systems and data used to provide the services

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Updating customer records

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract;

—to comply with our legal and regulatory obligations;

—for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests, ie to promote our business to existing and former customers

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

How and why we use your personal data—in more detail

More details about how we use your personal data and why are set out

Purpose

Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)

Processing operation

Addressing and sending communications to you as required by data protection laws, ie: —the UK GDPR or Data Protection Act 2018;

Lawful basis relied on under the UK GDPR

Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))

Relevant categories of personal data

—your name, address and contact information, including email address and telephone number and company details;

—your account details (username)

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us at tom@acceleratingaction.com; or

• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

• We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

• third parties we use to help deliver our services to you, eg payment service providers;

• other third parties we use to help us run our business, eg marketing agencies or website hosts; and

• third parties approved by you, eg social media sites you choose to link your account to or third party payment providers.

We or the third parties mentioned above occasionally also share personal data with:

• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;

• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;

• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Your rights

You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal data

Rectification

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of processing

The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object

The right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to automated individual decision making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

The right to withdraw consents

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

• email, call or write to us—see below: ‘How to contact us’; and

• provide enough information to identify yourself (eg your full name, address and/or email address) and any additional identity information we may reasonably request from you;

• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner in the UK.

Changes to this privacy policy

This privacy notice was published on 14 March 2022.

We may change this privacy notice from time to time—when we do we will inform you via our website www.acceleratingaction.com or other means of contact such as email.

How to contact us

Individuals in the UK

You can contact us by email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

tom@acceleratingaction.com

+44 (0) 7964369576