K3 CAPITAL GROUP LIMITED

PRIVACY NOTICE

This version is effective from: 28 February 2025

1 Introduction

This Privacy Policy sets out how certain entities within the K3 Capital Group Limited group of companies process your personal data in connection with our business, including the provision of our website at k3capitalgroup.com (our “Site”), and the provision of the services we offer.

This Privacy Notice also explains how we process your personal data if you are an individual that interacts with any of our Group Companies, including if you: work for businesses that provide goods or services to us, apply to work for us, visit our premises, attend events that we host, and are engaged by us to promote our business.

Please take a moment to read this Privacy Notice as it provides you with important information about your personal data, including the rights you have in relation to it. Your access to and use of our Site is also subject to our Terms of Use, and your purchase of any Services from us will be subject to our standard terms and conditions.

This Privacy Notice is intended to meet the requirements of privacy laws of the United Kingdom (“UK”) and the European Union (“EU”), in particular the EU’s General Data Protection Regulation, the UK GDPR, and other similar European privacy laws (for ease of reference, collectively, the “GDPR”). However, as a group which conducts business internationally, including outside of the UK and EU, we may be subject to other privacy laws and process personal data relating to individuals located in territories – if this applies to you, please see the International Privacy Laws and Requirements section.

Any changes we make to this Privacy Notice will be posted on our Site, including to reflect any changes to our use of personal data or to comply with applicable law or regulatory requirements. Where possible we may notify you of these changes by email, but we encourage you to check this page regularly to keep up to date.

2 About us

This site and our services are made available by various companies in the K3 Capital group of companies (each a “Group Company”).

For a full list of entities in K3 Capital Group click here:

No.	Entity name and registration number	Registered office or address	ICO Number or Equivalent
1.	K3 Capital Group Ltd	Company number: 06102618 Registered office address: KBS House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZA236839
2	Shin Topco Ltd	Company number: 14515822 Registered office address: 2 Park Street, 1st Floor, London, United Kingdom, W1K 2HX
3	Flint Studios Ltd	Company number: NI610114 Registered office address: Unit 6a Ravenhill Business Park, Ravenhill Road, Belfast, BT6 8AW	ICO number: ZA539181
4	HMA Property Services Ltd	Company number: 14728607 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT
5	HMA Tax (Dubai) Ltd	Company number: 14707145 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT
6	HMA Tax (International) Ltd	Company number: 14529671 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZB534038
7	HMA Tax (Offshore) Ltd	Company number: 14990789 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT
8	Intax Ltd	Company number: 11271031 Registered office address: 20 St. Andrew Street, London, England, EC4A 3AG	ICO number: ZA424021
9	K3 Advantage Ltd	Company number: 15294829 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZB664F328
10	K3 Debt Advisory Ltd	Company number: 13326242 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZB054710
11	K3 Law Ltd	Company number: 13175495 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZB693634
12	K3 Tax Advisory Ltd	Company number: 13381540 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZB071392
13	KBS Capital Markets Ltd	Company number: 11164985 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT
14	KBS Corporate Finance Ltd	Company number: 08924449 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZA236843
15	KBS Corporate Sales Ltd	Company number: 04141555 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: Z9151884
16	Knight Corporate Finance Ltd	Company number: 06773338 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: Z2947739
17	Knight R&D Ltd	Company number: 10271074 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZA728120
18	Knightsbridge Business Sales Ltd (trading as Knightsbridge Commercial)	Company number: 08924297 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZA236848
19	KR8 Advisory Limited	Company number: 16078236 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, United Kingdom, BL3 2NT	ICO number: ZB853397
20	KR8 Real Estate Limited	Company number: 16080636 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, United Kingdom, BL3 2NT	ICO number: ZB853390
21	Market Mapping Ltd (trading as Origin IQ)	Company number: 12835170 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZA796709
22	Pinnacle Computing (Support) Ltd	Company number: NI026898 Registered office address: Pinnacle House, 153 Upper Newtownards Road, Belfast, BT4 3HX	ICO number: ZA298419
23	Pinnacle Computing Ltd	Company number: IE283485 Registered office address: Clonmel House, Forster way, Swords, County Dublin	ICO number: ZA298419
24	Professional Insight Marketing Ltd (trading as JE Consulting)	Company number: 05883501 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZA340910
25	Quantuma (BVI) Ltd	Company number: 2056855 Registered office address: Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Island.
26	Quantuma (Cayman) Ltd	Company number: 366700 Registered office address: Suite N404, Flagship Building, 142 Seafarers Way, George Town, Grand Cayman, Cayman Islands
27	Quantuma (HK) Ltd	Company number: 73623607 Registered office address: 26/F, Prosperity Tower, 39 Queen’s Road Central, Central Hong Kong, SAR China
28	Quantuma (Singapore) Pte. Ltd	Company number: 202125356D Registered office address: 137 Amoy Street, #02-03 Far East Square, 049965, Singapore
29	Quantuma Advisory (Yorkshire) Ltd	Company number: 03488487 Registered office address: Resolution House, 12 Mill Hill, Leeds, LS1 5DQ	ICO number: Z9077007
30	Quantuma Advisory Ltd	Company number: 12743937 Registered office address: 20 St. Andrew Street, London, England, EC4A 3AG	ICO number: ZA776330
31	Quantuma Advisory Middle East Ltd	Company number: 4995 Registered office address: Unit 2205, Level 22, Index tower East, DIFC, Dubai, United Arab Emirates.
32	Quantuma Corporate Finance Ltd	Company number: 12579748 Registered office address: 20 St. Andrew Street, London, England, EC4A 3AG
33	Quantuma Cyprus Ltd	Company number: HE383074 Registered office address: Charalambous Tower, Floor 1, Flat/ Office 102, Stasikratous 32, 1065 Lykavitos, Nicosia, Cyprus
34	Quantuma Labuan Ltd	Company number: LL21156 Registered office address: Unit Level 14(B) & 14(C), Main Office Tower, Financial Park Labuan Complex, Jalan Merdeka, 87000 Federal Territory of Labuan, Malaysia
35	Quantuma Poland s.p.z.o.o.	Company number: 0000944120 Registered office address: Business Link Astoria, ul. Przeskok 2, 00-032 Warsaw, Poland KRS: 0000944120, NIP: 5252892615, REGON: 520988658
36	Quantuma Vietnam Pte Ltd	Company number: 202125356D Registered office address: 11 Doan Van Bo, Ward 13, District 4, Ho Chi Minh City, Vietnam
37	RandD UK Ltd	Company number: 06648783 Registered office address: Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT	ICO number: ZB298677

Where this Privacy Policy refers to the “K3 Capital Group”, “we”, “us”, “our”, this means one or more of the Group Companies that provide this site and/or the particular services to you.

For the purpose of EU and UK data protection legislation, except as stated otherwise, where applicable, each Group Company is an independent controller of your personal data.

For more information about any of the Group Companies or details of our ICO registration (as applicable), please contact us using the details in the “How to contact us” section in this Privacy Notice.

3 How to contact us

If you want more information or have any questions about our processing of your personal data or this Privacy Notice you can contact us by sending an email to [email protected], or writing to us at Kbs House 5 Springfield Court, Summerfield Road, Bolton, England, BL3 2NT.

If you would like to direct any questions or comments to our EU representative, please send an email to [email protected].

We take our data protection obligations extremely seriously. If for some reason you are not entirely satisfied with how your data has been processed, please direct your concerns to [email protected]. We will endeavour to respond to you as soon as possible. We may need to conduct investigations to help us to understand and address your concerns, and we will keep you updated on the progress of any investigations.

4 How we collect and receive personal data

We collect and receive personal data through the following methods:

Personal data you provide to us. You may give us your personal data directly, for example, when you use our Services, contact us with enquiries, complete forms on our Sites, subscribe to receive our marketing communications or provide feedback to us, or if we contact you by phone.
Personal data we collect automatically, including through cookies and other similar technologies. When you access and use our Sites, we may collect Technical Data and Usage Data automatically, including through our use of cookies and other similar technologies. For more information about this data, please see our Processing Activities Schedule. For more information about our use of cookies and other similar technologies, please see the Cookies section.
Personal data we receive from our clients or other third parties. We may receive personal data from our clients (which may include an organisation in respect of whom you are a shareholder or whom you currently work with or were previously engaged by) and other third parties. Such third parties may include analytics providers, data suppliers and brokers, credit reference agencies, advertising networks, search information providers, third-party directories and third parties that provide technical services to us so that we can provide our Site and our Services.
Personal data that is publicly available. We may collect personal data that is available from public sources (including media publications) or that you or a third party may otherwise publish (for example on websites, posts on social media platforms, or speeches at events).

5 Personal data we control

We may process or otherwise be a controller of the following personal data:

Identity Data. Name (first, middle, and last); and title.
Contact Data. Email address; telephone number; and postal address.
Professional Data. Job title; and organisation that you represent (where you or your organisation supplies products or services to us).
Image Data. Photos or video recordings that feature you or your likeness, including images which we take or obtain if we engage you to promote our business, or when you visit our premises or attend events that we host.
Financial Data. Data about your financial affairs including bank account details, loans, investments, payment details, receipt details, tax status and your credit worthiness (as we may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you)

Special Category Data. Special category data, such as: trade union membership or information about individuals’ health

Transaction Data. Details of Services purchased from us or products and services that we may purchase from you or the organisation that you work for, including payment information (such as payment card details, bank account details and billing address).
Profile Data. Date of birth; gender; personal pronouns; country of residence; nationality; information about your interests, affiliations and preferences, including any dietary requirements; other information that you supply in connection with your use of our Sites or in your interactions with us (including in relation to our promotions or competitions, your provision of feedback or responses to our surveys, or your attendance at an event); and the content of any communications when you contact us.
Usage Data. Data observed or collected in relation to browsing activity on our Site or interaction with our emails, interaction with ads that you see as a result of the activities described in the Online Advertising Activities section, or attendance at our events. This may include information about pageviews and events on our Sites; information about the webpage or other source that users were previously on before reaching our Sites; information about when a browsing session started and ended; and information about views of and clicks on our ads, together with advertising or other identifiers associated with a user or their device (e.g. a device’s IDFA (iOS) or AAID (Android) or advertising cookie identifiers); and information about sessions attended and networking interactions at our events.
Technical Data. IP address; details of the Site that you are viewing, such as full web page URL; browser type, device type and operating system and any other information available to us about the device you are using; location data, including the geographic location (which may be approximate, like the city or region you are in, or more precise) of a device derived from IP address, GPS signals or information about a device’s connection with local Wi-Fi equipment; diagnostic data (including crash logs, launch time, hang rate and energy use, and any other data collected for technical diagnostics purposes), and any relevant unique identifiers assigned to a device or browser (including cookie identifiers).
Social Media Data. Information that is logged by the third-party providers of social media platforms in relation to events that users take in relation to our social media pages or content. Events can include views, clicks, following or unfollowing, and any other types of interaction with our page or content. This information may be combined by third-party providers of social media platforms with other information about the person taking the action and the device they are using, such as social media handles, the date and time of the event, the country/city (derived from IP address or social media profiles) of the user, age/gender information and the type of device used. Unless specified otherwise in this Privacy Notice, this personal data is not shared with us, but third-party social media providers may use it to provide us with anonymous and aggregate statistics about our social media pages and content, and we may be a joint controller of this personal data, as described in the Social media insights and interaction and Advertising and Social Media Partners sections.
Advertising Partner Data. Information obtained independently by our Advertising Partners as described in the Online Advertising Activities section. This may include unique identifiers and a profile of your possible interests and characteristics, which may have been built by observing your activity on websites, apps and other digital properties, including those operated by third parties, that use our Advertising Partners’ services. Unless specified otherwise in this Privacy Notice, this personal data is not shared with us, but we may be a controller of it in relation to purposes described in this Privacy Notice.
Incident Data. Information about any injury that you suffer or incident you may be involved in (including witness) at an event hosted by us or if you visit our premises and any other personal data collected during the process of completing our incident report.
Communications Data. Marketing preferences; and service communication preferences.
Recruitment Data. Profile Data (to the extent that it is relevant to our recruitment activities or you volunteer it during our recruitment process), together with other information including details of your eligibility to work (including documents and information that we may collect to verify this, such as your national insurance number, tax status and other tax or governmental identifiers, your driving licence(s) (including copies where we are required to hold such information for identification or insurance purposes where you or other members of your family are to use our vehicles), and other identification documents such as your passport, utility bills, and identity cards); your work preferences (including areas and dates where you are available for work); skills, qualifications, training and work history; any personal data which appears in your curriculum vitae or application; information about your current employment (such as salary, bonus, commission, remuneration, profit share, annual leave, pension, benefits, and location of your employment); and any other personal data that you volunteer during our recruitment process.

6 Our processing activities

We process your personal data for the following purposes:

to provide you with our Sites;
to provide you with Services;
to deal with customer services and enquiries, carry out surveys and obtain feedback, and to manage public relations;
to optimise our business through the use of data, including through insight and analytics,;
to carry out online and other advertising and marketing activities;
for recruitment purposes; and
for business administration and legal compliance purposes, including to exercise or defend legal claims.

For more information about our processing activities, including the personal data that is processed in connection with those activities, please see our Processing Activities Schedule.

7 Cookies

Where indicated in this Privacy Notice, cookies, web beacons, pixel tags and other similar technologies (“Cookies”) may be used for the purposes described in this Privacy Notice. In addition to the information set out in this Privacy Notice, please visit the relevant Group Company’s website for further information about the Cookies that we use on our Sites, and to learn how you can manage your consent to the use of non-essential Cookies.

In some cases, the Cookies that we use may be provided by a third party. Information about you may be shared with the relevant third party and used in accordance with their privacy notice.

In addition, where we use Cookies relating to services provided by Google, Google has published information about how it uses personal data in connection with its services here. Google also provides further information about:

How it uses personal data in connection with Google Analytics here. If you do not want your personal data to be used for the purposes of Google Analytics, you can install the Google Analytics opt-out browser add-on (but please note that this will only work on certain browsers) which is available here.
How it uses personal data in connection with its online advertising services in its Privacy Policy and here. You can also use Google’s Ad Settings to manage your online advertising preferences.

Please note that you can also manage your Cookie preferences using functionality provided by your browser, but please be aware that to use some parts of our Sites you will need to allow essential Cookies. If you block essential Cookies, some parts of our Sites may not work properly, or you may not be able to access our Sites.

For more general information about Cookies and managing Cookies, including blocking or deleting cookies for a wide variety of browsers, visit All About Cookies.

On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

8 Sharing personal data

We only share personal data with third parties or other entities within our group of companies when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data and to maintain the confidentiality and security of it.

The circumstances where we may typically share personal data are set out below, though please note that there may be other circumstances where we need to share personal data that are not set out below.

Group Companies in the K3 Capital Group. We share personal data with other entities within the K3 Capital Group to ensure we are providing our services to you in an effective and efficient manner in collaboration with Group Companies where necessary, and to enable each Group Company to send you relevant communications that we think may be of interest to you.
Third-party suppliers who provide applications/ functionality, data processing or IT services. We share personal data with third parties who support us in providing our Sites and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics.
Payment providers and banks. We share personal data with third parties who assist us with the processing of payments.
Delivery and courier companies. We share personal data with suppliers who assist us in the delivery of our documents, information and materials.
Advertising partners. We share personal data with third party advertising partners. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities. For more information, please see the Advertising and Social Media Partners section.
Third-party post/email marketing, data brokers and CRM specialists. We share personal data with specialist suppliers including data brokers who assist us in managing our marketing database and sending out our post, email and social media marketing communications and account-related communications.
Event partners and suppliers. When we run events, we may share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we may share your personal data with such organisations for use in relation to the event.
Recruitment agencies, data directories and providers, and related organisations. We share personal data with external recruiters and third-party providers that undertake background checks on our behalf, and with data providers that we work with.
Auditors, lawyers, accountants and other professional advisers. We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies. We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties. Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

9 Your rights

You have the following rights in relation to your personal data:

Your right of access. If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification. If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.
Your right to erasure. You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to restrict processing. You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to data portability. You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.
Your right to object. You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.
Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the How to contact us section or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the How to contact us section. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.ftab

10 Information security

We are committed to keeping personal data secure and we have implemented information security policies, rules and technical measures to protect personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, our personnel and data processors (third parties that process personal data on our behalf) are obliged to respect the confidentiality of the personal data relating to users of our Sites and those who purchase our Services.

11 How long we keep your personal data

We will only keep your personal data for as long as necessary for the purposes set out in this Privacy Notice. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

12 Third-party links and services

This Privacy Notice only applies to personal data processed by us.Our Sites may contain links to third-party websites, apps or services. We have no control over these third-party websites, apps or services and this Privacy Notice does not apply to your interaction with the relevant third parties.

13 Personal data of minors

Our Sites and Services are not intended for use by, or targeted at, minors (individuals under the age of 18). However, this does not prevent minors from providing personal data to us. Where we do process personal data of minors, we will comply with all applicable laws and regulations relating to that processing.

14 If you fail to provide your personal data

Where we are required by law to collect personal data, or we need to collect personal data under the terms of a contract we have with you, and you fail to provide that personal data, we may not be able to fulfil any obligations that we owe to you, and we may not be able to enter into or perform a contract with you. This may apply where you do not provide personal data that we need to provide our Services or to process an application to register an account. In these circumstances, we may have to cancel the provision of the relevant Services to you, in which case we will notify you.

15 International transfers of personal data

Certain Group Companies within the K3 Capital Group are located outside the UK and the EEA (see the “About us” section in this Privacy Notice for more details). Therefore, your personal data may be processed by us in certain non-UK and non-EEA jurisdictions.

We may also transfer personal data to third parties (as described in the “Sharing Personal Data” section in this Privacy Notice) that are located in countries that do not have data protection laws that protect personal data to the same standard as the data protection laws in the UK and the EEA (such as the GDPR).

These third countries may not give you the same rights as under the GDPR in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns.

However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

When transferring personal data to third countries, we usually rely on one of the following:

Adequacy decisions: We may transfer your personal data to countries or organisations that have been deemed to provide an adequate level of protection for personal data by the European Commission, the UK Government, or any other relevant government body. This may include transfers to organisations that participate in the Data Privacy Framework listed here.
Contractual safeguards: We may use specific contracts approved by the European Commission, the UK Government, or any other relevant governmental body to safeguard personal data. The contracts that we usually rely on are referred to as “Standard Contractual Clauses” or “SCCs”, although we may from time to time use other approved mechanisms. To find out more about the SCCs we use, please see here (EU) and here (UK). You can also contact us using the contact details set out in the How to contact us section.

16 Use of AI as part of our Recruitment process

16.1 We may also use AI and automated technologies to collect information about you as part of the pre-screening stage of our recruitment processes.

16.2 The tool will be extensively trained by us to recognise responses that meet the minimum criteria requirement and will undergo regular testing to ensure that any decisions based on your responses remain fair, effective and non-discriminatory.

16.3 Please note, you have the right to appeal decisions that we make in this way. If you wish to do so, then please contact us using the information set out in the “How to contact us” section above.

16.4 Please note, you may also opt out of this process if you do not consider you are able to respond effectively to the tool. In such circumstances, you will be referred to a human interviewer to continue the pre-screening process/ your application will be subject to manual review.

17 Additional information if you are using a Group Company for services relating to insolvency appointments

17.1 Identity and contact details of the data controller.

For the purpose of the UK / EU GDPR, where an insolvency practitioner of a Group Company is not appointed as office holder, the relevant data controller is either the company/individual on whose instructions Group Company is acting, or it is the Group Company depending on the nature of the processing.

Where an insolvency practitioner of Group Company is appointed as office holder and the data processing is carried out as part of their statutory duties, the office holder(s) is/are the data controllers.

If one or more Group Companies are jointly instructed to provide insolvency services, those Group Companies will be considered “joint controllers” for the purpose of the UK/EU GDPR.

17.2 Lawful basis for processing

Please see our Processing Activities Schedule for information about how we process your personal data in connection with the provision of our insolvency services. For our insolvency services, most processing is carried out to comply with our legal obligations under statute and other regulatory obligations related to the insolvency process. For example, we have a statutory duty to circulate the Statement of Affairs which will include, amongst other information, the names and postal addresses of shareholders, companies’ creditors (including current employees, former employees, and consumers). Some processing may be for the legitimate interests of all stakeholders in the insolvency process, as they are entitled to be kept informed and may wish to engagement in the insolvency process.

17.3 How to contact?

For more information about our processing of your personal data in connection with the provision of insolvency services please contact [email protected] or see our “How to contact us” section above.

18 Advertising and Social Media Partners

Where the GDPR applies, this section provides information about third parties that may be a controller of your personal data in relation to certain activities described in this Privacy Notice, meaning that the third party may (alone or jointly with us) determine how and why they will use your personal data.

Meta (Facebook)

We are joint controllers with Meta in respect of online advertising activities, where those activities involving advertising to you on platforms owned and operated by Meta (including Facebook and Instagram). When we refer to Meta, we mean Meta Platforms, Inc. if you are a UK resident, and Meta Platforms Ireland Limited if you are an EU resident.

We and Meta have entered into Meta’s Controller Addendums (available here (EU) and here (UK))to determine our and Meta’s responsibilities for compliance with data protection obligations in relation to our online advertising activities. We and Meta are each responsible for providing information about how your data might be processed in connection with these activities in our privacy notices. Meta has primary responsibility for giving effect to your data subject rights (see the Your rights section of this Privacy Notice) in respect of these activities.

In addition, where we receive insights from Meta for the purposes described in the Social media pages and insights section, we are joint controllers with Meta in relation to Meta’s processing of their Social Media Data to provide those insights to us. For more information, please see Meta’s Information about Page Insights Data here.

For further information about how Meta uses your personal data in connection with these activities, including the legal basis Meta relies on and the ways to exercise your data subject rights against Meta, please see Meta’s Privacy Policy at https://www.facebook.com/about/privacy.

LinkedIn

LinkedIn Ireland Unlimited Company (LinkedIn) is a controller of your personal data when our online advertising activities involve advertising to you on LinkedIn. LinkedIn has published information about how it uses your personal data in connection with its advertising services, including how you can opt-out of LinkedIn’s interest-based advertising, here and here.

In addition, where we receive insights from LinkedIn for the purposes described in the Social media pages and insights section, we are joint controllers with LinkedIn in relation to LinkedIn’s processing of their Social Media Data to provide those insights to us.

For further information about how LinkedIn uses your personal data in connection with these activities, including the legal basis LinkedIn relies on and the ways to exercise your data subject rights against LinkedIn, please see LinkedIn’s Privacy Policy at https://www.linkedin.com/legal/privacy-policy

19 International privacy laws and requirements

As noted above this Privacy Notice is intended to meet the requirements of the GDPR. Accordingly, we will process your personal data in accordance with GDPR principles irrespective of your location. However, if you are resident in a territory in which we operate but outside of the UK and/or EEA, additional privacy laws may apply to our processing of your personal data. For more information about our obligations in your local territory, please see your relevant data protection authority’s website for further information.

Processing Activities Schedule

This Schedule sets out detailed information about the purposes for which we process the personal data described Personal data we control section and the lawful bases we rely on to do so.

This Schedule is split into the following sections – please click on the link below to be taken to the relevant section:

Providing our Sites and carrying out other online activities
Provision of Services
Customer Services, Feedback and Relationship Management
Insight and Analysis, Data Improvement and Personalisation
Online Advertising Activities
Other Advertising and Marketing Activities
Recruitment
Business Administration, Compliance and Legal Affairs

1. Providing our Sites and carrying out other online activities

Purpose and Personal Data Processed	Description	Lawful Basis
Delivery of our Site Technical Data	To provide our Site to you, including ensuring that we are showing you the correct notices and information, and recording your preferences in relation to our Cookies. Essential Cookies are used on our Sites for this purpose. Please see the Cookies section for further information.	Legitimate interests – to provide our Site effectively. Compliance with a legal obligation. Performance of a contract.
Support, maintenance and security Identity Data Contact Data Registration Data Technical Data	To administer and protect our Sites and users (including troubleshooting, fixing errors, analysis, testing, system maintenance, support, and security, including for fraud monitoring and prevention). To respond to user enquiries/offer support to users. We may use your information to respond to your enquiries and solve any potential issues you might have with the use of our Sites. To request feedback and to contact you about your use of our Sites. Essential Cookies are used on our Sites for this purpose. Please see the Cookies section for further information.	Legitimate interests – to run our business and to protect us and our users from harm. Compliance with a legal obligation.
Provision of location-based and other special features Technical Data	To provide you with location-based and other special features through our Sites by accessing your device’s location or other functions. For example: to send push notification reminders, alerts, updates and other information; to use your location when you use certain parts of our Sites that provide location-based functionality, such as showing you which of our offices are close to you; to enable functionality that requires access to your device’s camera or microphone, photo and videos, or contacts. You will be asked if you want to share this access before using these functions for the first time.	Consent through permissions granted on your device.
Site development and improvement Usage Data Technical Data	To develop and improve our Sites, including content that we make available, through insight and analysis that we carry out in relation to the use of our Sites as described in the Insight and analysis section. Non-essential Cookies are used on our Sites for this purpose. Please see the Cookies section for further information.	Consent (where non-essential Cookies are used on our Sites). Legitimate interests – to improve and enhance our Sites (where non-essential Cookies are not used).
Set up and manage user accounts Identity Data Contact Data Communications Data Profile Data Technical Data	To set up and manage user accounts, including to verify users when logging into accounts and secure areas of our Sites, which may be required to access to certain features, functionality, or benefits of our Sites. To contact users about their accounts.	Performance of a contract. Legitimate interests – to provide secure and effective access to the Sites.
Personalisation of our Site Usage Data Technical Data Profile Data	To personalise user experiences when using our Site, such as showing our users content and Site features that we think may be of interest or relevance to our users. Non-essential Cookies are used on our Sites for this purpose. Please see the Cookies section for further information. In addition, activities described in the Insight and Analysis, Data Improvement and Personalisation section may be relied on to carry out this activity.	Consent (where non-essential Cookies are used on our Sites). Legitimate interests – to give users of our Sites the best experience (where non-essential Cookies are not used).

2. Provision of Services

Purpose and Personal Data Processed	Description	Lawful Basis
Supply of our Services Identity Data Contact Data Transaction Data Professional Data Financial Data Special Category Data	To register or onboard you as a customer (as an individual or corporate customer) which may include identity checks. To process and deliver your request for our Services, including to manage and collect any fees or charges from you (or your organisation). To maintain our customer databases. To comply with our legal and regulatory obligations To keep a record of our Services provided, including (where necessary) keeping a record of any phone calls we have with you. To understand your need and how they may be met through our Services; To process financial transactions in connection with our Services To prevent and detect crime, fraud, or corruption arising as a result of your use of our Services	Performance of a contract. Legitimate interests – to provide the Services in an effective, safe and efficient way, and to exercise our rights in relation to transactions, including to receive payment of monies owed to us. Compliance with a legal obligation.
Creating an internal, centralised database for Group Companies Identity Data Contact Data Transaction Data Professional Data	To create a centralised database and make relevant data available to other Group Companies within the K3 Capital Group who are interacting with you or providing you with Services, to make our service provision more efficient and tailored to your needs. To enable each Group Company to send relevant marketing communications about service offerings by our Group that we think may be of interest to you.	Legitimate interests – to perform our obligations in accordance with any contract that we may have with you for the provision of our Services, and to ensure that we (including our Group Companies) provide our Services in an effective, safe and efficient way.
Administration of Events Identity Data Contact Data Profile Data Image Data Professional Data Location Data Usage Data Incident Data Technical Data	To register you as a visitor or exhibitor at one of our events. If you are a speaker at our event, we may publish your name in association with the event. To provide you with important information about our events. To facilitate your travel to our events, if you are a speaker or exhibitor. To make other logistical arrangements with you in connection with your attendance at the event (e.g. in respect of your exhibitor space). Photographs and video footage may be taken at our events and published for promotional and advertising material. We may send you SMS for operational purposes and the smooth running of an event, e.g. to inform of a travel update.	Performance of a contract. Legitimate interests – to provide information about speakers at an event. Legitimate interests – to promote our events. You can opt out of your image being used at any time. Legitimate interests – to provide necessary information about our events. Explicit consent (in respect of any special category data).
Event insight and engagement Identity Data Contact Data Technical Data Usage Data Professional Data Incident Data	To gain insights about attendance and engagement at our in-person events, including to monitor attendance of individual sessions, understand interactions between attendees, manage and optimise our events. These insights will only be used to generate aggregate information about our event attendees and will not be used to identify or target any individual attendee. We may also provide attendees with the option to share their live location with other attendees to aid networking, and the ability to digitally exchange contact information. In some cases, we may also make personalised recommendations to attendees about our sessions or networking opportunities. We may carry out these activities through any app that we use for the purpose of the event, or through event passes and beacons located at a venue. For example, we may capture your location if you scan your pass or if you are in close proximity to an exhibit that has a beacon.	Consent (where required). Legitimate interests – to measure the success of our events and to assist in future event planning, and to help attendees network more effectively and get the most out of our events.

3. Customer Services, Feedback and Relationship Management

Purpose and Personal Data Processed	Description	Lawful Basis
Customer services and general enquiries Identity Data Contact Data Transaction Data Profile Data Professional Data Communications Data	To manage and respond to any enquiry that you submit to us. To record phone calls for training and monitoring purposes only, and to ensure we are providing you with our Services in an effective and efficient manner.	Legitimate interests – to help with your enquiry, provide a good standard of service and improve our customer services.
Social media insights and interaction Identity Data Contact Data Social Media Data	To gain insight into our social media pages (including, but not limited to, LinkedIn and Facebook), we may receive insights from the third-party provider of the social media platform about how users interact with our pages. We receive this information so that we can understand how many people saw our social media content, which content people are engaging with the most, actions users are taking on our pages (such as whether they are visiting our Sites after visiting our pages, clicking on any content), and the demographics (such as age, gender and location) of those that view our social media pages. These insights are derived from personal data that the third-party provider of the social media platform processesand are only provided to us in the form of anonymous and aggregate statistics – we do not receive your personal data or any information that we can use to identify you when we receive these insights. In addition, we may also see who has ‘liked’ or shared content that we post on social media (including when you interact with any ‘like’ or similar embedded feature on our Sites). Note, we may be joint controllers with the relevant social media platform in relation to the insights that we receive. For more information, please see the Advertising and Social Media Partners sections.	Legitimate interest – to promote our Sites and Services via social media and improve the content that we post on social media, including to ensure that our content is relevant to persons that we would like to engage with on social media.
Managing our relationship with you or the organisation you work for Identity Data Contact Data Profile Data Transaction Data Professional Data Communications Data	To manage our relationship with you or the organisation you work for (where your organisation is a customer of, or supplier to, us), including to contact you about any matter concerning an order for our Services that you have placed, to contact our suppliers about goods or services that we have purchased or may purchase from them, and to provide you with other important information (including about changes to our terms and conditions or this Privacy Notice).	Performance of a contract. Legitimate interests – to provide those that we work with the best experience and to ensure effective business administration. Legitimate interests – to effectively manage our supply chains. Compliance with a legal obligation – to comply with our consumer rights and privacy obligations.
Survey and feedback Identity Data Contact Data Transaction Data Profile Data Communications Data	To help us to monitor and improve our Sites and Services, and to assist with the selection of future services and to train our personnel, we may carry out surveys or ask you for feedback.	Legitimate interests – to improve our Sites and our Services, and provide them in an effective way.
Public Relations and Media Identity Data Contact Data Profile Data Professional Data Communications Data	To respond to media enquiries and requests (including interview requests, requests for comment, and requests for information) that we receive, or address reports in the media that concern us, we may process personal data relating to journalists, reporters and other media professionals. We may also send these persons corporate communications and other information by email for media and public relations purposes.	Legitimate interests – to ensure that our business is fairly and accurately represented in the media. Legitimate interests – to provide the right information to those who request it or otherwise have an interest in receiving it.

4. Insight and Analysis, Data Improvement and Personalisation

Purpose and Personal Data Processed	Description	Lawful Basis
Insight and analysis Technical Data Usage Data Profile Data	To carry out insight and analytics, including: to carry out insight and analytics in relation to our Sites, including counting user visits to our Sites, combining this with general insights about our users’ interests and browsing habits so that we can understand the type of user that our Sites appeals to, and learning what content and features of our Sites are most popular – these insights and analytics are used for the purposes described in the Site development and improvement section;to count the open rate and measure the effectiveness of our marketing emails;to measure the effectiveness of our online advertising, including to generate aggregate statistics that do not identify individuals (for example, counting how many people viewed or clicked on our ads and were redirected to our Sites through one of our ads);to gain general insights about customers and their purchase or use of our Services, so that we can develop future service offerings; andto analyse the success of our events, including assessing sign-up rates, monitoring social media, online forums, and other online content, and collecting and analysing event feedback. Some of the insights and analysis that we gather may be used by us to support the activities described in the Personalisation section. Non-essential Cookies are used our Sites for this purpose. Please see the Cookies section for further information.	Legitimate interests – to develop and improve our Sites and our Services and to support other activities described in this Privacy Notice (where non-essential Cookies are not used). Consent (where non-essential Cookies are used).
Data improvement Identity Data Contact Data Profile Data	To improve the quality of our data through the use of services and the data of third-party data suppliers, including to: enrich the data we hold about our customers and users (for example, adding data to information that we already hold);carry out data cleansing and tracing (for example, identifying redundant records and updating records);segment our customers and users (for example, identifying target sub-groups of our customers or users). Some of activities set out in this section, may be used by us to support the activities described in the Personalisation section.	Legitimate interests – to ensure the effective and efficient use of data and to support other activities described in this Privacy Notice. Compliance with a legal obligation.
Personalisation Technical Data Usage Data Profile Data Advertising Partner Data	To tailor the information and experiences provided to our users and customers, so that they are more likely to be of interest and relevance, including in relation to: user experiences on our Sites as described in the Personalisation of our Sites section;our marketing communications described in the Marketing communications section;our online advertising described in the Online Advertising Activities section. The activities described in the Insight and analysis and Data improvement sections may be relied on to carry out this activity. Non-essential Cookies are used our Sites for this purpose. Please see the Cookies section for further information.	Legitimate interests – to give users and customersthe best experience, and to support our marketing and advertising activities, where non-essential Cookies are not used. Consent (where non-essential Cookies are used).

5. Online Advertising Activities

We may share your personal data with, or otherwise use the services of, third-party social media and advertising technology companies (“Advertising Partners”), so that we can advertise our business, including our Sites and our Services, on websites, apps, and other digital platforms, including social media, that are operated by third parties (“Third-party Sites”).

Our online advertising activities are explained in more detail below. If you see one of our ads, this may be the result of one or a combination of these activities.

Please note:

Some of the advertising that you see based on these activities may be personalised to you. Please see the Personalisation section for further information.
We may be joint controllers with our Advertising Partners, or our Advertising Partners may be independent controllers, in relation to the activities described in this section. For more information, please see the Advertising and Social Media Partners sections.

Purpose and Personal Data Processed	Description	Lawful Basis
‘Custom Audience’ advertising (also known as ‘Custom Match’ advertising) Contact Data Usage Data (identifiers only) Advertising Partner Data	To enable our Advertising Partners to ‘match’ identifiers which we have obtained (for example, your email address or your device’s advertising identifier) with identifiers that are available to our Advertising Partners, including those relating to registered users of Third-party Sites. The matched identifiers are known as a ‘custom audience’. We and our Advertising Partners create this custom audience so that our ads will be displayed to individuals whose identifiers are included in the custom audience when those individuals use the relevant Third-party Site (e.g. to show you an ad on your Facebook newsfeed). Our custom audience may also be used to exclude individuals from seeing our ads (because we want to show ads to people who are not our existing customers or users).	Consent (in relation to data that we share with our Advertising Partners). Legitimate Interests – to increase the effectiveness of our advertising (to the extent we are a controller of Advertising Partner Data or we have not obtained your consent).
‘Lookalike Audience’ advertising Contact Data Usage Data (identifiers only) Advertising Partner Data	To ask our Advertising Partners to find other people that share similar interests and characteristics to the individuals who are in our custom audience (as described in the ‘Custom Audience’ advertising section), so that we can show our ads to those other individuals when they use Third-party Sites. This activity is known as ‘lookalike audience’ advertising because the individuals who see our ads ‘look like’ the individuals who form part of our custom audience. For example, our Advertising Partners may use their data to identify that 70% of our custom audience are men aged between 20-25. We then ask our Advertising Partners to show our ads to other men aged between 20-25. Our Advertising Partners do not provide their Advertising Partner Data to us, but they may provide us with aggregate insights about the individuals who are shown our ads (for example, their age, gender, approximate location and interests).	Legitimate Interests – to increase the effectiveness of our advertising by finding new people who we may wish to advertise to. See the ‘Custom Audience’ advertising section to understand the lawful basis we rely on to create our custom audience.
Advertising on Third-party Sites using Cookies and our Advertising Partners’ tools Technical Data Usage Data Advertising Partner Data	To display our ads to you when you visit Third-party Sites, including to: recognise you as a user of our Sites and to display ads for Services that you have viewed on our Sites; and reach users of Third-party Sites who meet certain criteria determined by us or our Advertising Partners using selection tools made available by our Advertising Partners (for example, users who are likely to be men or are aged between 20-25). Non-essential Cookies are used on our Sites to recognise you as a user of our Sites. Please see the Cookies section for further information. In addition, our Advertising Partners may use non-essential Cookies on Third-party Sites, as well as Advertising Parter Data that they have independently collected, for this purpose. We are not responsible for these technologies and you should separately review the information provided to you on the Third-party Site about these technologies.	Consent (where non-essential Cookies are used on our Sites). Legitimate interests – to increase the effectiveness of our advertising by displaying our ads to individuals who are most likely interested in it based on criteria determined by us and our Advertising Partners (where other personal data is used).
Measuring the effectiveness of our advertising Usage Data Technical Data Advertising Partner Data	To determine how successful our other advertising activities described in this Online Advertising Activities section have been, and to understand who has viewed or interacted with our ads. We may do this to: generate insight and analysis about our advertising activities, as described in the Insight and analysis section; andpersonalise experiences, as described in the Personalisation section. Non-essential Cookies are used on our Sites to recognise you as a user of our Sites. Please see the Cookies section for further information. In addition, our Advertising Partners may use non-essential Cookies on Third-party Sites, as well as Advertising Parter Data that they have independently collected, for this purpose. We are not responsible for these technologies and you should separately review the information provided to you on the Third-party Site about these technologies.	Consent (where non-essential Cookies are used on our Sites). Legitimate interests – to understand the type of advertising and marketing content that is most likely to be of appeal (where other personal data is used). Legitimate interests – to increase the effectiveness of our advertising by collecting information about which of our ads an individual has responded to, so that we can show that individual similar ads, or other ads that may be of interest to them, in the future.

6. Other Advertising and Marketing Activities

Purpose and Personal Data Processed	Description	Lawful Basis
Marketing communications Identity Data Contact Data Communications Data	To promote our Sites, our Services, or to otherwise promote our business (including events), via email, telephone or post, including to enable each Group Company (whether directly, or via a third party marketing agency acting on our behalf) to send relevant marketing communications about service offerings by our Group that we think may be of interest to you. To ensure that the marketing content that is provided to you is more likely to be of interest, our marketing communications may be personalised. For more information, please see the Personalisation section.	Consent (where marketing via email). Legitimate interests (where marketing via telephone and post) – to grow our business. You can unsubscribe from our email marketing by clicking the ‘unsubscribe’ link in our emails. You can also ask us to stop using your personal data for our direct marketing activities by contacting us using the details set out under the How to contact us section.
Third-party marketing (lead generation) Identity Data Contact Data Profile Data Communications Data	To share your personal data with third-party partners to enable them to contact you in relation to send marketing to you in relation to their products and services, including to contact you in relation to events.	Consent. Legitimate interests – to provide marketing services to third parties and to help those third parties grow their business, and for our third-party partners’ (including, for example, event sponsors’) legitimate interests to get the most out of an event and to promote their business to you.

7. Recruitment

Purpose and Personal Data Processed	Description	Lawful Basis
Recruitment Identity Data Contact Data Recruitment Data	To assess your suitability for any of our positions that you apply for. To assess your eligibility to work in the location where the position is based. To communicate with you about the recruitment process. To communicate with you about future opportunities to work with us. To keep records about our recruitment process. To comply with our legal and regulatory obligations in relation to recruitment. To review our equal opportunity profile in accordance with applicable legislation.	Legitimate interests – to ensure that we can make the best recruitment decisions. Performance of a contract or to take steps at your request prior to entering into a contract. Compliance with a legal obligation.

8. Business Administration, Compliance and Legal Affairs

Purpose and Personal Data Processed	Description	Lawful Basis
Business administration and legal compliance Identity Data Contact Data Profile Data Usage Data Technical Data Incident Data Communications Data Recruitment Data Professional Data	To comply with our legal obligations. To enforce our legal rights or defend against potential legal claims. To protect the rights of third parties. To facilitate a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.	Legitimate interests – to operate our business effectively. Compliance with a legal obligation.
Security Identity Data Contact Data Image Data	To implement and manage physical security measures. Security measures are in place at our premises, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need-to-know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft). Visitors to our premises may be required to sign in on arrival and where that is the case, we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).	Legitimate interests – to keep our premises secure and provide a safe environment for our personnel and visitors to our premises.
Health, Safety and Incidents Identity Data Contact Data Profile Data Incident Data	To report or manage a health and safety or other type of incident that occurs at our premises or at one of our events.	Compliance with a legal obligation. Legitimate interests – to effectively manage an incident, including to assess our handling of an incident to help us improve our processes. Necessary to protect vital interests.