PRIVACY POLICY

Privacy Policy

Iron Octopus Limited (company number 09899797) (“IOL”) takes your privacy very seriously and is
committed to protecting your personal data. Please read this privacy policy carefully as it will inform
you as to how we look after your personal data when you visit our website (regardless of where you
visit it from), purchase services from us or otherwise interact with us and it tells you about your privacy
rights and how the law protects you.
It is important that you read this privacy policy together with any other privacy policy or fair processing
policy we may provide on specific occasions when we are collecting or processing personal data
about you so that you are fully aware of how and why we are using your data. This privacy policy
supplements the other policies and is not intended to override them.
Please use the Glossary at the end to understand the meaning of some of the terms used in this
privacy policy.
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).
Given the nature of our website, we do not expect to collect the personal data of anyone under 13
years old. If you are aware that any personal data of anyone under 13 years old has been share with
our website, please let us know so that we can delete that data.
This privacy policy is divided into the following sections:
1. Important Information and who we are
2. Personal data we collect about you
3. How your personal data is collected
4. How and why we use your personal data
5. Marketing
6. Who we share your personal data with
7. Transferring data
8. Cookies
9. Your rights
10. How to complain
11. Data security
12. Data retention
13. Changes to this privacy policy
14. How to contact us
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how IOL collects and processes your personal
data through your use of this website, including any data you may provide to us or through this
website when you sign up to our newsletter, contact form, quote forms, purchase services or take
part in a competition.
Controller
IOL is the controller and responsible for your personal data (collectively referred to as “company”,
"we", "us" or "our" in this privacy policy).
We have appointed a Privacy Manager who is responsible for overseeing questions in relation to
this privacy policy. If you have any questions about this privacy policy, including any requests to

exercise your legal rights, please contact the Privacy Manager using the details set out below. In the
Privacy Manager’s absence please contact the Deputy Privacy Manager. Our contact details are:
Full name of legal entity: Iron Octopus Limited
Name of Privacy Manager:
Email address:
Postal address:
Telephone number:
You have the right to make a complaint at any time to the Information Commissioner's Office
(“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so please
contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was introduced on 1 st July 2024 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy statements. When you
leave our website, we encourage you to read the privacy policy of every website you visit.
2. Personal data we collect about you
Personal data, or personal information, means any information about an individual from which that
person can be identified ("Personal Data"). It does not include data where the identity has been
removed (anonymous data). We may collect, use, store and transfer different kinds of personal data
about you which we have grouped together follows:
- Identity data includes first name, maiden name, last name, title, date of birth and gender.
- Contact Data includes billing address, site address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services
you have purchased from us.
- Technical Data includes IP address, your login data, browser type and version, time zone setting
and location, browser plug-in types and versions, operating system and platform and other
technology on the devices you use to access this website.
- Profile Data includes your orders and enquiries made by you, your interests, preferences,
feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us
and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal
data in law as this data does not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or

indirectly identify you, we treat the combined data as personal data which will be used in accordance
with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health and genetic and biometric data). Nor do we collect
any information about criminal convictions and offences.
If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and
you fail to provide that data when requested, we may not be able to perform the contract we have or
are trying to enter into with you (for example, to provide you with services). In this case, we may have
to cancel a service you have with us but we will notify you if this is the case at the time.
Sometime, you can choose if you want to give us your personal data and let us use it. Where that is
the case we will tell you how and give you the choice before you give your personal data to us. We
will also tell whether declining to share that personal data will have any effect on how you use our
services.
We collect and use this personal data for the purposes described in the section ‘How and why we use
your personal data’ below.
3. How your personal data is collected
We use different methods to collect data from and about you including through:
- Data by filling in forms or by corresponding with us by post, phone, email, on our website or
otherwise. This includes personal data you provide when you:
apply for our services:
a. subscribe to our services or publications;
b. request marketing to be sent to you;
c. enter a competition, promotion or survey; or
d. give us some feedback
Automated technologies or interactions. As you interact with our website, we may
automatically collect Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies and other similar technologies. We may also
receive Technical Data about you if you visit other websites employing our cookies. Please
see our Cookie Policy for further details.
- Indirectly through your browsing activity while on our website; we will usually collect
information indirectly using the technologies explained in the section on ‘Cookies’.
4. 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, for
example:
- 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 of 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.
You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
Generally we do not rely on consent as a legal basis for processing your personal data other
than in relation to sending third party direct marketing communications to you via email or text
message. You have the right to withdraw consent to marketing at any time by contacting us.
As such, we will only use your personal data when the law allows us to. Most commonly, we will
use your personal data in the circumstances set out below. We have set out below, in a table
format, a description of all the ways we plan to use your personal data, and which of the legal
bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.
What we use your personal
data for

Type of data Lawful basis for processing
including basis of legitimate
interest

Create and manage your
account with us / to register
you as a new client

(a) Identity
(b) Contact
(c) Profile

For our legitimate interests, i.e.,
to be as efficient as we can so
we can deliver the best service
to you at the best price and;
To perform our contract with you
or to take steps at your request
before entering into a contract.

Providing services to you such
a processing and delivering
your order including:
a. Managing payments, fees
and charges;
b. Collecting and recovering
money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
communications

a. To perform our contract with
you or take steps at your request
before entering into a contract.
b. Necessary for our legitimate
interests (to recover debts due to
us)

Conducting checks to identify
you and verify your identity or
to help prevent and detect
fraud against you or us

To comply with our
legal and regulatory
obligations and; for our
legitimate interests.

To comply with our legal and
regulatory obligations and; for
our legitimate interests.

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 i.e., to
protect out
business,
interests and
rights.

Depending on the
circumstances:
- To comply with our legal
and regulatory
obligations
In other cases, for our legitimate
interests i.e., to protect our
business, interests and rights.

To manage our relationship
with you which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(b) Asking you to leave a
review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications

(a) Performance of a contract
with you
(b) Necessary to comply with a
legal obligation
(c) Necessary for our legitimate
interests (to keep our records
updated and to study how clients
use our services)

To enable you to partake in a
prize draw, competition or
complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications

(a) Performance of a contract
with you
(b) Necessary for our legitimate
interests (to study how clients
use our services, to develop
them and grow our business)

To administer and protect our
business and this website
(including troubleshooting,
data analysis, testing, system
maintenance, support,
reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

Necessary for our legitimate
interests (to study how clients
use our services, to develop
them, to grow our business and
to inform our marketing strategy)

To use data analytics to
improve our website, services,
marketing, client relationships
and experiences

(a) Technical
(b) Usage

Necessary for our legitimate
interests (to define types of
clients for our services, to keep
our website updated and
relevant, to develop our business
and to inform our marketing
strategy)

To make suggestions and
recommendations to you
about services that may be of
interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Necessary for our legitimate
interests (to develop our services
and grow our business)

Please see the Glossary to find out more about the types of lawful basis that we will rely on to
process your personal data.
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about
the specific legal ground we are relying on to process your personal data where more than one
ground has been set out in the table below.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with

the original purpose. If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
5. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. We will use your personal data in the following circumstances:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we decide which
services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us
or purchased services from us or if you provided us with your details when you entered a
competition or registered for a promotion and, in each case, you have not opted out of receiving
that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any external
companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following
the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of purchasing a service, service experience or other transactions.
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 sell or share it with
other organisations outside IOL’s group for marketing purposes.
6. 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,
warehouses and delivery companies
- other third parties we use to help us run our business, eg marketing agencies or website
hosts and website analytics providers
We only allow those organisations to handle your personal data if we are satisfied they take
appropriate measures to protect your personal data. We also impose contractual obligations on
them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:

- our external auditors, eg in relation to the audit of our accounts, in which case the recipient
of the information will be bound by confidentiality obligations
- our 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.
7. Transferring your personal data out of the UK (international transfers)
The data that we collect from you is stored in the UK however it is also transferred and processed
outside of the European Economic Area ("EEA").
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection
is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the
Privacy Shield which requires them to provide similar protection to personal data shared between
the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
8. Cookies
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other
electronic device) when you use our website. We use cookies on our website. These help us
recognise you and your device and store some information about your preferences or past
actions.
You can set your browser to refuse all or some browser cookies, or to alert you when websites
set or access cookies. If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly. For more information about the
cookies we use, please see our Cookie Policy.
9. Your rights
You generally have the following rights, which you can usually exercise free of charge.
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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

personal data

Correction (also known as 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 use The right to require us to restrict use 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 to use The right to object:

—at any time to your personal data being used
for direct marketing (including profiling)
—in certain other situations to our continued
use of your personal data, eg where we use
your personal data for 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 decisions without
human involvement

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
We do not make any such decisions based on
data collected by our website.

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
You may withdraw consents by [insert details
as relevant depending on consents]
Withdrawing a consent will not affect the
lawfulness of our use of your personal data in
reliance on that consent before it was
withdrawn

What we may need from you
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is a

security measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to your request
to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.
10. 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. They
may be contacted using may be contacted using the details at https://ico.org.uk/make-a-
complaint or by telephone: 0303 123 1113.
11. Data security
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we
limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally required to do so.
12. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.
To determine the appropriate retention period for personal data, we consider the amount,
nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable legal
requirements.
Details of retention periods for different aspects of your personal data are set out below.
- Clients: Data for clients is generally retained for 15 years after the purchase of each
service to comply with legal and industrial regulatory requirements.
- Enquiries: Data for potential clients who have enquired about our services is generally
retained for up to 2 years after each enquiry.
- Recruitment Records: Information relating to unsuccessful applicants will be kept for up
to 1 year from the date which it was decided not to proceed with the latest application. This

data will be used to assist the recruitment process to keep a record of the names of
applicants who have been shortlisted or interviewed.
- Disposal of Records: all Personal Data will be disposed of in a way that protects the
rights and privacy of Data Subjects.
By law we have to keep basic information about our clients (including Contact, Identity,
Financial and Transaction Data) for 7 years after they cease being clients for tax purposes
however due to industrial regulatory purposes we shall retain this for 15 years.
In some circumstances you can ask us to delete your data: see “Request erasure” below
for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this
information indefinitely without further notice to you.

13. Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we
will take steps to inform you, for example by including a prominent link to a description of
those changes on our website for a reasonable period or by other means, such as email.
14. How to contact us
You can contact us by post, 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 can be found on our About Us page.
Glossary
Lawful Basis Legitimate Interest means the interest of our business
in conducting and managing our business to enable us
to give you the best service and the best and most
secure experience. We make sure we consider and
balance any potential impact on you (both positive and
negative) and your rights before we process your
personal data for our legitimate interests. We do not
use your personal data for activities where our
interests are overridden by the impact on you (unless
we have your consent or are otherwise required or
permitted to by law). You can obtain further information
about how we assess our legitimate interests against
any potential impact on you in respect of specific
activities by contacting us.

Performance of Contract Performance of Contract means processing your data
where it is necessary for the performance of a contract
to which you are a party or to take steps at your
request before entering into such a contract.

Compy with a legal or regulatory obligation

Comply with a legal or regulatory obligation means
processing your personal data where it is necessary for

compliance with a legal or regulatory obligation that we
are subject to.
Third Parties External Third Parties

Service providers based in the UK who provide IT and
system administration services.
Professional advisers including surveyors, architects,
tradesmen, lawyers, bankers, auditors and insurers
based in the UK who provide construction,
consultancy, banking, legal, insurance and accounting
services.
HM Revenue & Customs, regulators and other
authorities based in the UK who require reporting of
processing activities in certain circumstances.
Sub-contractors, the Land Registry and the local
council departments if we need to pass on your details
for any reason in connection with an order or an
enquiry.