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Privacy Policy

Last updated: 19 September 2023

1.0 Introduction

This privacy policy (Policy) relates to your personal data in connection with your use of and access to the Sancrox website (www.sancrox.com) (the Sancrox Platform) and any services provided by Sancrox (the Sancrox Platform and services together forming the Sancrox Services).

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this Policy, or our practices with regards to your personal data, please contact us at contact@sancrox.com.

When you use the Sancrox Services, you trust us with your personal data. We take your privacy very seriously. We seek to explain to you in the clearest way possible what personal data we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the Sancrox Services.
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1.1 Changes to this policy or your personal data

We review this Policy regularly and it is your responsibility to check regularly and determine whether you still agree to comply with this Policy. If you do not agree to any change to this Policy, then you must immediately stop using the Sancrox Services. In the event we make any significant changes to this Policy we will use our reasonable endeavours to inform you or such changes in advance in writing.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes for example you change your email address.

2. About us

The Sancrox Services are owned and operated by Sancrox Political Advisory Limited (trading as Sancrox) a company registered in England and Wales with company number 15153623 and whose registered office is situated at the Mill Pury Hill Business Park, Alderton Road, Towcester, United Kingdom, NN12 7LS (Sancrox/we/us/our). Sancrox is the controller (also known as a data controller) and is responsible for your personal data. The term “you” refers to the user wishing to access and/or use the Sancrox Services.
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3. Personal data we may collect about you

3.1 Where and how we collect personal data
3.2 Personal data you disclose to us

(a) Where and how we collect personal data

We collect personal data that you voluntarily provide to us when registering to use and actually using the Sancrox Services, or otherwise contacting or interacting with Sancrox.

If you apply or are put forward for a role with us, we also collect your personal data, which may include your contact details, details of your education, qualifications and skills, your nationality, your job title and your CV.

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We use different methods to collect your personal data including through:

  • Direct interactions. You may give us your personal data by filling in forms, interacting with Sancrox at events, or by corresponding with us by post, phone, email or otherwise. This
    includes personal data you provide when you;
  • have contact with Sancrox through introductions or meeting a Sancrox representative or corresponding with Sancrox in relation to a transaction that Sancrox and/or the funds it manages or advises;
  • apply for and/or use the Sancrox Services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • subscribe to our service or publications;
  • Deal with payment for the Sancrox Services;
  • Resolve disputes or collect overdue payments;
  • give us feedback or contact us;
  • Automated technologies or interactions. As you interact with the Sancrox Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details;
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources - for example for anti-money laundering,background checks or similar purposes;
  • If we have a business relationship with the company that you represent, your colleagues or
    other business contacts, they may provide Sancrox with personal data such as your contact
    data or other relevant information; or
  • Personal Data may be collected from publicly available sources such as Companies House.

(b) The types of personal data we may collect

We collect personal data that you voluntarily provide to us when registering and using the Sancrox Services, or otherwise contacting us. The personal data that we collect depends on the context of your interactions, the choices you make and the products and features you use. When you use the Sancrox Services and/or when you otherwise deal with us, we may collect the following information about you (the Personal Data):

  • Identity Data which includes first name, last name, gender, video, photograph or audio recordings of you.
  • Contact Data which means the data we use to contact you including your address, email address and contact number.
  • Business Data, which includes job title, company, business affiliations and career highlights.
  • Transaction Data which means details about transactions you have made using the Sancrox Services including details of services you have purchased from us. Usage Data which includes information about how you use the Sancrox Services. This includes your browsing patterns and information such as how long you might spend on one of our webpages on the Sancrox Platform and what you look at and for, the page that referred you to the Sancrox Platform and the click stream during your visit to our website, page response times and page interaction information (clicks you make on a page).
  • Marketing and Communications Data which includes your preferences in receiving marketing from us and your communication preferences.
  • Other information relevant to the Sancrox Services.

All Personal Data that you provide to us must be true, complete and accurate, and you must notify us of any changes to your 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 the contract you have with us, but we will notify you if this is the case at the time.

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3.3 Personal Data from third parties

Occasionally we may receive Personal Data about you from other sources, which we will add to the Personal Data we already hold about you in order to help us provide, improve and personalise the Sancrox Services. If you apply for a job with us, we may also receive Personal Data from those who provide references relating to your prospective or actual engagement or employment.

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3.4 Personal Data automatically collected

We automatically collect certain Personal Data when you visit, use or navigate the Sancrox Platform. This Personal Data does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Sancrox Platform and other technical information. This information is primarily needed to maintain the security and operation of the Sancrox Platform, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy.

4. How do we use your personal data?

In Short: We process your Personal Data for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations,
and/or your consent.

We use your Personal Data collected via the Sancrox Services for a variety of business purposes described below. We process your Personal Data for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual Reasons), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below.

We may process your Personal Data for the following purposes:

  • To operate, manage, develop and promote Sancrox and the Sancrox Services and to identify you and verify your identity and/or eligibility in connection with any Sancrox Services you wish to use;
  • To take steps towards entering into a contract with you to provide the Sancrox Services
    and to claim any right to be paid under our terms (Contractual Reasons). This includes collecting and using your Personal Data to:
  • Prepare an agreement with you;
  • Manage any accounts you hold with us;
  • Contact you for reasons related to the Sancrox Services;
  • Enable us to follow up on enquiries made by you in relation to the Sancrox Services and/or to provide information you have requested;
  • Contact your referee(s) or to obtain a reference for a job that you are applying
    for; and
  • Notify you of any changes to the Sancrox Services that may affect you.
  • To invite you to presentations and events and organise meetings between you and Sancrox representatives and to contact you regarding enquiries you have made in relation to the Sancrox Services (Business Purposes).
  • To provide you with analysis of the markets which Sancrox operates in and assess any potential transactions and assess your suitability for involvement in a transaction, including verifying your identity and source of funds (Business Purposes).
  • To facilitate a recruitment process in which you are involved (Business Purposes).
  • To send administrative information to you for Business Purposes, Legal Reasons and/or possibly Contractual Reasons. We may use your Personal Data to send you service and new feature information and/or information about changes to our terms and policies, as may be in place from time to time.
  • To send you marketing and promotional communications for Business Purposes and/or with your Consent. We may use your Personal Data for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails (see below for further details).
  • To request feedback for our Business Purposes and/or with your Consent. For example, we may use your Personal Data to request feedback and to contact you about your use of
    the Sancrox Platform.
  • To protect the Sancrox Services for Business Purposes and/or Legal Reasons. We may use your Personal Data as part of our efforts to keep the Sancrox Services safe and secure (for example, for the purposes of monitoring and/or preventing fraud).
  • To enforce our terms and policies for Business Purposes, Legal Reasons and/or possibly Contractual Reasons.
  • To respond to legal requests and prevent harm for Legal Reasons. For example, if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • We may use your Personal Data for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Sancrox Services, our services, our marketing and your experience.

5. Will your personal data be shared with anyone?

In Short: We only share information to comply with Contractual obligations, fulfil our Business Purposes, or with your Consent.

We only share and disclose your Personal Data in the following situations:

Contractual: to share information with providers to enable any Sancrox Services to be fulfilled.

Compliance with Legal Obligations. We may disclose your Personal Data where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests. We may disclose your Personal Data where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. Third-Party Service Providers. We may share your Personal Data with third-party
vendors, service providers, contractors or agents who perform services and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts. They will only have access to your Personal Data to the extent that they need to perform those services. They are required to keep your Personal Data confidential and may not use it other than as we ask them to and always in accordance with this Policy. Business Transfers. We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sancrox Platform. These companies may use information about your visits to the Sancrox Platform and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookies Policy for further information on cookies.‍

‍Business Partners. Provided you have given us Consent to do so we may share your Personal Data with our business partners to offer you certain products, services or promotions.

With your Consent. We may disclose your Personal Data for any other purpose with your Consent.

We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Sancrox Services. In such circumstances we do not disclose any information which can identify you personally.

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6. Is your personal data transferred internationally?

In Short: We may transfer, store, and process your Personal Data in countries other than
your own but will take all reasonable steps to ensure it is protected.

Whenever we transfer your Personal Data outside of the UK, we will take all reasonable measures that we can to protect your Personal Data in accordance with this Policy and applicable law. To the extent that any transfer requires approved safeguards are in place (for example if transferring outside of the European Economic Area that the EU model contract clauses or if to the USA that the entity it is transferred to is EU/US Privacy Shield registered) we will ensure these measures are in place

7. Third-party websites

In Short: We are not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the Sancrox Services.

The Sancrox Platform may feature links to third-party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any
third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sancrox Platform. You should review the policies of such third parties and contact them directly to respond to your questions.
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8. How long do we keep your personal data?

In Short: We keep your Personal Data for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.

We will only keep your Personal Data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing Business Purpose to process your Personal Data, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
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9. How do we keep your personal data safe?

In Short: We aim to protect your Personal Data through a system of organisational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Data we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Personal Data, transmission of Personal Data to and from the Sancrox Platform is at your own risk. You should only access our services within a secure environment.
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10. Do we collect personal data from minors?

In Short: We take steps to ensure that the Sancrox Services are only used by those over 16 years of age and we do not knowingly collect data from or market to children under 16
years of age.

‍We do not knowingly solicit data from or market to children under 16 years of age. By using the Sancrox Services, you represent that you are at least 16 years of age. If we learn that Personal Data from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 16, please contact us at contact@sancrox.com.
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11. Your content to processing

You will be required to give Consent to certain processing activities before we can process your Personal Data. Where applicable, we will seek Consent from you when you first submit Personal Data to or through the Sancrox Services.

If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing contact@sancrox.com.

If you withdraw your Consent, and if we do not have another legal basis for processing your Personal Data, then we will stop processing your Personal Data. If we do have another legal basis for processing your Personal Data, then we may continue to do so subject to your legal rights.

Please note that if we need to process your Personal Data in order for you to use the Sancrox Services and you object or do not provide Consent to us processing your Personal Data, the Sancrox Services will not be available to you.
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12. Marketing and opting out

If you have given Consent to marketing we may contact you about our services. If you no longer wish to receive such information you can withdraw your Consent at any time by sending an email to contact@sancrox.com or unsubscribe from the communications.

If you have given Consent, we may share your Personal Data with carefully selected third-party organisations and business partners and they may contact you directly. If you prefer not to receive direct marketing communications from the third-party please contact them directly to withdraw the Consent.

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13. What are your privacy rights?

In Short: You have certain rights in respect of your Personal Data.‍

You have certain rights in relation to the Personal Data that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request. This is a security measure to ensure that your Personal Data is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response. To exercise or discuss any of your rights please contact us at contact@sancrox.com.

Right of Access. You have the right at any time to ask us for a copy of the Personal Data that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your Personal Data, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

Right of Correction or Completion. If Personal Data we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.

Right of Erasure. In certain circumstances, you have the right to request that the Personal Data we hold about you is erased e.g. if the Personal Data is no longer necessary for the purposes for which it was collected or processed or our processing of the Personal Data is based on your consent and there are no other legal grounds on which we may process the Personal Data.

Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your Personal Data. For example, if we are processing your Personal Data on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests.

You may also have the right to restrict our use of your Personal Data, such as in circumstances where you have challenged the accuracy of the Personal Data and during the period where we are verifying its accuracy.
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Right of Data Portability. In certain instances, you have a right to receive your Personal Data that we hold about you in a structured, commonly used and machine-readable format.

In such circumstances, you can ask us to transmit your Personal Data to you or directly to a third party organisation.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal data of others without their consent.

If we are relying on Consent to process your Personal Data, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

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14. Contact us

We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy or have any questions regarding your Personal Data in connection with Sancrox or any other questions, please email us at contact@sancrox.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.