Privacy Policy

CIRCULARCONNEX INDUSTRIAL SUPPLY CHAIN INTELLIGENCE

Privacy Policy

For the CircularConnex website, diagnostic enquiries and business client services

1. Who we are

CircularConnex Industrial Supply Chain Intelligence is a trading name of Circularconnex Sourcing Consultancy Ltd, a company registered in England and Wales with company number 16789564.

Registered office: Eleven Brindley Place, 2 Brunswick St, Birmingham B1 2L.

Privacy contact: info@circularconnex.co.uk.

For the purposes of this Privacy Policy, “we”, “us” and “our” refer to the legal entity stated above.

2. Scope of this policy

This policy explains how we collect and use personal data when you visit our website, contact us, request a diagnostic, become a client, or otherwise communicate with us in connection with our services.

Our services are intended for business customers. Tender packs and business documents can contain personal data, including contact details and names of individuals involved in a project. We ask clients not to provide personal data that is unnecessary for the requested service.

3. Personal data we collect

• Identity and contact data, including names, job titles, company name, business email address, telephone number and correspondence details.

• Enquiry and service data, including sector, tender value range, submission deadline, requested service type and information included in messages or tender materials.

• Tender and diagnostic data, including tender packs, scope information, supplier or component references, programme information, risk assumptions and documents supplied for a diagnostic.

• Transaction and administration data, including quotations, invoices, payment status, engagement records, delivery records and audit metadata.

• Technical data generated by normal website use, such as information supplied through website forms and basic security or server logs where applicable.

4. How and why we use personal data

We process personal data only where we have a lawful basis to do so. Depending on the circumstances, this will normally be because it is necessary to take steps at your request before entering into a contract, to perform a contract with you, to comply with a legal obligation, or for our legitimate interests in running and protecting our business.

• Responding to enquiries, confirming service fit, preparing quotations and arranging an engagement.

• Producing, quality checking and delivering diagnostics and Monthly Monitor outputs.

• Managing client relationships, service records, invoices, payment administration and support.

• Protecting our systems, preventing misuse and maintaining internal audit trails.

• Improving our services using aggregated or anonymised operational information where appropriate.

5. Software, analytical tools and automated systems

We may use software, analytical tools and automated systems to support the production, quality control and administration of our services. These tools may assist with analytical processing and preparation of client outputs. CircularConnex remains responsible for the review and delivery of all client outputs. Where an external service provider processes personal data on our behalf, we handle that processing in accordance with our data-protection obligations and the safeguards described in this policy. We review material changes to our processing arrangements and update this policy where required.

6. Who we share personal data with

We do not sell personal data. We share personal data only where necessary for the purposes set out in this policy.

• Email and communication providers used to communicate with you and deliver final reports manually by email.

• Access controlled business storage and administration systems used to hold tender materials, final reports, engagement records and audit information.

• Google Sheets may be used for approval status and audit metadata only. Raw tender packs are not stored in those approval records.

• Professional advisers, insurers, regulators, law enforcement bodies or courts where disclosure is required or reasonably necessary.

• Service providers acting on our instructions and subject to appropriate confidentiality and data protection obligations.

7. International transfers

Some service providers may process personal data outside the United Kingdom. Where this occurs, we will use appropriate safeguards required by applicable data protection law before transferring personal data internationally.

8. Service delivery and review

Diagnostic reports and Monthly Monitor outputs are manually reviewed and normally delivered by email in PDF format. We do not currently operate automated Monthly Monitor emails. Software and automated systems may support internal analysis, quality control and report preparation, but CircularConnex remains responsible for final review and delivery.

9. Retention

We retain personal data only for as long as necessary for the purpose for which it was collected, subject to legal, accounting and claims handling requirements. Our standard retention periods are:

• Unconverted enquiries and contact form submissions: 12 months after the last meaningful contact.

• Tender materials for declined or expired opportunities: 90 days after decline or expiry.

• Raw tender materials supplied for a completed diagnostic: 90 days after delivery, unless a longer period is agreed in writing or needed for a dispute or legal obligation.

• Final diagnostic reports, scope records and delivery records: 24 months after delivery.

• Monthly Monitor delivery and service records: 24 months after the end of the relevant service period.

• Invoices, payment records and accounting records: 6 years after the relevant financial year, or longer where required by law.

10. Security

We use reasonable organisational and technical measures designed to protect personal data against unauthorised access, loss, misuse or disclosure. No transmission or storage method can be guaranteed to be completely secure; we will respond to incidents in accordance with applicable law and our internal procedures.

11. Your rights

Subject to applicable law, you may have rights to request access to your personal data, correction of inaccurate data, deletion in certain circumstances, restriction of processing, objection to processing, and data portability. You may also complain to the Information Commissioner’s Office if you are unhappy with how we handle your personal data.

12. How to contact us

To exercise your rights or ask a question about this policy, contact info@circularconnex.co.uk.

We may need to verify your identity before responding to a request.

13. Changes to this policy

We may update this policy from time to time. The current version will be available on our website and will state its effective date.