• 1. Introduction

• 1.1 We are committed to safeguarding the privacy of our prospective and actual Clients, Partners, Providers and Associates, our website visitors and service users.
• 1.2 This policy applies where we are acting as a data controller with respect to the personal data of our prospective and actual Clients, Partners, Providers and Associates, our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
• 1.3 Our Cookies Policy is an integral part of this policy, and can be found at: https://www.eggcelerate.com/cookies-policy/ We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
• 1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive any communications and/or of what type. You can access the privacy controls via https://www.eggcelerate.com/signup/
• 1.5 In this policy, “we”, “us” and “our” refer to SteM Advisory Ltd. For more information about us, see Section 13.

• 2. Credit

• 2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).

• 3. How we use your personal data

• 3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
• 3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system (e.g., Google Analytics).
• 3.3 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name, business telephone and email address, company, company details (e.g. address, registration number, VAT number). The source of the service data is you or your employer.
• 3.4 We may process information that you post for publication on our website or through our services (“publication data“).
• 3.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“).
• 3.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your company’s bank account details and the transaction details.
• 3.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“).
• 3.8 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication.
• 3.9 We may process information relating to your business contact details (“professional data”). This data may include your name, business telephone and email address, role, company, company’s details (e.g. type of business, location, size). The source of this data is the public, where such data is publicly available, or business networks or databases that provide such data in compliance with current laws and regulations.
• 3.10 We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
• 3.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

• 4. Purposes of processing and legal bases

• 4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
• 4.2 Operations – We may process your data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
• 4.3 Publications – We may process your data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent.
• 4.4 Relationships and communications – We may process your data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
• 4.5 Direct marketing – We may process your data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
• 4.6 Research and analysis – We may process your data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
• 4.7 Record keeping – We may process your data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
• 4.8 Security – We may process your data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
• 4.9 Insurance and risk management – We may process your data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
• 4.10 Legal claims – We may process your data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
• 4.11 Legal compliance and vital interests – We may also process your data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

• 5. Providing your personal data to others

• 5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
• 5.2 We may disclose some personal data category to our suppliers or subcontractors insofar as reasonably necessary for specific purposes, as summarized in Table 1.

Financial transactions relating to our website and services are handled by our payment services providers, Barclays Bank UK PLC. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider's privacy policies and practices at:

https://www.barclays.co.uk/important-information/privacy-policy/

Table 1: List of suppliers or subcontractors with whom we may disclose some personal data categories as reasonably necessary for specific purposes.

Category	Supplier or Subcontractor	URL	Purpose	Location
Usage Data Notification Data Professional Data	SendinBlue SAS	https://www.brevo.com/legal/privacypolicy/	Managing contacts and sending messages	EU
Professional Data	Nett Sales, LLP	https://www.nett-sales.com	Managing contacts and sending messages	UK
All	Google, LLC	https://policies.google.com/privacy	Backup saving and management Managing contacts and sending messages Displaying content from external platforms	USA
All	Dropbox, Inc.	https://www.dropbox.com/en_GB/privacy	Backup saving and management	USA
Enquiry Data Notification Data Professional Data	Nimble, Inc.	https://www.nimble.com/company/privacy/	Managing contacts and sending messages	USA
Enquiry Data Notification Data Professional Data	Covve Visual Network Ltd.	https://covve.com/privacy-policy	Managing contacts and sending messages	EU
All	Microsoft Corporation	https://privacy.microsoft.com/en-gb/privacystatement	Managing contacts and sending messages Backup saving and management	USA
Usage Data	Twitter, Inc	https://twitter.com/en/privacy	Interaction with external social networks and platforms	USA

• 5.3 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
• 5.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

• 6. International transfers of your personal data

• 6.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred from/to a third country under the UK and/or EU data protection law.
• 6.2 We may transfer from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
• 6.3 The hosting facilities for our website are situated in the EU (Italy) and the UK. The competent data protection authorities have made an adequacy determination with respect to data protection laws of the UK/EU. Transfers to each of these countries will be protected by appropriate safeguards, namely:

  the UK GDPR (https://www.legislation.gov.uk/eur/2016/679/contents); and

  the EU GDPR (https://gdpr-info.eu)

• 6.4 Some of our suppliers or subcontractors (ref. Table 1) are situated in the USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to the USA will be protected by appropriate safeguards, namely the obligations and standards of the EU-US and Swiss-US Privacy Shields (Privacy Shield, 2021 EU Standard Contractual Clauses, European Data Protection Board Recommendations, EU Essential Guarantees, Privacy Shield 2.0). This means that our suppliers or subcontractors lawfully transfer and protect the personal data of EU/EEA residents to the USA pursuant to the rules of the Federal Trade Commission and the EU.
• 6.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

• 7. Retaining and deleting personal data

• 7.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
• 7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
• 7.3 We will retain your personal data as follows:
• (a) the minimum and maximum period usage data will be retained is set by the expiration of our Cookies, starting from the beginning of the first user session on our website.
• (b) service data will be retained for a minimum period of 7 years following the end of the contract and provision of the service.
• (c) enquiry data will be retained for a maximum period of 5 years following the latest interaction.
• (d) transaction data will be retained for a minimum period of 7 years following the transaction date.
• (e) notification data will be retained for a maximum period of 5 years following the latest interaction.
• (f) notification data will be retained for a maximum period of 5 years following the latest interaction.
• (g) professional data will be retained for a maximum period of 5 years following the acquisition of the data.
• 7.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
• (a) the period of retention of usage data (e.g., gathered while interacting with us through our marketing automation platform) will be determined based on when a request to unsubscribe is executed.
• (b) the period of retention of service data will be determined based on when our company ceases to be a going concern.
• (c) the period of retention of publication data will be determined based on the specific agreement concerning a specific publication of data.
• (d) the period of retention of transaction data will be determined based on when our company ceases to be a going concern.
• (e) the period of retention of notification data will be determined based on when a request to unsubscribe is executed.
• (f) the period of retention of any personal data will be determined based on when the data subject withdraws consent to processing or the data is no longer up to date.
• 7.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

• 8. Amendments

• 8.1 We may update this policy from time to time by publishing a new version on our website.
• 8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
• 8.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

• 9. Your rights

• 9.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
• 9.2 Your principal rights under data protection law are:
• (a) the right to access;
• (b) the right to rectification;
• (c) the right to erasure;
• (d) the right to restrict processing;
• (e) the right to object to processing;
• (f) the right to data portability;
• (g) the right to complain to a supervisory authority; and
• (h) the right to withdraw consent.
• 9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
• 9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
• 9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
• 9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
• 9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
• 9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
• 9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• 9.10 To the extent that the legal basis for our processing of your personal data is:
• (a) consent; or
• (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
• and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
• 9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
• 9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
• 9.13 You may exercise any of your rights in relation to your personal data by written notice to us.

• 10. Our details

• 10.1 This website is owned and operated by SteM Advisory Ltd.
• 10.2 We are registered in England and Wales under registration number 9198779, and our registered office is at 4th Floor H&B, 43 Berkeley Square, London W1J 5FJ.
• 10.3 You can contact us: by post, using the postal address given above; using our website contact form; by telephone, on +44(0)2032391653; or by email, using privacy@eggcelerate.com