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Customer Privacy Notice

Last updated: 8 September 2025

Registered name: Wrenham Ltd

We are the controller of your personal data. This privacy notice tells you what to expect us to do with your personal information.

Contact Details

What Information We Collect, Use, and Why

To provide and improve products and services for clients:

  • • Names and contact details
  • • Addresses
  • • Gender
  • • Occupation
  • • Payment details (including card or bank information for transfers and direct debits)
  • • Transaction data (including details about payments to and from you and details of products and services you have purchased)
  • • Usage data (including information about how you interact with and use our website, products and services)
  • • Video recordings
  • • Audio recordings (eg calls)
  • • Records of meetings and decisions
  • • Account access information
  • • Website user information

For the operation of client or customer accounts:

  • • Names and contact details
  • • Addresses
  • • Purchase or service history
  • • Account information, including registration details
  • • Information used for security purposes
  • • Marketing preferences
  • • Technical data, including information about browser and operating systems

For information updates or marketing purposes:

  • • Names and contact details
  • • Addresses
  • • Profile information
  • • Marketing preferences
  • • Purchase or account history
  • • Website and app user journey information
  • • IP addresses

For research or archiving purposes:

  • • Names and contact details
  • • Addresses
  • • Purchase or client account history
  • • Website and app user journey information
  • • IP addresses

To comply with legal requirements:

  • • Name
  • • Contact information
  • • Identification documents
  • • Client account information
  • • Health and safety information
  • • Any other personal information required to comply with legal obligations

For recruitment purposes:

  • • Contact details (eg name, address, telephone number or personal email address)
  • • Date of birth
  • • National Insurance number
  • • Copies of passports or other photo ID
  • • Employment history (eg job application, employment references or secondary employment)
  • • Education history (eg qualifications)
  • • Right to work information
  • • Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
  • • Security clearance details (eg basic checks and higher security clearance)

For dealing with queries, complaints or claims:

  • • Names and contact details
  • • Addresses
  • • Call recordings

Lawful Bases and Data Protection Rights

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. Which lawful basis we rely on may affect your data protection rights which are set out below:

Your right of access

You have the right to ask us for copies of your personal information and request other information such as details about where we get personal information from and who we share personal information with.

Your right to rectification

You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.

Your right to erasure

You have the right to ask us to delete your personal information.

Your right to restriction of processing

You have the right to ask us to limit how we can use your personal information.

Your right to object to processing

You have the right to object to the processing of your personal data.

Your right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.

Your right to withdraw consent

When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our Lawful Bases for Collection and Use of Your Data

Consent

We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You do have the right to withdraw your consent at any time.

Contract

We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legal obligation

We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Where We Get Personal Information From

  • • Directly from you
  • • CCTV footage or other recordings
  • • Previous employment
  • • Providers of marketing lists and other personal information
  • • Suppliers and service providers

How Long We Keep Information

We store any data related to financial or contracts for seven years to be able to facilitate audits with HMRC. We will hold any candidate data for as long as the candidate is being considered.

Who We Share Information With

Data Processors

Claris

This data processor does the following activities for us: Host cloud software solutions.

Contabo

This data processor does the following activities for us: Host cloud software solutions.

OutSystems

This data processor does the following activities for us: Host cloud software solutions.

Others We Share Personal Information With

  • • Regulatory authorities
  • • Organisations we're legally obliged to share personal information with

How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO.

Information Commissioner's Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint