Summary

We take our obligations with respect to data processing and protection very seriously and it is important to us that you understand how we use your personal data.

In this policy you will find:

• The purposes for which we process your personal data
• The types of personal data we collect and where we collect it from
• Who we share data with and why we do so
• Where we store data
• Any rights you have in relation to the data and how to act upon them
• How to contact us about your data

The main purposes for which we process your personal data are to provide you with services that you request from us, either through onmode.ai or through other sites that are powered by the Onmode technology, collectively (the “Platform”) as well as to optimise those services.

The Onmode Platform enables you to access, create and maintain portfolios of entities and data and information about them. The data available in the Platform may be provided by you or by third parties, which in some cases may be accessed using your credentials through your relationship with the third party and in other cases using Onmode’s relationship with the third party.

By updating your information using the Onmode Platform and providing your access credentials you are providing your consent that we may use your credentials to access data available to you via third parties that you have relationships with. You may withdraw this consent at any time by contacting us via the methods described below.

We will also process your data for other purposes such as marketing (where you have provided your consent), keeping you informed about our service, market research, fraud prevention, to develop the service and statistical analysis.

We will only keep your personal data for as long as is required.

We will need to share your data with third-parties, such as our partners and suppliers that support the Platform. The list of third-parties can be found in this policy.

You may contact us to exercise your rights in relation to this Privacy Policy using the information provided below.

Purposes for processing your personal data

The main purposes for which we process your personal data are to provide you with the services that you request from us and to administer your account. The services may be provided either through onmode.ai or through other sites that are powered by the Onmode technology.

These services include, but are not limited to:

• Creating an account for you on the Platform
• Granting you access to your account on the Platform
• Enabling you to see and update your details about you, your business, your portfolios and your Onmode profile
• Sending you any updates or reminders about your account
• Sending you relevant information that can help you to update and enhance your Onmode profile
• Sharing of your details with third party organisations that you have relationships with to access their information on your behalf

Such third party organisations will be data controllers in relation to the use of the data for these purposes and we recommend that you visit their websites to read their privacy policies.

Data protection laws require us to tell you the legal basis on which we are processing your personal data. The main bases we rely on to process your personal data are:

To establish and perform our contract with you in order to provide you with the service

To comply with a legal obligation, where we are subject to legal requirements or where we may be obliged by law to disclose your information such as to a regulatory body or a law enforcement agency

Where it is in our, your or a third-party’s legitimate interest to process the data, such as to share information with our customers and to promote and improve our business

Where you have provided consent for us to do so. You have the right to withdraw your consent at any time using the contact details provided below.

The types of personal data we collect and where we collect it from

We collect data relating to you and your business in order to provide you with the service. Where your business is a sole trader or non-registered partnership, this information is considered as personal data. Such personal data is provided either directly by your or by other people or companies that you have authorised to act for you. The information may include:

• Your contact details, including your name, email address, telephone number and date of birth
• Details relating to your business, including directors, business owners and shareholders details, which may be provided directly by you or collected from other parties such as Companies House (see table of data sources below). Where you give us data about someone else, you must ensure that this person is aware of this Privacy Policy and that they are happy to provide us with their data
• Copies of identification documents, such as passports which may be used to verify who you are
• Records of communication between us including via telephone, webchat, email and other correspondence
• Details of your use of our service including how and when the service was accessed, including the IP address used. We collect some of this data using cookies, which are commonly used on the internet and do not harm your computer system. You can read our cookie policy here for more information.

The data sources we use include:

Source	Data Description
Third Party Databases	Business information including business names, names of individuals associated with the business, company ownership details and other business details (e.g. industry sector and number of employees)
Businesses’ publicly available Websites	Subject to the allowed purposes defined in websites’ robots policies, we gather information relating to the nature of businesses, policies, filings and registrations as available to the public
Companies House	Publicly available information about the nature of businesses, directors, and its filings
Public Sector data assets	A wide range of publicly available filings, reports, market summaries etc, such as carbon emissions data and supply chain metrics.

Who we share data with and why we do so

In order to operate the Platform and to provide you with the service we work with a number of third-parties and are required to share data with them for the following reasons:

• To our agents and sub-contractors for operating the service, which may include Customer Support services, IT support services (including Data Warehousing), Data Access providers (such as providers of Open Banking services) and Payment processing companies
• If you request us to do so
• If we are required to do so to comply with any legal obligation
• If we are required to do so for audit purposes
• If we sell or buy any business or assets, whereby the personal data is required to be shared with the potential buyer or seller
• If our business assets are acquired by a third-party and the personal data is transferred as one of the business assets

We use third-parties to support us in providing you with the service, and these third-parties act as data processors on our behalf. How they use your information is controlled by us and we remain responsible for the processing of your data by these organisations, including:

• Google Analytics – which allows us to monitor how users use the service
• Google – providing us with cloud based hosting service for our databases
• Marketing companies – supporting us in communicating to our customers
• Analytics companies – supporting us in making improvements to the service

Where we store data

We currently store personal data in the UK, however we reserve the right, to relocate the personal data to other locations within the European Economic Area (EEA), if we choose to do so in the future. We will take all reasonable steps required to ensure your data is handled securely and in line with this Privacy Policy.

Where we use third-party supplies to process your personal data, some of these suppliers may store data outside of the UK or EEA, which may not have equivalent laws in place to protect your personal data. Wherever we do this we will ensure that your personal data is kept securely and given the equivalent protection as if it were processed in the UK.

Your rights

Under data protection law you have the following rights in relation to your personal data. You can exercise these rights by contacting us using the information provided below. We can only support these rights for you where we are the data controller of your personal data. If you make a request to us where one of our partners is the data controller, we will direct you to that partner as appropriate.

Contacting us

If you wish to contact us about one of your data rights, please:

Email to support@onmode.ai

or

Write to Data Requests, Onmode Ltd, 22 Howards Thicket, Gerrards Cross, SL9 7NX

In either case please provide the information you require and include your email address(es) as this allows us to identify you and all relevant information.

If you wish to make a complaint about how we have handled your personal data you can contact us using the following:

Email to info@onmode.ai

or

Write to Complaints, Onmode Ltd, 22 Howards Thicket, Gerrards Cross, SL9 7NX

You also have the right to complain to the Information Commissioner’s Office, which regulates compliance to data protection legislation. You can do this by visiting their website https://ico.org.uk.

Our rights

We reserve the right to change this Privacy Policy at any time and will publish any changes on the Platform and our website. The published policy will include the date of the most recent version.