Privacy Policy

1. Purpose and scope

This Privacy Policy explains how Actera collects and uses personal data in connection with the Actera website, access requests, business enquiries and related business communications.

It applies to visitors, customers, prospective customers, investors, suppliers and other professional contacts. It does not govern personal data processed through the Actera product on behalf of a customer. That processing is governed by the relevant customer agreement, data-processing terms and product documentation.

This Policy describes Actera’s current practices and may be updated as our organisation, Site, service providers or processing activities change. We will publish the current version on this page and update the date above. Where a change materially affects how we use personal data, we will take additional steps to notify affected people where required by law.

2. Who is responsible for your data

Actera is the controller of personal data described in this Policy. This means Actera decides why and how that data is used. Privacy questions and requests may be submitted through the contact or request-access form on the Site.

3. Personal data we collect

Depending on how you interact with us, we may collect:

Information you provide

• Identity and professional details: name, work email address, employer, job title, department and professional profile information.

• Enquiry and access-request details: the content of your message, areas of interest, proposed workflows, agent use cases, control requirements and preferred next steps.

• Communications: messages, meeting details, notes and records of correspondence with Actera.

• Feedback: views about the Site, Actera service, product experience or market needs.

Information collected through the Site

• Technical data: IP address, browser and device type, operating system, referring page, approximate location derived from IP, request timestamps and security or error logs.

• Usage data: pages viewed, navigation events and aggregate performance information, where collected by our hosting or analytics configuration.

• Cookie and preference data: information stored or accessed through cookies, local storage or similar technologies, as described in the Cookie Policy.

Information received from other sources

We may receive professional contact details from a colleague or mutual contact, from your organisation, or from public professional sources such as a company website or professional-networking profile. We use such information only where relevant to legitimate business-to-business communication and subject to applicable direct-marketing rules.

4. Please do not submit sensitive information

The Site is not designed to collect special-category personal data, criminal-offence data, government identifiers, payment-card details, credentials, production data or confidential information about third parties. Please do not include these in a general enquiry or access-request form.

If a discussion later requires sensitive or regulated information, Actera will first agree an appropriate purpose, channel and set of safeguards.

5. How and why we use personal data

We use personal data only where we have a lawful basis. The main purposes and lawful bases are:

Where we rely on legitimate interests, we consider whether the use is necessary and proportionate and whether your rights override those interests. You may object to processing based on legitimate interests as described below.

If we ask for consent, you may withdraw it at any time. Withdrawal does not affect processing already carried out lawfully before withdrawal.

6. Business communications and marketing

We may contact you about an enquiry, meeting, requested access or an existing business discussion. We may also send limited, relevant business-to-business communications where permitted by law and where we reasonably believe the subject is relevant to your professional role.

We will not sell your details to third parties for marketing. You can ask us to stop marketing communications at any time by using the unsubscribe method provided or contacting us through the Site. We may keep a minimal suppression record so that we can respect that request.

7. When we share personal data

We may share personal data only as reasonably necessary with:

• website hosting, infrastructure, form-delivery, email, communications, scheduling and analytics providers;

• professional advisers such as lawyers, accountants, auditors and insurers;

• contractors or consultants supporting Actera, subject to appropriate confidentiality and data-protection obligations;

• a prospective buyer, investor, lender or adviser in connection with financing, reorganisation, acquisition or sale, subject to appropriate safeguards; and

• regulators, courts, law-enforcement bodies or other parties where required by law or reasonably necessary to protect rights, safety and security.

Service providers may process data only for agreed purposes and under appropriate contractual restrictions. We do not sell personal data.

8. International transfers

Some service providers may process personal data outside the United Kingdom. Where UK data-protection law requires safeguards for an international transfer, we will use an approved mechanism, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful safeguard. Where relevant, we will also assess whether additional protections are required.

You may contact us to request more information about safeguards used for a relevant transfer.

9. Retention

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, including legal, security, accounting and dispute-management requirements.

Our retention approach is:

• enquiries, access requests and ordinary business correspondence: normally up to 24 months after the last meaningful interaction, unless a longer period is justified by an active relationship or legal requirement;

• records relating to an agreement, legal obligation or dispute: for the term of the relationship and the applicable limitation or statutory record-keeping period;

• security and technical logs: for the shortest period reasonably necessary for security and troubleshooting, ordinarily no longer than 12 months unless an incident requires longer retention;

• marketing preferences and suppression records: for as long as needed to demonstrate and respect your choice; and

• cookie or consent records: for the duration described in the Cookie Policy or relevant preference interface.

We may anonymise information so that it no longer identifies an individual and use the anonymised information for product, research or statistical purposes.

10. Security

We use technical and organisational measures intended to protect personal data against unauthorised access, alteration, disclosure, loss and destruction. These may include access controls, encryption in transit, provider due diligence, least-privilege access, logging and secure development practices appropriate to the nature of the Site and data.

No internet service is completely secure. You should not send credentials, production data or highly sensitive information through an ordinary website form.

11. Your rights

Depending on your location and the circumstances, you may have the right to:

• request access to your personal data and information about its use;

• ask us to correct inaccurate or incomplete data;

• ask us to erase data;

• ask us to restrict processing;

• object to processing based on legitimate interests or to direct marketing;

• receive certain data in a portable format;

• withdraw consent where processing relies on consent; and

• complain to a data-protection authority.

These rights are not absolute and may be subject to legal conditions or exemptions. We may need to verify your identity before acting on a request. We will not charge a fee unless a request is manifestly unfounded or excessive, where the law permits a reasonable fee.

To exercise a right, submit a request through the contact form on the Site and state that it is a privacy request.

If you are in the United Kingdom, you may complain to the Information Commissioner’s Office at ico.org.uk. We would appreciate the opportunity to address your concern first, but you are not required to contact us before approaching the ICO.

12. Automated decision-making

Actera does not currently use personal data collected through the Site to make solely automated decisions that produce legal or similarly significant effects about individuals.

13. Children’s data

The Site is intended for adult business users and is not directed at children. We do not knowingly collect personal data from anyone under 18 through the Site. If you believe a child has provided data, please contact us so that we can review and delete it where appropriate.

14. Third-party websites

The Site may contain links to third-party websites. Their handling of personal data is governed by their own privacy policies, not this Policy. We encourage you to review those policies before providing information.

15. Contact

Questions, complaints and requests concerning this Privacy Policy may be submitted through the contact or request-access form on the Site. Please mark the message “Privacy”.