General information on our use of personal data

 

Updated: October 2025

 

In this privacy notice (the "Notice") we describe how we collect, use, and share your personal data when using our platform (the "Platform"), our website, our digital channels, when you communicate with us and when you participate in events and other activities that we arrange. The services available through our Platform are below named the "Service."

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Personal data means any information that, directly or indirectly, identifies you, for example, your name or your IP address.

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We are committed to your privacy. We take measures to ensure that your personal data is protected and that our use of personal data complies with applicable regulations and laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, and our internal procedures and routines.

In the event our website contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.

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1. WHO IS COVERED BY THIS NOTICE?

This Notice covers:

• Users of our Platform, our website, and our digital channels, for example, our channels and feeds on social media platforms.

• Contact persons of a customer, supplier, or partner to us.

• External persons who contact or otherwise communicate with us and are not covered by the categories above.

 

2. WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL DATA?

Impactive Tech Ltd ("we," "our" and "us") is responsible for the use of your personal data as described in this Notice. Please see section 11 below for contact information.

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3. WHICH PERSONAL DATA DO WE COLLECT?

We only collect the personal data that we need. We collect and process the following categories of personal data, but which personal data we collect about you, in particular, depends on how you interact with us:

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• Identity information. Information that makes it possible to identify you, for example, your name.

• Contact information. Information that makes it possible to contact you, for example, your email address.

• Profile information. Information regarding your company or organisation that you work for and your country.

• User-generated information. Information regarding your activity and use of our Platform, website, digital channels, and services, for example, clicks and visits and your behaviour when using the Platform, the website, and our digital channels.

• Communication. Contents of communication with us, for example, contents in email communication or the responses you provide when participating in a survey.

• Payment information. Information necessary to process payments for our services, including billing details. Where payment is made by card, payment card information is processed directly by our payment service provider (Stripe) and we do not store full payment card details. Where payment is made by bank transfer, we collect and store the information necessary to process and reconcile the payment.

• Order information. Information about orders for services, for example, the service subscribed to, price or fee, subscription period.

• Technical information. Technical information about the device that you use when using our Platform or visiting our website and digital channels, for example, type of device, version of browser, operating system, and IP address.​

 

4. FROM WHERE DO WE COLLECT PERSONAL DATA?

We collect personal data from the following sources:

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• Yourself. When you use our Platform, website and other digital channels, register for an account, contact us or communicate with us, we collect the personal data that you provide to us.

• Publicly available sources. Our Platform provides intelligence on shareholder engagement and voting derived from publicly disclosed records. This information is collected from publicly available regulatory filings and disclosure documents.

• Social network platforms. If you visit our channels or feeds on social media, we collect the personal data that you provide to us when using these channels.

• Service providers. We receive certain technical and usage data from our service providers, such as hosting and analytics providers.

• External persons. We collect personal data about you that external persons provide to us, for example, in connection with communication or an event or similar activity.

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5. WHY DO WE USE YOUR PERSONAL DATA?

Below we explain the purposes for our use of personal data and provide examples of processing activities carried out for each purpose. Please note that not all processing activities may apply to you. Which processing activities apply to you depend on how you interact with us.

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Provide the Service

If you have signed up and registered a user account for the Service, we use your personal data to provide the Service, including to set up and administrate your user account, provide access to shareholder engagement and voting intelligence, and to deliver customised content and features in the Service based on your use.

You need to provide the information that we request when you sign up and register a user account for the Service as the information is necessary for the performance of the contract with you. If you do not provide the information requested, we cannot create your user account and you cannot use the Service.

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Process payments

We use your personal data to process payments for the Service. Payment processing may be handled by our payment service provider, Stripe (for card payments), or directly by us (for bank transfer payments).

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Communicate about the Service

If you are a user of the Service, we use your personal data to communicate with you regarding the Service, for example to notify you of updates to the Service, changes to your subscription, or important service announcements.

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Analyse the use of the Service

We use your personal data to analyse the usage of the Service on an aggregated level, for example to collect and analyse statistics of how the Service is used and how users interact with various functions in the Service. This helps us better understand how the Service is used and how we can continue to develop and improve the Service. We do not profile your personal data for this purpose since analysis is made using aggregated information.

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Develop and improve the Service

We continuously develop and improve the Service in order to provide the best experience possible. We therefore use your personal data for this purpose, for example to develop new features for the Platform.

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Detect and prevent misuse of the Service

We use your personal data to detect and prevent misuse of the Service, including unauthorised access and fraudulent activity. This is for your and others' safety.

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Manage the relationship with business customers, suppliers, and partners

If you are a contact person of a business customer, supplier or partner to us, we use your personal data to manage the customer or supplier relationship or partnership, for example, to register you as a contact person, manage invoices and agreements, and to communicate for the same purpose.

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Manage orders of services

To manage orders of services, we use, where necessary, your personal data for this purpose if you are a contact person for the customer or supplier, for example to manage requests for proposals, submit and manage orders, and to communicate for the same purpose.

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Follow up and evaluate the relationship with business customers, suppliers, and partners

We use, where necessary, personal data about contact persons of business customers, suppliers, and partners to follow up and evaluate the customer or supplier relationship or partnership.

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Respond to questions

If you contact us, for example by email or phone, with a question, we use the personal data that you share with us to respond to your question.

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Communicate about us, our business, and our services

We use your personal data to communicate about us, our business, and our services in various channels, including for marketing and promotional purposes. This includes communicating with you regarding offers from us in various digital channels (e.g., email and social network platforms) and promoting the Service and activities that we carry out, such as webinars, events, and surveys. You can at any time unsubscribe from our communications by clicking on the unsubscribe link in the communication or by contacting us.

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We also share your personal data for this purpose with marketing platforms. Please see section 6 below for further information on which recipients we share personal data with.

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Communication between employees and external persons

We use your personal data, where applicable, in connection with communication, for example, by email, between employees and external persons.

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Provide newsletter

We use your personal data to provide our newsletter, for example to send out the newsletter and manage your subscription. You can at any time unsubscribe from the newsletter by clicking on the unsubscribe link in the newsletter or by contacting us.

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Follow up and analyse the business

We use your personal data to compile reports on an aggregated level and statistics to follow up and analyse the business. We do not profile your personal data for this purpose.

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Document the business

We use your personal data, where necessary, to document the business, for example, to manage and store agreements, decision documents, minutes, and presentations.

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Carry out events and other activities

If you participate in an event or another activity that we arrange, such as webinars or conferences, we use your personal data to carry out the event or activity, for example, to register your participation and to communicate with you regarding the activity.

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Carry out surveys

If you choose to participate in a survey that we carry out, we collect the personal data that you provide in connection with the survey. Your opinions about our business and services are important to us. You can unsubscribe from such communications at any time by clicking on the unsubscribe link in the communication or by contacting us.

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Develop and improve the business

We use your personal data when we carry out analysis on an aggregated level to develop and improve the business, our business methods, and business strategies. We do not profile your personal data for this purpose.

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Follow-up and analyse the use of this website and our digital channels

It is important for us to understand how this website and our digital channels are used. We therefore use your personal data for this purpose, for example, when we collect and analyse visitor and user statistics on how our website and digital channels are used.

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Enable functionality on this website

To enable functionality on this website, for example to remember your settings and maintain your login session, we use where necessary your personal data. This is in order to provide you with a better user experience on the website.

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Ensure technical functionality and security

We use your personal data to ensure necessary technical functionality and security of the Platform, this website and our IT systems, for example, for security logging, error handling, and backups.

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Manage and defend legal claims

If needed, we use your personal data to manage and defend legal claims, for example, in connection with a dispute or court proceeding. For this purpose, we share personal data, when needed, with other recipients. Please see section 6 below.

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Fulfil legal obligations

To fulfil our legal obligations, if necessary, we will use your personal data, for example, to fulfil accounting, tax, or data protection obligations. For this purpose, we may share certain information with other recipients. Please see section 6 below for more information.

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6. WHICH RECIPIENTS DO WE SHARE PERSONAL DATA WITH?

Below we describe which recipients we share your personal data with. Which recipients we share your personal data with depends on how you interact with us. Unless we have stated otherwise below, the recipient is responsible (data controller) for its own use of your personal data.

 

Service providers

To process personal data for the purposes described in this Notice, we share personal data with service providers that we have engaged. These service providers provide, for example:

• Cloud hosting services (Microsoft Azure, AWS) for storing and processing data

• Payment processing services (Stripe) for handling subscription payments and billing

• Marketing and communications services (HubSpot) for managing customer communications and marketing campaigns

• Analytics services for understanding how our Platform and website are used (Google Analytics)

 

When the service providers process personal data on our behalf, they act as data processors for us, and we are responsible for the processing of your personal data. They must not use your personal data for their own purposes and are contractually and legally obliged to protect your personal data.

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Business communications:

When we communicate with you or on your behalf, personal data may be shared as part of normal business correspondence via email, phone, or other communication channels.

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Social network platforms

To communicate and provide promotional content in our digital channels and on other websites, we share personal data with social network platforms such as LinkedIn.

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Other recipients

If needed, we share your personal data with other recipients for the following purposes:

• to manage a merger or sale of the business,

• to manage and defend legal claims and rights,

• to fulfil legal obligations,

• to respond to a lawful request from authorities, and

• to protect and ensure the safety of our staff.

 

Examples of recipients are external advisers (such as legal or financial advisers), public authorities, courts, law enforcement, and potential buyers and sellers should we sell the business.

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7. YOUR RIGHTS

Rights in relation to the use of your personal data

We normally reply to your request within one month following the date that we received the request. If your request is complex or if you have submitted several requests at the same time, we may need additional time to respond to your request. If we consider it necessary to extend the time to respond to your request, we will notify you of this and the reason as to why we need more time to respond to your request within one month following the date that we received your request. The time to respond to your request can be extended by up to a maximum of two months.

Moreover, if we for some reason cannot, wholly or partly, respond to your request, we will notify you of this and the reason as to why we cannot reply to your request within one month following the date that we received the request.

If you have submitted your request electronically, for example via email, we will also respond to your request electronically unless you request otherwise.

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We need to confirm your identity to reply to your request

When you submit a request to exercise your rights, we need to confirm your identity to ensure that you are who you claim to be. This is to avoid that we, for example, disclose personal data to an unauthorised person or in error delete personal data. It is helpful if you use the same email address that you used to sign up for the Service when submitting a request to exercise your rights. If we do not have sufficient information to confirm your identity, we can request that you provide supplementary information about yourself needed to confirm your identity. We only request such information that is reasonable and necessary.

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Below we describe the rights that you have in relation to your personal data.

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Right to access (Article 15 of the UK GDPR)

You have the right to request confirmation from us as to whether we handle your personal data and in such case receive a copy of your personal data together with additional information on our use of your personal data. Please note that the right to a copy of your personal data may not adversely affect the rights of others.

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Right to rectification (Article 16 of the UK GDPR)

You have the right to request that we rectify or supplement your personal data if you consider that your personal data is incorrect, incomplete, or misleading.

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Right to withdraw your consent (Article 7 of the UK GDPR)

For certain use of your personal data, we rely on your consent. When we use your personal data based on your consent, you have the right to at any time withdraw your consent. When you have withdrawn your consent, we will not continue to use your personal data based on the consent previously provided.

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Right to erasure (Article 17 of the UK GDPR)

You have in certain situations the right to request erasure of your personal data ("the right to be forgotten"). Accordingly, the right to erasure is subject to certain conditions. For example, the right to erasure applies if we keep your personal data but no longer need the personal data for the purposes for which it was collected, if you withdraw your consent which we rely on for our use of your personal data, or if you object to our use of your personal data and we cannot show a compelling reason to further use your personal data notwithstanding your objection.

There are also several exemptions from the right to erasure, including if we are obligated under law to keep your personal data or if the personal data is needed to exercise, manage, and defend legal claims.

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Right to object to our use of personal data (Article 21 of the UK GDPR)

In certain situations, you have the right to object to our use of your personal data. Where we rely on our or another's legitimate interest for the use of your personal data, you have the right to object to the use for reasons which relate to your particular situation. If we cannot show a compelling reason to continue to use your personal data, we will stop using your personal data for the relevant purpose.

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You always have an unconditional right to object to our use of your personal data for direct marketing purposes.

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Right to request restriction of your personal data (Article 18 of the UK GDPR)

In certain situations, you have the right to request restriction of your personal data which means that you can, at least for a certain period, stop us from using your personal data. The right to request restriction of your personal data applies if you consider that the personal data about you is incorrect and during the period that we verify this, if the use of your personal data is unlawful and if you wish that we continue to store your personal data instead of deleting the personal data, and if we no longer need your personal data for the purposes for which we collected the personal data, but you need the personal data to manage, defend or exercise legal claims and rights.

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You also have the right to request restriction of your personal data if you have objected to our use of your personal data and during the period we verify whether we have a compelling reason to continue to use your personal data.

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If the use of your personal data has been restricted, we may normally only store your personal data and not use it for any other purpose than to manage, defend or exercise legal claims and rights. We can also use your personal data for other purposes if you have given your consent to such use.

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Right to copy of certain personal data and transfer of the personal data to an external recipient (data portability) (Article 20 of the UK GDPR)

The right to data portability means that you have a right to receive a copy of the personal data that you yourself have provided to us in a structured, commonly used format. Moreover, where it is technically feasible, you also have the right to request that the copy of your personal data is transferred directly to an external recipient.

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The right to data portability only applies, however, to personal data that we handle based on your consent or for the performance of an agreement with you.

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Right to lodge a complaint

You have the right to lodge a complaint with the relevant supervisory authority. In the United Kingdom, the supervisory authority is the Information Commissioner's Office (ICO) (www.ico.org.uk).

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Automated individual decision-making

We do not carry out any automated individual decision-making which has legal effects or similar significant effects on you.

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8. COOKIES AND OTHER TECHNOLOGIES

We use cookies and other technologies on our website. Cookies are small text files that are stored on your device when you visit our website. We use cookies to:

• Enable essential functionality of the website

• Remember your preferences and settings

• Analyse how our website is used

• Deliver relevant marketing content

 

You can control and manage cookies through your browser settings. However, please note that disabling certain cookies may affect the functionality of our website.

 

For more detailed information on our use of cookies, including the types of cookies we use and how to manage your cookie preferences, please see our Cookie Policy.

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9. WHERE WE PROCESS PERSONAL DATA

We store and process your personal data within the United Kingdom. All of our data processing infrastructure and service providers are located in the UK, ensuring that your personal data remains within UK jurisdiction at all times.

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If our data processing arrangements change in the future and we need to transfer personal data outside the UK, we will update this Notice and implement appropriate safeguards to protect your personal data.

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For more information on where your personal data is stored and processed, please contact us. Please see section 11 below for contact details.

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10. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected or to comply with legal, regulatory, or internal policy requirements.

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As a general rule:

• Account and service data: We retain your account information and usage data for as long as your account is active and for a reasonable period thereafter to allow you to reactivate your account if needed.

• Payment and billing data: We retain payment records for the period required by applicable tax and accounting laws.

• Marketing communications: We retain your contact details for marketing purposes until you unsubscribe or request deletion.

• Technical and analytics data: We typically retain aggregated analytics data indefinitely as it does not identify individuals.

 

When we no longer need your personal data, we will securely delete or anonymise it.

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11. UPDATES TO THIS NOTICE

We regularly update this Notice in order to ensure that it reflects our use of personal data from time to time. As an example, we will update this Notice if we decide to collect additional categories of personal data or if we intend to use collected personal data for additional purposes.

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We will in such case notify you by appropriate means, for example by showing a message on the Platform, on this website or by email. The latest version of the Notice is always available on this page and the date the Notice was last updated is stated at the top of this document.

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12. ANY QUESTIONS?

If you have questions about this Notice, our use of your personal data or if you wish to exercise your rights, please contact us:

 

Impactive Tech Ltd
Company Registration Number: 14351993
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: info@impactive.pro

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If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) (www.ico.org.uk), the data protection authority in the United Kingdom.