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Privacy Notice


This Privacy Policy is applicable to personal data we may collect in the course of business or of employment contracts, or in connection with services we are provided by consultants or contractors, and explains how we use any personal data ("information") we collect from or about you.

In this Privacy Policy "we", "us", "Gardenia" means Gardenia Technologies Limited, a company incorporated in England and Wales under number 10047691, whose registered office is at 10 Orange Street, WC2H 7DQ, Haymarket, London, and whose place of business is at 71-91 Aldwych, WC2B 4HN.

The specific provisions applying to relationships with employees, consultants, and contractors are set out in the relevant addendum hereto.


This policy describes:

  • what information we collect about you;

  • how we use your information;

  • how we source your information;

  • who we share your information with;

  • your rights regarding our use of your information;

  • how long we keep your information; and

  • how to contact us.

The information we collect about you

We collect some or all of the following information about you:

  • Contact details, including but not limited to email, telephone numbers, Skype addresses;

Source of Information

We will gather information about you from the following sources:

  • from you directly;

  • cookies or other such analysis on our website.

How we use your information

We use your information for the following legitimate business purposes:

  • to work with you on proposals and transactions, including:

  • sharing corporate data and drafting documents;

  • for analytics and algorithm development and calibration;

  • to comply with our legal obligations and establish, exercise, or defend our legal rights;

  • for those other purposes that you have agreed with us.

Who we share your information with

We share your information with the following:

  • our subcontractors and consultants, including but not limited to lawyers and accountants; if we do transfer your information we will take appropriate steps to protect that information according to;

    • The Data Protection Act 2018 (DPA 2018) and the UK General Data Protection Regulation (UK GDPR) as it applies in the UK;

    • The EU General Data Protection Regulation (GDPR) if you are a resident of a country member of the European Union.

Some of these third parties could be based outside the UK.

If we do transfer your information outside we will take appropriate steps to protect that information, which include:

  • only transferring to third parties in jurisdictions that the UK Government has determined offers adequate protection for your information;

  • entering into an agreement with the third party, which includes clauses that the UK Government has determined offers adequate protection for your information, or

  • transferring to third parties that have agreed to comply with schemes approved by the UK Government to protect your information.

Your rights regarding your information

You have rights under data protection law in relation to our use of your information, including to:

  • request access to your information, of which you can do by contacting Gardenia Technologies;

  • update or amend your information if it is inaccurate or incomplete;

  • object to certain uses of your information (which includes processing for direct marketing purposes, processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling) and processing for purposes of scientific or historical research and statistics) on grounds relating to your particular situation;

  • request the deletion of your information, or restrict its use, in certain circumstances (for example you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected (unless certain exceptions apply));

  • withdraw any consents you have provided in respect of our use of your information;

  • request the return of information you have provided to us, to use for your own purposes (often called your right to data portability) where the processing is based on your consent or for the performance of a contract; and the processing is carried out by automated means; and

  • to lodge a complaint with the Information Commissioner’s Office ( ).

More information about these rights can be found at . If you have any questions about these rights, or you would like to exercise any of them, please contact Gardenia – additional details of how to get in touch are set out in section 'How to contact  us' below.

Data breach

In the event that a breach is identified, the Security Officer will:

  • enter details of the breach into our personal data breach records;

  • carry out an investigation into what happened and take appropriate steps to restrict the consequences of the breach;

  • assess whether the breach needs to be reported to the Information Commissioner’s Office (‘ICO’);

  • assess whether the affected individual needs to be informed of the breach;

  • assess whether any third parties or other authorities need to be informed.

How long we keep your information for

Gardenia will keep your information for:

  • for at least five years after your employer has ended its relationship with Gardenia;

  • for an indeterminate length of time in order to maintain required records etc. Data that is not needed, such as contact details, can be deleted with the agreement of the Company on request.

How to contact us

Please contact us if you have any questions about this Privacy Policy or the information we hold about you:

  • by email:

  • by phone: +44 (0)203 384 4866

  • by post: Gardenia Technologies Limited 71-91 Aldwych London WC2B 4HN

Changes to this Data Protection Policy

We keep this Privacy Policy under regular review and we will place any updates on this page.