EGM Foundry Ltd respects the privacy of the people who communicate with us and is committed to handling personal information responsibly and in accordance with applicable UK data protection law.
This Privacy Policy explains the limited personal information that EGM Foundry processes in connection with the administration, marketing and record-keeping of its own business.
1. Who we are
EGM Foundry Ltd (“EGM Foundry”, “we”, “us” or “our”) is a company registered in England and Wales.
Company number: 17261275
Registered office: 20 Wenlock Road, London, England, N1 7GU
Email: info@egmfoundry.com
EGM Foundry is the controller of the personal information described in this Privacy Policy.
Our commercial activities are focused primarily on legal entities, commercial transactions, contracts, commodities, logistics, financial information and other corporate or transaction-level information.
We do not ordinarily use personal information as an input into transaction scoring, Deal Passport eligibility assessment or other corporate analytical processes.
2. Personal information we process
We limit the personal information we process to what is reasonably necessary for the administration, marketing and record-keeping of our own business.
This may include:
- your name;
- professional role or job title;
- organisation or employer;
- business email address;
- business telephone number;
- business correspondence;
- information contained in an enquiry that relates to you as a business contact;
- records showing when and how we have communicated with you;
- information required for invoices, payments, contracts or records of transactions with EGM Foundry;
- information required to administer staff, directors, contractors or applicants; and
- your direct-marketing preferences, including any request not to receive further communications.
We do not ordinarily collect special-category personal data, personal credit information, criminal-record information, personal financial profiles, identity-document databases or information intended to assess an individual’s creditworthiness, reputation or personal risk.
Please do not send passports, identity documents, personal financial information, health information, criminal-record information or other sensitive personal information through our website or general email address unless we have specifically requested it and there is a lawful reason for doing so.
3. Corporate and transaction information
Much of the information used in EGM Foundry’s commercial activities relates to companies and transactions rather than identifiable individuals.
This may include:
- company names and registration information;
- corporate financial statements;
- contracts and commercial documents;
- commodities and cargo information;
- origin and destination information;
- logistics and transportation data;
- transaction values and payment terms;
- insurance and collateral information;
- corporate trade history;
- corporate credit characteristics;
- transaction milestones; and
- market and commercial information.
Information relating solely to a legal entity and which does not identify a living individual is not personal data.
EGM Foundry’s corporate and transaction assessment processes are designed to operate on this type of information rather than on personal profiles.
4. Why we use personal information
We process personal information only for purposes connected with the operation of EGM Foundry’s own business.
Our own advertising, marketing and public relations
We may use limited professional contact information to:
- introduce EGM Foundry and its services;
- respond to enquiries about our services;
- communicate with prospective and existing corporate customers, suppliers and business contacts;
- provide information about EGM Foundry’s activities, publications, services or events; and
- maintain a record of marketing preferences and objections.
We do not sell personal contact databases or provide personal information to third parties for their own unrelated advertising or marketing.
Our own accounts and business records
We may process limited personal information where necessary to:
- keep accounts;
- maintain records of purchases, sales and other transactions;
- maintain records of contracts and commercial communications;
- issue and retain invoices and payment records;
- ensure that payments, deliveries or services relating to EGM Foundry’s own transactions take place;
- decide whether to establish a customer or supplier relationship; and
- prepare financial or management forecasts relating to EGM Foundry’s business.
We do not obtain or process consumer credit-reference-agency information for these purposes.
Staff administration
Where applicable, we process personal information concerning employees, directors, workers, contractors, applicants and other persons working for EGM Foundry for normal personnel and administrative purposes.
5. Lawful bases
Depending on the circumstances, our lawful bases under UK data protection law may include:
- legitimate interests, including promoting EGM Foundry’s own services, maintaining appropriate business relationships and administering our own business records;
- contractual necessity, where processing is necessary in connection with a contract with an individual or steps requested before entering into one;
- legal obligations, including accounting, tax, company and employment requirements; and
- consent, where we specifically ask for it.
Where we rely on consent, you may withdraw that consent at any time.
The lawful basis we use under UK GDPR is separate from the rules governing whether an organisation is required to pay the ICO data protection fee.
6. Business enquiries and professional contacts
If you contact EGM Foundry, we may retain your name, professional contact details and correspondence where reasonably necessary to respond to your enquiry and maintain an appropriate record of the communication.
If no commercial relationship develops, enquiry information will normally be deleted or anonymised after the applicable retention period described below.
We may also obtain limited professional contact details from:
- company websites;
- professional networking services;
- business directories;
- professional events;
- business cards;
- corporate publications;
- publicly available professional sources; or
- introductions from existing business contacts.
Where we use such information, we use it only in connection with promoting and administering EGM Foundry’s own business and services.
7. Personal information and EGM Foundry’s analytical activities
EGM Foundry does not ordinarily use personal information to:
- assign personal credit scores;
- profile the behaviour of individuals;
- assess an individual’s personal wealth;
- conduct personal background investigations;
- create personal reputation scores;
- determine an individual’s political exposure;
- perform individual behavioural-risk scoring; or
- make automated decisions about individuals.
EGM Foundry’s commercial analysis is intended to relate to legal entities, transactions and commercial assets rather than natural persons.
8. KYC, identity verification and individual screening
EGM Foundry does not ordinarily maintain databases of passports, identity documents, personal credit files, source-of-wealth files, PEP profiles or individual screening records as part of its commercial assessment methodology.
Where a bank, financier, regulated institution or other independent organisation requires personal identity verification, sanctions screening, PEP screening or other individual KYC procedures, that organisation may request the relevant information directly from the individual or relevant party and process it under its own legal responsibilities and privacy arrangements.
EGM Foundry may record a limited corporate or transaction-level status such as:
- verification completed;
- verification pending;
- verification expired; or
- further information required,
where this is necessary for its own transaction records.
We do not ordinarily retain the underlying personal identification or screening materials used by another organisation to reach that status.
10. International transfers
Some providers supporting our email, hosting or business administration may process information outside the United Kingdom.
Where UK data protection law requires safeguards for an international transfer of personal information, we require an appropriate transfer mechanism, such as:
- UK adequacy regulations;
- an approved UK international data-transfer mechanism; or
- another lawful safeguard permitted under applicable data protection law.
We seek to minimise the amount of personal information transferred internationally.
11. Retention
We keep personal information only for as long as it is reasonably required for the purpose for which it was collected.
General business enquiries
Normally up to 24 months after the last meaningful communication where no commercial relationship develops.
Marketing and professional contacts
For as long as the contact remains reasonably relevant to EGM Foundry’s own business-development activities, subject to periodic review and your right to object.
Marketing suppression records
We may retain minimal information where necessary to ensure that a person who has opted out is not contacted again for direct marketing.
Accounts, contracts and transaction records
Normally up to six years following the end of the relevant accounting period, contractual relationship or transaction, or longer where required by law or necessary in connection with a legal claim.
Staff administration
For the period reasonably required by applicable employment, tax, company and other legal obligations.
Information that is no longer required is deleted, anonymised or securely destroyed.
12. Website technologies
EGM Foundry does not use its website to create behavioural profiles of visitors.
We do not ordinarily use advertising pixels, cross-site tracking technologies or visitor-level behavioural analytics.
Where strictly necessary technical functionality is required to deliver the website, we seek to minimise the information processed and do not use that information to profile visitors for advertising or commercial decision-making.
If we introduce analytics, tracking or other technologies that materially change how personal information is processed, we will review this Privacy Policy and the applicable cookie and data-protection requirements before doing so.
13. Your rights
Depending on the circumstances, UK data protection law may give you rights including the right to:
- request access to personal information we hold about you;
- request correction of inaccurate personal information;
- request deletion of personal information in certain circumstances;
- request restriction of processing;
- object to particular processing;
- request data portability where applicable; and
- withdraw consent where processing is based on consent.
Direct marketing
You have the right to object at any time to the use of your personal information for direct marketing.
If you tell us that you do not want to receive direct-marketing communications, we will stop using your personal information for that purpose.
We may retain limited information on a suppression list so that we can respect your request in the future.
14. Security
We take reasonable organisational and technical measures appropriate to the limited personal information we hold.
These may include access controls, password protection, restricted permissions, appropriate service-provider arrangements and reasonable measures designed to protect business correspondence and records against unauthorised access, alteration or loss.
15. Automated decision-making
EGM Foundry does not ordinarily make decisions producing legal or similarly significant effects on individuals solely through automated processing of personal information.
Corporate or transaction-level analytical models used by EGM Foundry are intended to evaluate legal entities, commercial transactions and transaction characteristics rather than natural persons.
16. Changes to this policy
We may update this Privacy Policy where our business activities, technology or legal obligations change.
Where a material change affects how we use personal information, we will update this policy before or when the relevant change takes effect.
The latest version will be published on this website together with the date of the most recent update.
17. Contact
For privacy enquiries or to exercise your data-protection rights, contact:
EGM Foundry Ltd
20 Wenlock Road
London
England
N1 7GU
Email: info@egmfoundry.com
You also have the right to raise a complaint with the UK Information Commissioner’s Office if you believe that your personal information has been handled in breach of applicable data protection law.