Privacy Policy

1. Introduction

Ascend AI ("we", "us", "our") is committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains how we collect, use, store, and share your personal information when you interact with our website.

Legal Framework

We are registered in England and Wales and operate in full compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).

Scope of This Policy

This policy applies to all personal data processed by Ascend AI through our website located at ascend-ai.co.uk (the "Site"). It does not apply to our portfolio companies, which maintain their own separate privacy policies.

Data Controller

Ascend AI is the data controller responsible for your personal data.

• Email: contact@ascend-ai.co.uk
• Website: ascend-ai.co.uk
• Registered in: England and Wales

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2. Information We Collect

We collect information directly from you when you interact with our Site.

2.1 Information You Provide Directly

When you submit an enquiry through our contact form, we collect the following information:

• Name (required)
• Email address (required)
• Organisation name (optional)
• Nature of enquiry (Investment, Partnership, Advisory, or General) (required)
• Message (required, minimum 50 characters)

2.2 Information Collected Automatically

Our website does NOT use cookies or analytics. Unlike many websites, we do not track your browsing behaviour or collect technical data such as IP addresses or device information.

We use Google Workspace solely to forward contact form submissions to our email inbox. Google's data processing practices apply only to email transmission, not to our website directly.

2.3 Information We Do NOT Collect

To be clear, Ascend AI does NOT collect:

• Website analytics or visitor tracking data
• Marketing cookies or tracking pixels
• Social media data (we have no social media integration)
• User accounts or authentication data
• Payment information (we do not process payments on this website)
• Location data or device fingerprinting

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3. How We Use Your Information

We use the personal data collected from our contact form solely for the following purposes:

3.1 Primary Purpose

• Responding to enquiries: To reply to your business enquiries and provide the information you have requested
• Business communication: To communicate with you about potential investment, partnership, or advisory opportunities relevant to your enquiry

3.2 Secondary Purposes

• Record keeping: To maintain a record of our communications for business continuity
• Legal compliance: To comply with our legal and regulatory obligations
• Fraud prevention: To detect and prevent fraudulent or malicious enquiries

3.3 No Automated Processing or Profiling

We do not use your data for automated decision-making, profiling or automated analysis of your characteristics, marketing or promotional communications (unless you specifically request ongoing updates), or selling or renting your data to third parties.

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4. Legal Basis for Processing (UK GDPR)

Under UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following legal bases:

4.1 Legitimate Interests (Article 6(1)(f) UK GDPR)

Our primary legal basis is legitimate interests. We process your personal data for responding to business enquiries in a timely and efficient manner, evaluating potential investment, partnership, or advisory opportunities, maintaining accurate business records, and preventing fraudulent or malicious communications.

Our legitimate interests do not override your fundamental rights and freedoms. We process only the minimum data necessary to achieve these purposes.

4.2 Legal Obligation (Article 6(1)(c) UK GDPR)

We may process your data to comply with legal obligations, such as tax and accounting record-keeping requirements, anti-money laundering regulations, or court orders or legal requests from regulatory authorities.

4.3 Consent (Article 6(1)(a) UK GDPR)

Where we send you information beyond what you initially requested, we will obtain your explicit consent first. You may withdraw your consent at any time by contacting us.

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5. Data Sharing

5.1 Who We Share Your Data With

We do NOT sell, rent, or trade your personal information. We may share your data only in the following limited circumstances:

Service Providers:

• Google Workspace: For email forwarding services only. Google processes emails solely for transmission purposes and does not use the content for any other purpose. Google's privacy policy governs their use of data.
• Web Hosting Provider: Our website is hosted by a third-party provider who may have access to server logs for technical maintenance purposes only.

Professional Advisers:

• Lawyers, accountants, or other professional advisers where necessary for our business operations
• All such advisers are bound by strict confidentiality obligations

Legal Requirements:

• Law enforcement or regulatory authorities when required by law
• To protect our rights, property, or safety
• In connection with any legal proceedings

5.2 Who We Do NOT Share With

We will NEVER sell your personal data to third parties, share your data with marketing companies, share your data with data brokers, or share your data with other organisations for their direct marketing purposes.

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6. Data Retention

6.1 Retention Periods

We retain your personal information only for as long as necessary:

• Contact form submissions: 3 years from the date of your last communication with us
• Email communications: 3 years from the date of the last message in the email thread

6.2 Retention Criteria

The retention periods are based on business needs and potential future opportunities, limitation periods for legal claims (typically 6 years), and the nature of our relationship (one-off enquiries vs. ongoing relationships).

6.3 Data Deletion

You may request the deletion of your personal data at any time by contacting us at contact@ascend-ai.co.uk. We will comply unless we have compelling legitimate grounds to retain your data, such as establishment, exercise, or defence of legal claims or compliance with legal obligations.

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7. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

7.1 Right of Access (Article 15)

You have the right to request a copy of the personal data we hold about you. We will provide this within 30 days of your request.

7.2 Right to Rectification (Article 16)

You have the right to request correction of inaccurate or incomplete personal data.

7.3 Right to Erasure (Article 17)

You have the right to request deletion of your personal data, subject to certain exceptions such as legal obligations.

7.4 Right to Restrict Processing (Article 18)

You have the right to request that we limit how we process your personal data in certain circumstances.

7.5 Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used format and to request that we transfer it to another organisation where technically feasible.

7.6 Right to Object (Article 21)

You have the right to object to processing based on legitimate interests. We will stop processing your data unless we have compelling legitimate grounds that override your interests.

7.7 Rights Related to Automated Decision-Making (Article 22)

We do not use automated decision-making or profiling, so this right is not applicable to our processing activities.

How to Exercise Your Rights

To exercise any of these rights, contact us at:

• Email: contact@ascend-ai.co.uk
• Subject line: "Data Rights Request"
• Response time: We will respond within 30 days of receiving your request

We may request verification of your identity before providing access to your data to protect your privacy.

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8. Data Security

8.1 Technical Measures

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss or destruction, unauthorised disclosure or access, and alteration or misuse.

Security Measures Include:

• Encryption: HTTPS/TLS encryption for all data transmitted between your browser and our website
• Access controls: Restricted access to personal data on a need-to-know basis
• Secure email: Emails are transmitted through encrypted connections (TLS)
• Regular security assessments: We review our security practices regularly

8.2 Data Breaches

In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, we will notify you without undue delay and no later than 72 hours after becoming aware of the breach, where required to do so by law.

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9. Cookies & Tracking

9.1 Our Position on Cookies

Our website does NOT use cookies. Unlike many websites, Ascend AI does NOT use essential cookies (for user preferences or shopping carts), analytics cookies (such as Google Analytics), marketing cookies, or any other form of tracking technology.

9.2 Third-Party Cookies

Our website contains no third-party widgets, social media plugins, or embedded content that would set cookies on your device.

9.3 Browser Settings

Since we do not use cookies, you do not need to adjust your browser settings for our website. However, your browser may still set cookies for other websites you visit.

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10. Children's Privacy

Our website and services are not intended for children under the age of 18. We do not knowingly collect personal data from children under 18. If you are under 18, please do not submit your contact form or provide any personal information to us.

If we discover that we have inadvertently collected personal data from a child under 18, we will delete it immediately.

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11. International Transfers

11.1 Email Forwarding via Google Workspace

Contact form submissions are forwarded via Google Workspace. Google may transfer data outside the UK/EEA. Google provides appropriate safeguards under the UK GDPR, including Standard Contractual Clauses (SCCs), Binding corporate rules where applicable, and compliance with UK adequacy regulations for data transfers.

For more information, see Google's privacy policy at policies.google.com/privacy.

11.2 No Other International Transfers

We do not transfer your personal data to any other countries outside the UK.

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12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or regulatory guidance.

If we make material changes to this policy, we will update the "Last Updated" date at the top of this policy, notify you via email if we have your contact details on file, and post a prominent notice on our website.

Minor clarifications or corrections may not warrant notification but will be reflected in the updated date.

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13. Complaints & Contact

13.1 Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

• Email: contact@ascend-ai.co.uk
• Website: ascend-ai.co.uk

13.2 Right to Lodge a Complaint

You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection matters.

ICO Contact Details:

• Website: ico.org.uk
• Phone: 0303 123 1113
• Helpline: 0303 123 1115 (for small organisations)
• Email: casework@ico.org.uk

The ICO can investigate your complaint and provide independent advice about your rights under data protection law.

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