Privacy Policy

2. Scope and our role

This Privacy Policy explains how we collect, use, store and protect Data obtained through the Website and through related communications with us.

Integrate Projects Ltd is the data controller for personal data processed in connection with the Website, unless we tell you otherwise.

We provide specialist construction procurement, contract management and commercial services for clients operating in sectors including Defence, Infrastructure and Commercial.

This Privacy Policy applies only to our processing of Data. It does not apply to websites, applications or services operated by third parties that may be accessible through links on the Website. You should read the privacy policies of those third parties before providing them with personal data.

3. How we collect Data

We may collect Data in the following ways:

3.1 Data you give us

You may provide Data when you:

• complete and submit the enquiry form on the Website;
• contact us by telephone;
• contact us by email;
• correspond with us by post; or
• otherwise communicate with us in connection with our services.

The Website enquiry form currently collects:

• Full name — required;
• Organisation — required;
• Email address — required;
• Telephone number — optional;
• Sector — required, selected from Defence, Infrastructure, Commercial or Other; and
• "How can we help?" — required free-text message.

The form also contains a hidden honeypot field used solely for spam-prevention purposes. It is not intended to collect personal data and is not used for any other purpose.

The notice displayed beneath the form states:

We use these details only to respond to your enquiry. Read our Privacy Policy.

3.2 Data collected automatically

When you access or use the Website, certain technical information may be collected automatically by the Website or its hosting infrastructure. This may include:

• your IP address;
• the date and time of access;
• the frequency of access;
• information about how you use and interact with Website content; and
• technical information required to deliver, secure and maintain the Website.

As at the date of this Privacy Policy:

• the Website sets no cookies;
• no analytics service is active;
• no PostHog analytics data is being collected or transmitted; and
• no marketing or advertising tracking technology is active.

The Website currently stores one local-storage entry on a visitor's device to remember that the visitor has acknowledged the Website's cookie notice. The entry is described in our separate Cookie Policy.

Local storage and similar technologies may be subject to PECR and related privacy requirements in the same way as cookies. We use the current local-storage entry only to remember the acknowledgement of the notice.

For further information, please read our Cookie Policy.

4. How we use Data and our lawful bases

We use Data for the following purposes.

4.1 Responding to enquiries

We use information submitted through the enquiry form and information provided by telephone, email or post to:

• understand your enquiry;
• contact you about your enquiry;
• provide information about our services;
• assess potential project requirements; and
• take steps at your request before potentially entering into a contract.

Depending on the circumstances, our lawful basis for this processing will be:

• our legitimate interests in responding to genuine business enquiries and developing our services; and/or
• taking steps at your request before entering into a contract.

You are not required to provide information through the Website. However, if you do not provide the required information, we may not be able to respond adequately to your enquiry.

4.2 Operating, securing and improving the Website

We may use technical information to:

• operate and maintain the Website;
• protect the Website against misuse, fraud, malicious activity and security threats;
• identify and resolve technical faults;
• understand general patterns of Website use; and
• improve the Website, its content and its usability.

Our lawful basis for this processing is generally our legitimate interests in operating, securing and improving our Website and business, provided those interests are not overridden by your rights and freedoms.

4.3 Complying with legal obligations

We may process Data where necessary to:

• comply with legal or regulatory requirements;
• respond to lawful requests from public authorities;
• establish, exercise or defend legal claims; and
• maintain appropriate business and financial records.

Our lawful basis for this processing is compliance with a legal obligation and, where relevant, our legitimate interests in establishing, exercising or defending legal claims.

4.4 Analytics, if introduced in future

Analytics is not active on the Website as at the date of this Privacy Policy.

If we introduce analytics or other non-essential tracking in the future, we will:

• update this Privacy Policy and our Cookie Policy;
• explain the relevant provider, information collected and purposes;
• obtain valid consent before activating non-essential cookies or similar technologies where required by PECR; and
• use consent as the UK GDPR lawful basis for any associated processing where applicable.

You will be able to refuse or withdraw consent without affecting the lawfulness of processing carried out before withdrawal.

5. Keeping Data secure

We take reasonable and appropriate technical and organisational measures to protect Data against unauthorised access, accidental loss, destruction, alteration, disclosure or other unlawful processing.

These measures may include:

• using reputable hosting and service providers;
• applying access controls;
• using secure communications and transmission methods where appropriate;
• limiting access to Data to people who need it for legitimate business purposes;
• maintaining appropriate operational procedures; and
• monitoring and addressing technical or security risks.

The Website does not provide user accounts and does not use account usernames or passwords.

No method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we will continue to review and improve our security arrangements where appropriate.

If you believe that Data may have been compromised or that there has been a security incident involving us, please contact us promptly at hello@integrateprojects.co.uk.

For general information about staying safe online, you may also refer to www.getsafeonline.org.

6. Data retention

We retain Data only for as long as reasonably necessary for the purposes for which it was collected, including to:

• respond to and manage enquiries;
• establish, exercise or defend legal claims;
• comply with legal, accounting or regulatory requirements; and
• maintain appropriate business records.

The Website itself does not store enquiry form submissions in a database. Enquiries submitted through the Website are delivered by email to hello@integrateprojects.co.uk.

Personal data submitted through the Website enquiry form (and related enquiry correspondence) is retained for 12 months from the date of the last contact, after which it is securely deleted, unless a longer period is required to fulfil a contractual relationship, comply with a legal or regulatory obligation, or deal with a legal claim.

Data may continue to exist for a limited period in backup or archival systems after it has been deleted from active systems. Where this occurs, it will be protected and deleted in accordance with our backup and retention procedures.

7. Third-party service providers and data processors

We use selected third-party service providers to operate the Website and support our business. Where these providers process personal data on our behalf, they act as data processors and are required to process that data only in accordance with our instructions and applicable Data Protection Laws.

7.1 Marblism

The Website is built and hosted using services provided by Marblism.

Marblism also provides hosting and content delivery infrastructure, including the delivery of certain Website images from cdn.marblism.com.

7.2 Marblism email service

When you submit an enquiry through the Website:

1. the form sends the information to a same-origin Website endpoint;
2. the endpoint forwards the enquiry server-side to Marblism's email service at ai.marblism.com; and
3. the enquiry is delivered to hello@integrateprojects.co.uk.

This server-side process does not cause Marblism's email service to set third-party cookies on your browser.

7.3 Penny blog API

Website blog content may be obtained from the Penny blog API provided through Marblism. Blog content is fetched server-side at build time. The Website does not use this service to set client-side cookies on visitors' devices.

We may appoint or replace service providers where reasonably necessary to operate, secure and improve the Website and our business. We will take reasonable steps to ensure that any replacement or additional processor provides appropriate safeguards for personal data.

8. Sharing your Data

We may share Data only where reasonably necessary and lawful, including with:

• the service providers and processors described in this Privacy Policy;
• professional advisers, including legal, accounting, insurance and financial advisers;
• courts, regulators, law enforcement agencies or public authorities where required or permitted by law;
• insurers or other relevant parties in connection with managing legal, regulatory or operational matters; and
• a buyer, investor, funder, successor or other relevant party in connection with a proposed or actual sale, restructuring, merger, acquisition or transfer of all or part of our business.

We do not sell personal data.

We will not share Data with third parties for their own unrelated marketing purposes unless we have a lawful basis to do so and, where required, your consent.

9. Changes of business ownership or control

If Integrate Projects Ltd is involved in a merger, acquisition, sale of assets, restructuring, insolvency process or other change of ownership or control, your Data may be transferred to the relevant successor or acquiring entity where necessary for the relevant transaction or to continue providing services.

Where required by law, we will provide appropriate information about the change and the treatment of your Data.

10. International transfers

Some of our service providers or their supporting infrastructure may process Data outside the United Kingdom.

Where Data is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful under applicable Data Protection Laws. Depending on the circumstances, this may include:

• transferring Data to a country recognised as providing an adequate level of protection;
• using the UK International Data Transfer Agreement or UK International Data Transfer Addendum to the EU Standard Contractual Clauses;
• applying other appropriate safeguards permitted by applicable law; or
• relying on a lawful derogation where appropriate.

You may contact us using the details in section 16 if you would like further information about the safeguards applicable to a particular international transfer.

11. Your rights

Subject to certain legal conditions and exemptions, you may have the following rights in relation to your personal data:

• The right of access — to request a copy of the personal data we hold about you;
• The right to rectification — to ask us to correct inaccurate or incomplete personal data;
• The right to erasure — to ask us to delete personal data in certain circumstances;
• The right to restriction — to ask us to restrict how we use personal data in certain circumstances;
• The right to data portability — to receive certain personal data in a structured, commonly used and machine-readable format, or ask us to transmit it to another controller, where applicable;
• The right to object — to object to processing based on our legitimate interests, unless we can demonstrate compelling legitimate grounds to continue processing;
• The right to withdraw consent — where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal; and
• The right to complain — to complain to the Information Commissioner's Office.

To exercise any of these rights, please contact us using the details in section 16. We may need to verify your identity before responding.

We aim to respond to valid requests within the period required by applicable Data Protection Laws.

You may complain to the Information Commissioner's Office using its website:

https://ico.org.uk/

12. Cookies and similar technologies

As at the date of this Privacy Policy, the Website sets no cookies.

The Website currently uses one first-party local-storage entry to remember that a visitor has acknowledged the Website's cookie notice. It is not used for advertising, profiling or analytics.

The Website currently has:

• no analytics cookies;
• no marketing or advertising cookies;
• no Google Analytics or Google Tag Manager;
• no Meta Pixel;
• no Hotjar, Mixpanel, Segment, Matomo or Microsoft Clarity;
• no third-party embedded content or iframes; and
• no externally hosted web fonts such as Google Fonts.

If we introduce non-essential cookies or similar technologies in the future, we will provide clear information about them and introduce a genuine opt-in consent mechanism before they are used where required by PECR.

You can find further information about the Website's current storage technologies, how they operate and how to manage them in our separate Cookie Policy.

13. Links to other websites

The Website may contain links to third-party websites or services.

We are not responsible for the privacy, security, content or practices of third-party websites. A link to another website does not mean that we endorse it or that this Privacy Policy applies to it.

You should review the privacy policy of any third-party website before providing personal data or using its services.

14. General provisions

You may not transfer any rights you have under this Privacy Policy to another person without our prior written consent.

If any provision of this Privacy Policy is found to be invalid, unlawful or unenforceable, that provision will be treated as deleted to the minimum extent necessary. The remaining provisions will continue in full force and effect.

A failure or delay by us in exercising any right or remedy under this Privacy Policy will not constitute a waiver of that right or remedy.

This Privacy Policy and any dispute or claim arising out of or in connection with it are governed by the law of England and Wales.

The courts of England and Wales will have exclusive jurisdiction in relation to any dispute or claim arising out of or in connection with this Privacy Policy, subject to any mandatory rights you may have under applicable law.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• the Website;
• our services or business practices;
• the technology or service providers we use;
• applicable Data Protection Laws; or
• regulatory guidance.

The updated version will be posted on the Website with a revised "Last updated" date. You should check this page periodically to ensure that you are aware of the current version.

16. Contact us

If you have any questions about this Privacy Policy, our processing of Data or the exercise of your rights, please contact:

Email: hello@integrateprojects.co.uk

Telephone: 020 451 319 14