Privacy & Data Handling Guidelines
1. FORENSIC ISOLATION
We do not "pool" data. Your client data never trains another firm's model. Each client environment is architecturally isolated within the Sovereign OS. The intelligence we build for you remains yours.
2. UK GDPR COMPLIANCE
We operate as a Data Processor. Your prospect data is processed under the "Legitimate Interest" basis for B2B outreach, ensuring compliance with PECR and UK GDPR. We are registered with the Information Commissioner's Office (ICO) as a data controller.
3. DATA WE COLLECT
We collect data through three primary channels:
- Client-Provided DNA: Information you input to train the system (company goals, tone of voice, project briefs).
- Public Reconnaissance: Our system maps publicly available professional data (LinkedIn, Companies House, News, Regulatory Filings) to identify decision-makers.
- Interaction Logs (The Vault): We track the status of outreach (emails sent, opens, replies) to optimize your campaign performance.
4. THE VAULT PROTOCOL
Data is encrypted at rest. When you request a "System Purge," the deletion is forensic and irreversible. All interaction history, prospect lists, and forensic research generated for the Client are proprietary to the Client and stored securely within their OS instance.
5. THIRD-PARTY DISCLOSURE
We do not sell data to brokers. We only share data with:
- Target Principals: Sharing your basic professional details (Name/Company) to facilitate the meeting you requested.
- Infrastructure Partners: Secure cloud providers (Google Cloud/Firebase) where the OS is hosted.
6. SECURITY
We employ "Institutional Grade" security. All data at rest is encrypted, and access to the Command Uplink is restricted via authenticated neural-token gateways. We maintain ISO 27001-aligned security practices.
7. YOUR RIGHTS
Under UK GDPR, you have the right to:
- Access: Request a copy of all data we hold on you.
- Rectification: Request correction of inaccurate data.
- Erasure: Request complete deletion of your data ("Total System Reset").
- Portability: Request your data in a machine-readable format.
- Object: Object to processing based on legitimate interests.
8. CONTACT THE PRIVACY OFFICER
For matters regarding data sovereignty, contact:
Accumen Intelligence Ltd
Attn: Legal & Privacy Dept.
71-75 Shelton Street, Covent Garden
London, WC2H 9JQ
Email: hello@accumen.xyz