Empire Group | Technology Empire Ltd Privacy Policy

Empire Group | Technology Empire Ltd (“We”, “Us”, “Our”)) is committed to protecting and respecting your privacy. This policy explains how we collect, use, store, and protect your personal data in accordance with the new Data (Use and Access) 2025, the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018 (DPA 2018), and Electronic Communications (EC Directive) Regulations 2004.

Who we are

Empire Group | Technology Empire Ltd is a registered company in England and Wales under the company number 07694674 with our registered address at Empire House College Road, Rochdale OL12 6AE.

We are registered with the Information Commissioner’s Office. For more information regarding

• our data protection practices please contact gdpr@empire-groupuk.com or
• general information about our services please contact support@empire-groupuk.com.

How we collect our data

As a technology service provider focused on redefining how organisations use AI and digital solutions to grow, we collect personal information through several legitimate and transparent methods. This enables us to deliver our services effectively, understand your needs, and continue improving the value we provide.

We collect personal data in the following ways:

• Direct enquiries: When you share your contact details with us to request information about our products or services. This may occur through our online enquiry forms, by telephone, by e-mail, or during face-to-face interactions.
• Website use and cookies: When you visit our website, certain information is collected automatically through cookies and similar technologies, depending on the preferences you allow.
• Publicly available sources: We may obtain information from open sources such as LinkedIn, company websites, or professional directories where you have made your details publicly accessible.
• Client feedback and ongoing communication: We gather information when you provide feedback, take part in surveys, or otherwise communicate with us to help assess your experience, improve our services, and develop future offerings.
• Service delivery: When you enter into an agreement to provide services to Technology Empire, we collect the information required to manage and fulfil that relationship.
• Referrals: We may also receive your details through referrals. For example, existing clients or partners who have used our services may recommend your organisation and share information necessary for us to make contact, always ensuring such referrals comply with data protection requirements.
• Social media interactions: When you engage with us on platforms such as LinkedIn, Facebook, or Instagram—for example by commenting, messaging, or following our pages.

Information we collect from you

The information we collect depends on how you interact with us, the services you use, and the permissions you provide. We may collect the following categories of information:

Information we may collect	Examples of personal data and Special category of personal information
Basic personal details for account administration	Identity Data: Name and surname, title, date of birth Contact Data: Address, email address, telephone number Service Data: Project specific requirements Communications data: Records of correspondences with us
Payment processing	Financial Data: banking details, billing information
Existing Customer Marketing	Your preference for receiving marketing communications
Information from your device	Technical Data: IP address, browser type and version, operating system, device information Usage Data: Website navigation patterns, page response times, download errors, visit duration Cookie Data: See our Cookie Policy at
Information from Third Parties	Business Partners: Project referrals and specifications Payment Providers: Transaction confirmation and fraud prevention data Credit Reference Agencies: Credit worthiness information (where applicable)

How we use your information

We may use your personal data for the following purposes:

Purpose of processing	Legal Basis for Processing
To respond to enquiries and provide information about our services	Legitimate interests – to communicate with potential clients and address requests
To deliver, manage, and support the services you have requested	Performance of a contract – necessary to fulfil our agreement with you
To set up and manage client accounts, systems, integrations, and project environments	Performance of a contract
To process payments, issue invoices, and maintain financial records	Performance of a contract and legal obligation (e.g., accounting and tax requirements)
To maintain records of prospective, current and past clients and our suppliers	Legitimate Interests, which we have balanced with the interests of our clients, suppliers and business contacts
To contact you to ask if you are interested in our Services	Legitimate Interests
To personalise your experience and tailor service recommendations	Legitimate interests – to provide relevant content and improve engagement
To gather feedback, run surveys, and analyse service performance	Legitimate interests – to improve and develop our services
To communicate service updates, newsletters, or marketing content	Your Consent
To protect against fraud, misuse, or security threats	Legitimate interests – ensuring the safety and integrity of our systems
To comply with legal, regulatory, or law-enforcement obligations	Legal Obligation

Who we may share your information with

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Empire Group | Technology Empire Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• We may have to share your information to law enforcement agencies, regulatory bodies and/or courts and tribunals

Profiling and automated decision making

Currently, we do not use automated decision-making or profiling that produces legal or similarly significant effects.

Marketing

We may use your personal information to send you marketing communications about our services if you have opted-in and given us your consent to receive marketing communication, including:

• New service offerings and capabilities
• Special promotions and discounts
• Industry insights
• Invitations to events and webinars
• Customer newsletters and updates

We have ensured an easy method of managing your marketing preferences whereby you can unsubscribe by using the unsubscribe option in every email or mange your preferences through your online account.

If you have any questions, please contact Data Protection Officer

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

Transferring information about you overseas

We store your personal data on our secure servers located in the United Kingdom.

Some of our staff or suppliers who work outside the European Economic Area (EEA) may need to access your personal data to:

• Provide software development or other technical services in line with your requirements

We are committed to keeping your personal data safe and therefore we have conducted the appropriate risk assessments and implemented the appropriate safeguards and transfer mechanisms such as the International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs) are in place where the country does not have the Adequacy status. All international processors are contractually bound to equivalent data protection standards. We have taken all reasonable security and organisational measures to ensure your personal data is kept safe and secure.

How we keep your information secure

We take the security of your personal information seriously and use a combination of technical and organisational measures to protect it against unauthorised access, accidental loss, alteration, or misuse. These measures are designed to ensure an appropriate level of security, taking into account the nature of the data we process and the risks involved.

Our security practices include, where appropriate:

• Secure network infrastructure with firewall and encrypted data storage
• Strict access controls, ensuring only authorised personnel can access personal information
• Regular security monitoring, vulnerability assessments, and system updates
• Use of industry-standard encryption for data transmission
• Staff training on data protection responsibilities and secure handling practices

How long we keep information about you

We’ll hold the information on our system for as long as is necessary for the relevant activity, or as long as is needed to meet our contractual, legal and accounting obligations. For further information, kindly contact our Data Protection Officer regarding our Retention Policy.

Keeping information up to date

We rely on you to keep your personal information accurate and up to date so we can provide you with the best possible service, ensure we can contact you, when necessary, process payments correctly, and comply with our legal and regulatory obligations.

Please notify us promptly of any changes to your contact details including postal address, email address, and telephone numbers, your business information such as company name, registration details, or key personnel changes, your service requirements including language pairs, specialisation areas, or accessibility needs, and your communication preferences for how and when you’d like us to contact you.

Your data subject rights

You have the following rights regarding your personal data we process:

Right	Description
Right to access	You can request copies of your personal data and information about how we process it.
Right to Rectification	You can request correction of inaccurate or incomplete personal data to ensure we have the correct information.
Right to Erasure	If you want to be forgotten, you can request we delete your personal data. This applies to information we hold about you we no longer need, or you have decided to withdraw consent (where consent is the lawful basis).
Right to Restrict Processing	You can ask us to stop using information you’ve queried while we deal with your query.
Right to Data Portability	You have the right to request a copy of the information you’ve given to a company under a contract or with your explicit consent. The copy must be provided to you in a structured, commonly used and machine-readable format.
Right to object	You may want to ask us to stop using your information, including direct marketing. Please note that in some circumstances this right does not apply, for example where we have a legal obligation to do so.
Right to Complain	Lodge a complaint with the relevant supervisory authority if they believe their personal data has been processed unlawfully or their data protection rights have been violated.

If you’d like to put any of your rights into effect, please contact the Data Protection Officer at gdpr@empire-groupuk.com. We will respond within one calendar month of receiving your request.

The requests are free; however, we may charge reasonable fees for manifestly unfounded or excessive requests.

We may also request proof of identity before processing your request.

Right to complain

Under the new Data (Use and Access) Act 2025, you have the statutory right to raise concerns about how we handle your personal data. We are committed to resolving any issues promptly and fairly.

You must first raise your concern with us directly before contacting the Information Commissioner’s Office (ICO). This is a legal requirement under the Act and allows us to address your specific needs more effectively and often leads to faster resolution.

Start by contacting us directly at gdpr@empire-groupuk.com with “Privacy Complaint” in the subject line. Please include the nature of your concern, what outcome you’re seeking, and any relevant dates or reference numbers to help us understand and address your issue quickly. We shall acknowledge your complaint within 30 days as prescribed by law and respond to it without undue delay.

If you’re not satisfied with our initial response, we’ll escalate your complaint to our senior management team who will provide a formal written response within the permitted timeframe, including a clear explanation of our position and any remedial actions we plan to take.

For complex disputes that remain unresolved, we can arrange independent third-party mediation, a review by our Data Protection Officer, or involve relevant professional bodies where applicable to ensure your concerns receive impartial consideration.

Only after exhausting our internal compliant process, you may contact the ICO (if you remain dissatisfied with our response or believe your data protection rights have been violated).

ICO Contact Details:

• Website:org.uk
• Telephone: 0303 123 1113
• Live chat: Submit complaints through the live chat option given on ICO website
• Online: Submit complaints through the ICO website
• Post: I Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Children’s Privacy

Our services are not directed to individuals under 16. We do not knowingly collect personal data from children under 16 without parental consent. If we become aware of such collection, we will delete the data immediately.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to gdpr@empire-groupuk.com.