Privacy Policy

1. Who we are

This website is operated by Springboard Futures Ltd, trading as Sustained Futures, a company registered in England and Wales.

• Company number: 14802390
• Registered office: 167-169 Great Portland St, London, W1W 5PF
• ICO registration number: [Insert ICO registration number]
• Email: hello@sustainedfutures.com

For the purposes of UK GDPR and the Data Protection Act 2018, Springboard Futures Ltd is the data controller responsible for your personal data.

2. What data we collect

We may collect and process the following personal data:

Data you provide directly:

• Full name
• Work email address
• Job title
• Company name, website URL, and size
• Industry and location
• Regulatory frameworks you report against
• How you heard about us
• Free-text responses (e.g. sustainability skills challenges)

Data collected automatically:

• IP address
• Browser type and version
• Operating system
• Pages visited, time spent, and referral source
• Cookie and similar technology data (see section 8)

3. Lawful basis for processing

Under UK GDPR, we rely on the following lawful bases to process your data:

• Consent (Article 6(1)(a)): When you submit a form on our website, you consent to us processing your data for the stated purpose. You can withdraw consent at any time by emailing hello@sustainedfutures.com.
• Legitimate interests (Article 6(1)(f)): We process data to improve our services, communicate relevant information to business contacts, and ensure website security. We have assessed that these interests do not override your rights and freedoms.
• Contractual necessity (Article 6(1)(b)): Where processing is necessary to perform a contract or take pre-contractual steps at your request.

4. How we use your data

We use your personal data to:

• Process waitlist registrations and enquiries
• Generate personalised skills gap reports
• Send you information about our services, where you have consented
• Improve our website and services
• Comply with legal obligations
• Administer and protect our business and website

We will not use your data for automated decision-making or profiling that produces legal effects.

5. Who we share your data with

We may share your data with the following categories of recipients:

• HubSpot Inc. (CRM and marketing platform) - processes data on our behalf under a data processing agreement. HubSpot is certified under the EU-US Data Privacy Framework.
• Vercel Inc. (website hosting) - processes data as required to serve our website.
• Analytics providers - we may use analytics services that collect anonymised usage data.
• Professional advisers - including lawyers and accountants where necessary.
• Regulatory authorities - where required by law.

We will never sell your personal data to third parties.

6. International transfers

Some of our service providers (including HubSpot and Vercel) are based in the United States. Where we transfer data outside the UK, we ensure appropriate safeguards are in place, including:

• UK adequacy decisions
• Standard contractual clauses approved by the ICO
• EU-US / UK-US Data Privacy Framework certification

7. Data retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Enquiry and waitlist data: retained for up to 2 years from your last interaction, or until you request deletion.
• Client data: retained for the duration of the business relationship plus 6 years (for legal and accounting purposes).
• Analytics data: retained in anonymised form indefinitely.

9. Your rights

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

• Right of access: request a copy of your personal data.
• Right to rectification: request correction of inaccurate data.
• Right to erasure: request deletion of your data, subject to legal obligations.
• Right to restrict processing: request limitation of how we use your data.
• Right to data portability: receive your data in a structured, machine-readable format.
• Right to object: object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.

How to exercise your rights

Email hello@sustainedfutures.com from the email address we hold on file for you, telling us which right you want to exercise. We will respond within one calendar month, in line with UK GDPR Article 12. There is no fee for the first request.

If you email from a different address than the one we hold, we may ask for additional verification (for example, a reference number from a recent email) before we can act on the request. This is to protect your data from unauthorised access.

You can also self-serve two of these rights at any time:

• Withdraw cookie consent: use the Cookie preferences link in the website footer.
• Unsubscribe from marketing: click the unsubscribe link in any marketing email we send you.

You also have the right to lodge a complaint with the Information Commissioner's Office (the UK supervisory authority) at ico.org.uk. If you reside in the EU, you may complain to your local supervisory authority.

California residents

We do not sell or share your personal information for cross-context behavioural advertising. The rights described above are available to you in addition to any rights you have under the California Consumer Privacy Act (as amended by the CPRA).

10. Right to complain

If you are unhappy with how we have handled your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk/make-a-complaint
• Phone: 0303 123 1113

We would appreciate the opportunity to address your concern before you contact the ICO, so please reach out to us first.

11. Changes to this policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. Where changes are significant, we will make reasonable efforts to notify you.

12. Contact

For any questions about this privacy policy or how we handle your data, contact us:

• Email: hello@sustainedfutures.com
• Post: Springboard Futures Ltd, 167-169 Great Portland St, London, W1W 5PF