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: info@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 info@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.

8. Cookies

Our website uses cookies and similar technologies. A cookie is a small file placed on your device that helps us provide and improve our services.

Types of cookies we use:

• Strictly necessary cookies: required for the website to function. These do not require consent.
• Analytics cookies: help us understand how visitors use our website. We will ask for your consent before placing these cookies, in line with PECR requirements.
• Marketing cookies: used to track visitors across websites for advertising purposes. We will ask for your consent before placing these cookies.

You can manage your cookie preferences at any time through your browser settings or our cookie consent tool (when implemented).

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.

To exercise any of these rights, email info@sustainedfutures.com. We will respond within one month.

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