1. Introduction

IKWA Ltd ("IKWA", "we", "us" or "our") is committed to protecting your privacy and handling your personal information responsibly.

This Privacy Notice explains how we collect, use, store and protect personal information when you visit our website, contact us, enquire about our products and services, participate in our Early Adopter Programme or engage with us as a customer, prospective customer or business partner.

It also explains your rights under applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We aim to be transparent about how we use your information and to ensure that any personal information we process is handled securely, fairly and lawfully.

2. Who We Are

IKWA Ltd is a UK-based technology company specialising in the design, development and delivery of applications built on the ServiceNow platform.

For the purposes of applicable data protection legislation, IKWA Ltd is the data controller for the personal information collected and used in connection with our website, business operations, marketing and customer relationships, except where we act in another capacity, such as a data processor.

• Company name: IKWA Ltd
• Website: https://ikwa.co.uk
• Registered address: The Racquets Court, College Street, Newcastle Upon Tyne, England, NE1 8JG
• Company registration number: 11069478
• Privacy contact: SupportTeam@Ikwa.cloud

If you have any questions about this Privacy Notice or how we handle your personal information, you can contact us using the details above.

3. Information We Collect

We may collect and process the following categories of personal information, depending on how you interact with IKWA.

Information you provide directly

When you submit a form, contact us or engage with our services, we may collect:

• Your name and job title.
• Your organisation and business contact details.
• Your business email address and telephone number.
• Information about your organisation's use of ServiceNow.
• Details of the products, applications or services you are interested in.
• Information submitted through our Book a Demo, Early Adopter Programme or general enquiry forms.
• Any additional information you choose to provide when communicating with us.

Business and professional information

We may collect relevant professional information about individuals representing organisations we work with or may wish to work with, including:

• Your organisation and professional role.
• Publicly available professional information.
• Business contact details published on professional networking platforms, such as LinkedIn.
• Information relating to previous business interactions, enquiries or discussions with IKWA.

Information collected automatically

When you visit our website, we may collect certain technical and usage information, including:

• Your IP address.
• Browser type and version.
• Device type and operating system.
• Pages visited and interactions with our website.
• The date, time and duration of visits.
• Referring websites and general website navigation information.
• Information collected through cookies and analytics technologies, where permitted.

We use Microsoft Clarity to help us understand how visitors interact with our website and to identify opportunities to improve its usability and performance.

Information relating to customers and applications

Where you use an IKWA application or service, personal information may be processed as part of delivering that application or service.

The type of information processed will depend on the application, its configuration and the organisation using it. This may include information relating to employees, students, suppliers, service requests, interactions, submissions or other operational activities.

Where IKWA processes personal information on behalf of a customer, the customer will generally determine the purposes and means of processing and IKWA will act as a data processor under the relevant contractual arrangements. In other circumstances, IKWA may act as a data controller for its own purposes.

Further information about the processing of personal information within a specific IKWA application may be provided by the relevant customer through its own privacy notices and associated documentation.

4. How We Use Your Information

We use personal information for legitimate business purposes and to provide, improve and promote our products and services.

These purposes include:

Responding to enquiries

We use your information to:

• Respond to enquiries submitted through our website or other communication channels.
• Arrange product demonstrations and meetings.
• Provide information about our applications and services.
• Understand your organisation's requirements.
• Follow up on discussions about potential projects or opportunities.

Managing the Early Adopter Programme

Where you register your interest in or participate in our Early Adopter Programme, we may use your information to:

• Process and manage your registration.
• Communicate with you about the programme.
• Provide information about relevant applications and developments.
• Arrange demonstrations, evaluations and feedback sessions.
• Manage your participation and related business communications.

Managing customer and business relationships

We may use your information to:

• Establish and maintain customer and supplier relationships.
• Deliver contracted products and services.
• Provide customer support and respond to service-related queries.
• Manage projects, commercial arrangements and ongoing communications.
• Maintain records of business interactions.

Marketing and business development

We may use relevant professional contact information to:

• Introduce IKWA and its products to relevant businesses.
• Communicate with professional contacts through appropriate business channels, including email and LinkedIn.
• Share information about our applications, services, events and developments.
• Send newsletters and other relevant business updates where permitted.
• Identify and develop potential business relationships.

We take account of applicable marketing and data protection requirements and provide individuals with appropriate opportunities to object to or opt out of direct marketing.

Website improvement and analytics

We use website analytics, including Microsoft Clarity, to understand how visitors interact with our website, identify usability issues, improve website content and enhance the visitor experience.

Legal and regulatory obligations

We may process personal information where necessary to:

• Comply with applicable legal or regulatory requirements.
• Establish, exercise or defend legal claims.
• Prevent, investigate or address fraud, misuse or security incidents.
• Maintain appropriate business and financial records.

5. How We Collect Information

We collect personal information through several channels, including:

• Directly from you: When you complete a website form, email us, telephone us, arrange a meeting or otherwise communicate with IKWA.
• Through business interactions: During sales discussions, demonstrations, events, projects and customer relationships.
• Professional networking platforms: Such as LinkedIn, where relevant professional information is publicly available or shared with us.
• Publicly available sources: Such as company websites and other professional or business directories, where relevant to our business activities.
• Automatically through our website: Using technical information, cookies and analytics technologies, where permitted.
• Through service providers: Where information is provided to us as part of delivering or supporting our business services.

Where we obtain personal information from sources other than the individual concerned, we will provide appropriate privacy information as required by applicable data protection law.

6. Lawful Basis for Processing

We process personal information only where we have a valid lawful basis under the UK GDPR.

Depending on the purpose, we may rely on the following lawful bases:

*Legitimate interests*

We may process professional contact information to develop business relationships, conduct relevant business-to-business marketing, improve our website, manage our operations and promote our products and services.

Where we rely on legitimate interests, we consider the necessity of the processing and balance our interests against the rights and freedoms of the individuals concerned.

Individuals have the right to object to processing based on legitimate interests, including an absolute right to object to processing for direct marketing purposes.

*Contractual necessity*

We may process personal information where it is necessary to enter into or perform a contract with you or your organisation, or to take steps at your request before entering into a contract.

This may include providing demonstrations, managing customer relationships and delivering agreed services.

*Legal obligation*

We may process personal information where necessary to comply with legal obligations, including relevant financial, tax, regulatory and record-keeping requirements.

*Consent*

Where required by law, we may rely on your consent, for example, for certain marketing communications or the use of non-essential cookies and similar technologies.

Where we rely on consent, you may withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

The lawful basis used will depend on the particular processing activity and circumstances.

7. Marketing Communications

IKWA undertakes business-to-business marketing to organisations that may benefit from our products and services.

We may use professional contact information to communicate with relevant business contacts through channels such as business email and LinkedIn.

Our marketing activities may include:

• Information about IKWA applications and services.
• Product announcements and updates.
• Invitations to events, demonstrations and webinars.
• Newsletters and other relevant business communications.

Where permitted by applicable law, we may send business-to-business marketing communications to corporate subscribers without prior consent. Different requirements apply to sole traders and certain partnerships, including rules concerning consent for unsolicited electronic marketing.

We will comply with applicable data protection and electronic marketing requirements, including the Privacy and Electronic Communications Regulations (PECR).

You can object to direct marketing or unsubscribe from marketing emails at any time by using the unsubscribe facility provided or contacting us directly.

If you opt out of marketing, we may retain limited information on a suppression list to ensure that we respect your preference and do not contact you again for the same marketing purpose.

Opting out of marketing will not prevent us from sending necessary non-marketing communications, such as information relating to an existing contract or service.

8. Sharing Your Information

We do not sell personal information to third parties.

We may share personal information with trusted third-party service providers where necessary to operate our business, deliver our services or fulfil our legal obligations.

These may include:

• HubSpot: For customer relationship management, prospect management and business communications.
• Microsoft 365: For business email, document management, collaboration and related business operations.
• Microsoft Clarity: For website analytics and understanding visitor interactions.
• ServiceNow: In connection with the development, operation, support and delivery of IKWA applications.
• Email marketing providers: To support the delivery and management of marketing communications and newsletters.
• Website hosting and technical providers: To host, maintain, secure and support our website and associated systems.
• Professional advisers: Such as legal, financial and accounting advisers, where necessary.
• Regulatory or public authorities: Where we are legally required to disclose information or where disclosure is necessary to protect our legal rights.

Where third parties process personal information on our behalf, we take appropriate steps to ensure that suitable contractual and security arrangements are in place.

We may also disclose information in connection with a business sale, merger, restructuring or similar transaction, where legally permitted and subject to appropriate safeguards.

9. International Data Transfers

IKWA's website is hosted in the United Kingdom. However, some of the third-party services we use may process or access personal information from outside the UK.

Where personal information is transferred internationally, we will ensure that the transfer is carried out in accordance with applicable data protection legislation.

Depending on the circumstances, this may involve:

• Transfers to countries recognised by the UK as providing an adequate level of data protection.
• Appropriate safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.
• Other lawful transfer mechanisms where permitted by applicable law.

Where required, we will take appropriate steps to assess the protection available for personal information transferred internationally.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including satisfying legal, regulatory, accounting or reporting requirements.

Retention periods may vary depending on the type of information and the nature of our relationship with you.

For example:

• Business enquiries and prospective customers: We may retain information while there is an ongoing or reasonably anticipated commercial relationship or opportunity.
• Early Adopter Programme participants: We may retain information for the duration of participation and for a reasonable period afterwards to manage follow-up activities and related business relationships.
• Customer and contractual records: We may retain information for the duration of the relationship and for any additional period necessary to meet legal obligations or resolve disputes.
• Marketing records: We may retain relevant contact information while it remains appropriate to our business development activities or until an individual objects or unsubscribes, subject to any necessary suppression records.
• Website analytics: Information is retained in accordance with the relevant analytics configuration and provider retention settings.

We periodically review the personal information we hold and take steps to delete or anonymise information when it is no longer required.

11. Cookies and Website Analytics

Our website may use cookies and similar technologies to support website functionality, understand visitor behaviour and improve the overall user experience.

We use Microsoft Clarity to analyse how visitors interact with our website. Depending on the configuration, this may include information about clicks, scrolling, navigation and interactions with website content.

Some analytics technologies may collect technical identifiers and interaction data that could constitute personal information.

Where required, we will obtain your consent before using non-essential cookies or similar technologies. You can manage your cookie preferences through the cookie settings provided on our website, where available.

You can also manage cookies through your browser settings. However, disabling certain cookies may affect website functionality.

Further information about the cookies used on our website, their purposes and how to manage your preferences should be provided through our cookie notice or cookie settings.

12. Data Security

We take appropriate technical and organisational measures to protect personal information against unauthorised access, accidental loss, destruction, alteration or disclosure.

These measures may include:

• Access controls and appropriate user permissions.
• Secure systems and communication methods.
• Use of reputable technology and service providers.
• Appropriate security practices for the systems we operate.
• Measures designed to identify and respond to potential security incidents.

Access to personal information is restricted to individuals and service providers who require it for legitimate business purposes.

Although we take reasonable steps to protect personal information, no method of transmission or storage can be guaranteed to be completely secure.

13. Your Data Protection Rights

Under applicable data protection legislation, you may have the following rights in relation to your personal information:

*Right of access*

You can request a copy of the personal information we hold about you.

*Right to rectification*

You can request that inaccurate or incomplete personal information is corrected.

*Right to erasure*

You can request that your personal information is deleted in certain circumstances.

*Right to restrict processing*

You can request that we restrict the processing of your personal information in certain circumstances.

*Right to data portability*

You can request a copy of certain personal information in a structured, commonly used and machine-readable format, where the right applies.

*Right to object*

You can object to certain types of processing, including processing based on legitimate interests. You have an absolute right to object to the use of your personal information for direct marketing.

*Rights relating to automated decision-making*

You may have rights in relation to decisions made solely by automated means that produce legal or similarly significant effects, where applicable.

Where we rely on consent, you also have the right to withdraw that consent at any time.

To exercise your rights, please contact us using the contact details provided in this Privacy Notice. We may need to verify your identity before responding.

We will respond within the timeframe required by applicable data protection legislation.

14. Third-Party Websites

Our website may contain links to third-party websites, platforms or services, including the ServiceNow Store and professional networking platforms such as LinkedIn.

These websites operate independently of IKWA and may have their own privacy notices, terms and data collection practices.

We are not responsible for the privacy practices or content of third-party websites. We recommend reviewing their privacy notices before providing personal information.

15. Children's Privacy

The IKWA website is intended primarily for business users, organisations and professional contacts.

We do not knowingly collect personal information directly from children through our website for marketing or business development purposes.

Some IKWA applications may be used by educational institutions and may process information relating to students, including individuals under the age of 18. In such circumstances, the processing of personal information will be governed by the relevant contractual arrangements, applicable data protection requirements and the privacy information provided by the institution responsible for the data.

16. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our business activities, technology, legal obligations or data protection practices.

Any updated version will be published on our website, with the revised date shown at the beginning of the notice.

We encourage visitors and business contacts to review this Privacy Notice periodically to remain informed about how we handle personal information.

17. Contact and Complaints

If you have any questions, concerns or requests relating to this Privacy Notice or the way IKWA handles personal information, please contact us using the details below.

IKWA Ltd
Website:https://ikwa.co.uk
Email: SupportTeam@Ikwa.cloud
Registered address: The Racquets Court, College Street, Newcastle Upon Tyne, England, NE1 8JG

*Information Commissioner's Office (ICO)*

Website: https://ico.org.uk
Telephone: 0303 123 1113

We would appreciate the opportunity to address any concerns you may have before you contact the ICO, although you are not required to do so.