FROM SHADOW TO LIGHT PRIVACY POLICY

1. INTRODUCTION AND GENERAL TERMS

This Privacy Policy outlines the processing of personal data by From Shadow To Light (“From Shadow To Light,” “we,” “us,” or “our”) when providing services to our clients.

At From Shadow To Light, we are committed to safeguarding your privacy and protecting your personal information. This Privacy Policy explains the basis on which any personal data we collect from you, or from publicly available sources, will be processed. When we determine the purposes and means of processing your personal data, we act as the “data controller.”

We adhere to all applicable data protection laws, including the General Data Protection Regulation (GDPR) 2016/679. You also have the right to object to the processing of your personal data for direct marketing purposes. For further details on how to exercise this right, please refer to Paragraph  below.

This Privacy Policy explains the following:

– What personal data we may collect about you;

– Why our processing is lawful;

– Who we may share your information with;

– How we will use that information;

– Who we may disclose that information to; and

– Your rights regarding the information.

2. WHAT INFORMATION WILL From Shadow To Light COLLECT ABOUT ME?

We collect and process the following types of data, which may include personal data:

From Shadow To Light Website: When you contact us regarding our services, any forms you fill out or emails you send may include personal information, such as your full name, email address, the organization you represent, and the nature of your inquiry.

From Shadow To Light Database: We collect both current and historical business contact data. The information we gather about individuals in our database includes:

– Name;

– Employer Company & Company Details;

– Office Location (Country & City);

– Business Telephone Number;

– Business Email Address;

– Job Title.

We also retain data related to your employer, including its name, alias, size, industry, website, and sector. In certain cases, we may estimate an individual’s net worth based on publicly available information, such as employment history or past sales of company shares. If you have changed jobs, we may retain information about your previous employers and job titles.

To provide certain services, From Shadow To Light requires a business email address to be associated with profiles in our database. If we do not possess this information, we may generate a business email address using the structure commonly used by the employer company.

We also hold hashed personal email addresses. Hashing is an encryption method that replaces the original email address with a unique reference known as a hash. This hash can be used to locate the same individual across social networks. We do not reverse the hash, nor do we use personal email addresses to contact you.

The majority of personal data we collect comes from publicly available sources, including business and employment-oriented social networks, recruitment websites, and company websites.

We may also collect information through correspondence with you (via email or phone), from our clients, affiliates, recruiters, and premium data providers. From Shadow To Light does not intentionally collect non-business-related data, such as date of birth, home address, personal email, telephone numbers, or sensitive personal data.

When clients use our services to send marketing emails, these emails may contain cookies or similar technologies to track whether the email was delivered, opened, or whether links were clicked.

3. GROUNDS OF PROCESSING

1. Consent

In certain instances, From Shadow To Light processes your personal data based on your consent. This consent may be obtained directly from you or through third parties acting on our behalf. You have the right to withdraw your consent at any time, and we will stop processing your data once consent is withdrawn.

2. Legitimate Interest

We process your personal data when it is necessary for our or our clients' legitimate interests, provided these interests are not overridden by your rights. Examples of legitimate interests include:

• Maintaining an organized, searchable database of potential business customers.
• Accessing up-to-date, accurate information to identify individuals in specific business roles.
• Identifying individuals with a certain estimated net worth.
• Assisting clients in targeting relevant contacts for B2B marketing.
• Generating and contacting potential B2B leads.
• Gaining statistical insights to understand patterns and trends in the business landscape.

3. Legal Obligation

From Shadow To Light may also process your data to comply with legal and regulatory requirements. This includes activities such as preventing, investigating, and detecting crime or fraud, and cooperating with law enforcement authorities as necessary.

4. Contractual Obligation

We may process your personal data where necessary to fulfill our contractual obligations. This applies when we have a contract with you, and processing your data is essential to meet our commitments under that agreement.

4. DATA SHARING

Sharing Your Information

We may share your personal data with the following parties:

1. Our Group of Companies

Access to personal data within From Shadow To Light and its affiliated companies is restricted to individuals who require it for legitimate business purposes.

2. From Shadow To Light Clients

We may share personal data with our clients as part of our services. From Shadow To Light provides limited access to its database, allowing clients to use the data to contact individuals via business telephone, business email, other electronic communication, or targeted display ads on social networks for marketing purposes.

Please note that when we provide this data to clients, From Shadow To Light acts as a data processor on behalf of the client, who serves as the data controller. Clients may have their own privacy policies and opt-out mechanisms, and we recommend reviewing them. When clients use personal data provided by us, their privacy policies should reference From Shadow To Light as a data source.

3. Suppliers, Subcontractors, and Service Providers

While we maintain the confidentiality of your information, we may disclose it to suppliers, subcontractors, or service providers as reasonably necessary for the purposes outlined in this privacy policy. This is done on the condition that these third parties have committed to safeguarding your information.

This includes external service providers such as accountants, auditors, legal advisors, IT systems and hosting providers, technical engineers, cloud storage vendors, and other third-party professionals who assist us in our business operations.

4. Government Authorities

We may disclose your personal information if required by law, which could include sharing data with government bodies or law enforcement agencies. This may occur in connection with legal proceedings, or when necessary to establish, exercise, or defend our legal rights. This can also involve providing information to third parties for fraud prevention purposes.

5. Potential Acquirers or Investors

In the event of a merger, acquisition, or sale of all or part of our assets, we may disclose your information to potential acquirers or investors. Should such a transaction occur, we will notify you by email, account message, or via a prominent notice on our website about any changes in ownership or the use of your personal information, as well as your options regarding the handling of that information.

5. HOW WE WILL USE INFORMATION WE COLLECT ABOUT YOU

From Shadow To Light Website and Client Platform
We may process your personal data for the following purposes, relating to From Shadow To Light's own operations:

• To manage platform log-ins (where applicable) and deliver our services to clients in accordance with agreed terms of service.
• To process your inquiries and provide support, including supplying you or your organization with information about the services From Shadow To Light offers.
• To keep you informed via our mailing list about news, offers, and updates related to From Shadow To Light (you can find details on how to unsubscribe below).
• To generate reports on how visitors use the From Shadow To Light website and to improve the website’s functionality.
• To conduct remarketing activities, allowing us to display From Shadow To Light ads to individuals who have previously visited our website.
• To advertise on social media platforms, which means that if you interact with our social media channels, you may see targeted From Shadow To Light ads on those platforms.

We collaborate with third-party advertising networks and social media platforms as detailed in our cookie policy, which you can find [here]. For further details on how these third parties collect and process your information, we recommend reviewing their respective privacy policies.

From Shadow To Light Database
We may use your personal data within the From Shadow To Light Database for the following purposes:

• To build our sales intelligence database, helping our clients generate and manage sales leads related to businesses and high-net-worth individuals.
• To enable our clients to display relevant ads on social networks (such as Facebook, LinkedIn, and Instagram) and other digital platforms.
• To help our clients enrich their existing customer relationship management (CRM) records and receive timely updates about any changes.
• To conduct research and compile aggregated statistical reports based on data within From Shadow To Light's sales intelligence database.
• To supply data to data management platforms.
• To run our own marketing campaigns and promote our services.

We also process personal data to comply with our legal and regulatory obligations. This includes preventing, investigating, and detecting crime, fraud, or anti-social behavior, as well as prosecuting offenders, which may involve working with law enforcement agencies.

Objectionable Content:
If you send objectionable content or behave disruptively while using our website, we may process the personal data contained in your messages to address and prevent such behavior. If we reasonably believe you are or may be in breach of the law (e.g., harassment or defamatory content), we may use your personal data to notify relevant third parties, such as your email or internet service provider, or law enforcement agencies.

Marketing Communications:
If you receive a marketing email from us and wish to be removed from our mailing list, please click the "unsubscribe" link at the bottom of any such email.

YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights concerning the way we process your personal data. We strive to fulfill your requests without undue delay and no later than one month from the date of the request.

To make a request, please contact us at mercedes@fromshadowtolight.co.uk.

• You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.
• We will make reasonable efforts, as required by law, to provide, correct, or delete personal data held about you in our records and with any third parties to whom the data has been disclosed.

6. OBJECT TO US PROCESSING DATA ABOUT YOU

You have the right to ask us to restrict, stop processing, or delete your personal data under the following circumstances:

• You initially consented to From Shadow To Light processing your personal data but have since withdrawn that consent.
• From Shadow To Light no longer needs to process the personal data for the purpose for which it was originally collected.
• From Shadow To Light is processing your personal data based on public interest or a legitimate interest, and you disagree with this processing, with no overriding legitimate reason for us to continue.
• The personal data was processed unlawfully.
• You need the personal data to be deleted in order to comply with a legal obligation

7. DATA RETENTION

We will retain your personal data only for as long as necessary to fulfill the relevant purpose.

When determining the appropriate retention period for personal data, we take into account several factors, including the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, whether those purposes can be achieved through other means, and applicable legal requirements.

8. CHILDREN

We do not collect data from or market to individuals under the age of 18. If a parent or guardian becomes aware that their child has provided us with personal information without consent, they should contact us at mercedes@fromshadowtolight.co.uk. We will delete the information from our records within one hour.

9. SECURITY

From Shadow To Light is committed to ensuring your personal data is safe and secure from unauthorized access, alterations, disclosure, or destruction. We take all reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal data.

Our security measures include:

• Hashing and encryption of our services and data.
• Regular review of information collection practices.
• Encryption of our services and data.
• Restricted access to data for employees, contractors, and agents.
• Internal policies outlining our data security practices.

Please note that while we strive to provide robust security measures for the data we process and maintain, no security system can guarantee complete protection against all potential breaches.

10. CHANGES

We will inform you of any changes to this Privacy Policy via email and/or by posting a notice on our website, as appropriate.

11. INTERNATIONAL DATA TRANSFERS

The personal data you provide to us is generally stored within the European Economic Area (EEA). However, due to the global nature of our business and the technologies we use, your personal data may be transferred to third-party service providers located outside the EEA, in countries where data protection laws may be less stringent.

When we transfer your data outside the EEA, we ensure that only the minimum necessary data is shared, anonymize it where possible, and have agreements in place that include standard data protection clauses. These agreements are designed to ensure appropriate safeguards are in place to protect your personal data in line with this Privacy Policy and European data protection standards. If you would like more information about these safeguards, please contact us.