This privacy notice tells you what to expect us to do with your personal information.
Contact details
Email: [email protected]
Data Controller: ValenPath Systems Ltd is the data controller for the personal information described in this privacy notice. We decide what personal information we collect and how we use it, and we are responsible for ensuring that the processing complies with UK data protection law.
What information we collect, use, and why
To provide and improve products and services for clients
- Names and contact details
- Usage data (including information about how you interact with and use our website, products and services)
- Information relating to compliments or complaints
- Records of meetings and decisions
- Website user information
For information updates or marketing purposes
- Names and contact details
- Addresses
- Marketing preferences
- Website and app user journey information
- IP addresses
To comply with legal requirements
- Name
- Contact information
- Any other personal information required to comply with legal obligations
For recruitment purposes
- Contact details (eg name, address, telephone number or personal email address)
- National Insurance number
- Employment history (eg job application, employment references or secondary employment)
- Education history (eg qualifications)
- Right to work information
For dealing with queries, complaints or claims
- Names and contact details
- Purchase or service history
- Correspondance
Data protection rights
Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.
Which lawful basis we rely on may affect your data protection rights. The rights listed below are set out in brief.
- Your right of access. You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
- Your right to rectification. You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
- Your right to erasure. You have the right to ask us to delete your personal information.
- Your right to restriction of processing. You have the right to ask us to limit how we can use your personal information.
- Your right to object to processing. You have the right to object to the processing of your data.
- Your right to data portability. You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
- Your right to withdraw consent. When we use consent as our lawful basis you have the right to withdraw your consent at any time.
Read more about your data protection rights
For full details about any right listed above—including the legal basis, scope, and exemptions that may apply—please visit the Information Commissioner's Guide to Data Subject Rights.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for collecting or using personal information
To provide and improve products and services for clients
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except that if you exercise your right to object, we may not be able to stop processing if the information is required to fulfil the contract.
- Legitimate interests – we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:- ValenPath Systems Ltd processes limited personal information because it is necessary to deliver and improve the professional services our clients commission. We need this information to communicate with clients, understand their requirements, provide accurate advice, and build, test, debug and deploy the software systems they rely on. We also need to retain relevant records to ensure correct payment, demonstrate the quality of our work, and support live systems effectively. This processing is legitimate and necessary because without access to client contact details, project information and technical data, we could not carry out our services or maintain reliable systems. The impact on individuals is low: we only use information directly related to the work clients ask us to perform, we do not process special category data, and we apply safeguards such as secure systems, restricted access and appropriate retention. Clients reasonably expect us to use their information in this way, and the benefits—accurate advice, functioning systems, effective support and clear project accountability—outweigh any minimal risks involved.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
For information updates or marketing purposes
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Legitimate interests – we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:- ValenPath Systems Ltd processes limited personal information under legitimate interests so that we can contact relevant professionals within organisations and share information about services that may genuinely benefit them. This includes identifying appropriate people to speak to, introducing our work, and providing updates that help organisations understand how we can support their technology, data or software needs. The processing is necessary because without using publicly available or business provided contact details, we would not be able to reach the right individuals or communicate effectively in a professional context. The impact on people is low: we only contact individuals in their work capacity, we limit outreach to appropriate and relevant roles, and we always provide a clear option to opt out. The benefits of this processing include enabling organisations to receive useful information, explore potential improvements to their systems, and access support they may need, while ensuring our communications remain proportionate and respectful. These benefits outweigh the minimal risks involved, and our legitimate interests do not override the rights or freedoms of the individuals we contact.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
To comply with legal requirements
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
For recruitment purposes
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:- ValenPath Systems Ltd processes personal information for recruitment because it is necessary to identify suitable candidates, assess their skills and experience, and take steps before entering into a contract. This includes reviewing applications, communicating with candidates, verifying relevant information and maintaining records of the recruitment process. The processing is legitimate because we need this information to run an effective and fair selection process and to ensure we appoint people with the right capabilities for the roles we offer. The impact on individuals is low: we only use information that candidates choose to provide, we do not process special category data unless required by law, and we apply safeguards such as secure systems, restricted access and limited retention. Candidates reasonably expect us to use their information in this way, and the benefits of a transparent, well managed recruitment process outweigh any minimal risks involved. Our legitimate interests do not override the rights or freedoms of individuals, and candidates can exercise their data protection rights at any time.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
For dealing with queries, complaints or claims
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Where we get personal information from
- Directly from you
- Publicly available sources
- Third parties: We may receive personal information from third parties when it is necessary for delivering our services. This can include clients who share the contact details of colleagues involved in a project, partner organisations who introduce us to relevant team members, or individuals who provide information on behalf of someone else as part of an enquiry or collaboration. These third party sources are limited, relevant and directly connected to the services we provide.
How long we keep information
Who we share information with
Data processor: Microsoft Corporation – Cloud services provider (email, productivity, and storage), Technology sector, headquartered in the United States with EU / UK data centres.
This data processor does the following activities for us: We use Microsoft Corporation as a cloud services provider for business email (Outlook), file storage (OneDrive) and productivity tools (Microsoft 365). Microsoft processes personal information only on our behalf and only under our instructions. They host and transmit the information we store within these services, such as client contact details, correspondence and project documents, and they do so in accordance with UK data protection law. Microsoft acts solely as a data processor for ValenPath Systems Ltd.
Sharing information outside the UK
Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
Organisation name: Microsoft Corporation
Category of recipient: Cloud services provider (email, productivity, and storage) – Technology sector
Country the personal information is sent to: Most data is stored in UK or EU data centres, but limited processing may occur in the United States or other countries where Microsoft or its authorised subprocessors operate.
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
- Email: [email protected]
If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113
Website: ico.org.uk/make-a-complaint