Privacy Policy

This privacy policy explains how Supa Technology Holdings Ltd ‘Supa’ collects and uses your personal data when you use our website. This includes data you provide through the website for example when you request a proposal or contact us.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Supa is the controller and responsible for your personal data (collectively referred to as Supa, "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

1. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Contact Data includes information that allows us to communicate with you, such as your name, email address, telephone number and postal address.
• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

2. How is your personal data collected?

We collect personal data about you through the following methods:

Direct interactions

You may give us your personal data by requesting a proposal through our website or by corresponding with us by email or phone. This includes data you provide when you:

• subscribe to marketing communications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• give us feedback or contact us through the website.

Automated technologies

As you interact with our website, we automatically collect Technical Data about your device, browsing actions and usage patterns. We collect this data using cookies, server logs and similar technologies. Please see section 5 of this document  for further details.

Third-party sources

We may receive Technical Data about you from:

• analytics providers (e.g., Google Analytics);
• website hosting and IT providers who support our website;
• advertising networks and search information providers where you have consented to marketing cookies.

Marketing partners

Where you have consented to receive marketing, we may share your Identity and Contact Data with third‑party providers who offer similar products or services that we believe may be of interest to you.

3. How we use your personal data

We only collect and use Contact and Identity Data through this website and for marketing where you have consented. We rely on the following legal bases:

• Legitimate interests — to operate and secure our website, understand how visitors use it, and improve user experience. We balance these interests against your rights before processing any data in this way.
• Consent — where you actively agree to receive marketing communications (for example, by subscribing to our newsletter or accepting marketing cookies). You can withdraw your consent at any time.
• Legal obligation — where we are required to process certain data to comply with applicable law (for example, security or fraud‑prevention requirements relating to website operation).

Purpose	Data type	Legal basis	Legitimate interest (if applicable)
To operate and maintain our website	Technical Data	Legitimate interests	Running an efficient, secure website
To analyse website usage and improve performance	Technical Data	Legitimate interests	Understanding how visitors use our site
To send marketing communications where you have opted in	Identity and Contact Data	Consent	N/A
To manage newsletter subscriptions and marketing preferences	Identity and Contact Data	Consent	N/A
To respond to website enquiries or feedback	Identity and Contact Data	Legitimate interests	Providing a responsive user experience
To ensure website security and prevent misuse	Technical Data	Legal Obligation/ Legitimate Interests	Protecting our systems and users

4. Direct marketing

You will receive marketing communications from us only where you have actively opted in (for example, by subscribing to our newsletter or accepting marketing cookies). We may use your Identity, Contact, Technical and Usage Data to understand how you use our website and to send marketing that is relevant to you. You can withdraw your consent at any time.

We may share your Identity and Contact Data with third parties so they can send you direct marketing about products or services similar to ours and which we believe may be of interest to you.

Opting out of marketing

You can withdraw your consent and stop receiving marketing communications at any time by using the opt‑out link in any marketing message or by contacting us at [email protected]

If you opt out of marketing, we may still send you non‑marketing communications that relate to the operation and security of our website (for example, account notifications or essential service messages). These are necessary to maintain your website account and ensure the site functions correctly.

5. Cookies

Cookies are small text files that a website places on your device when you visit it. We use a small number of cookies that are strictly necessary for our website to work securely and reliably.

We do not use analytics, advertising, social media or other tracking cookies. We do not use cookies to build a profile of you, to measure how you move around our website, or to track you across other websites.

Because every cookie we use is strictly necessary to provide the service you have requested, we do not need your consent to set them, and you will not see a cookie banner on our website. The cookies we use are:

Cookie	Set by	What it does	How long it lasts
__cf_bm	Cloudflare, Inc.	Distinguishes human visitors from automated traffic so that we can protect the website from bots and malicious activity. It does not correspond to any user ID, and is not used to track you between websites or between visits.	30 minutes from your last activity
__dpl	Vercel Inc. (our hosting provider)	Records which published version of our website you are viewing, so that pages and files stay consistent while you browse - including if we publish an update mid-visit.	Duration of browsing session
session-id	Vercel Inc. (our hosting provider)	Maintains continuity of your visit so that the website and the enquiry form function correctly.	Duration of browsing session

You can block or delete cookies through your browser settings, and most browsers let you refuse cookies altogether. Because the cookies listed above are necessary for our website to operate, blocking them may mean that parts of the website do not work properly.

We also collect Technical Data through our server logs and through the hosting and security services described above. Paragraph 2 explains how that data is collected and the table at paragraph 3 explains how we use it.

If we introduce analytics, advertising or any other non-essential cookies in future, we will ask for your consent before setting them, give you a straightforward way to refuse or withdraw that consent, and update this policy.

6. Disclosures of your personal data

We only share personal data collected through this website or for marketing where it is necessary for those purposes or where you have consented. This may include sharing data with:

• website hosting providers who operate and maintain our website;
• analytics providers (e.g., Google Analytics) to help us understand website usage;
• IT and security providers who support website functionality and security;
• email and marketing platforms used to send newsletters or marketing communications where you have opted in;
• third‑party marketing partners where you have consented to receive marketing about similar products or services.

If we sell, transfer or merge part of our business, the new owners may use your personal data in the same way.

We require all third parties to protect your personal data and process it only for the purposes we specify and in accordance with our instructions.

7. International transfers

We may transfer personal data collected through this website or for marketing purposes outside the UK. This may happen where our website hosting, analytics, email delivery or marketing‑technology providers are located overseas or store data in other jurisdictions.

Whenever we transfer your personal data outside the UK to a country that does not have an adequacy decision, we ensure that appropriate safeguards are in place. These may include:

• Use of the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, which provide contractual protections for your personal data;
• Technical and organisational measures, such as encryption, access controls and secure data‑handling practices.

If you would like further information about the safeguards we use for international transfers, please contact us using the details set out in paragraph 10.

8. Data security

We have put in place appropriate technical and organisational measures to protect personal data collected through this website and to prevent it from being lost, used, accessed, altered or disclosed in an unauthorised way. Access to your personal data is limited to those who need it for website operation or marketing, and they are required to keep it confidential.

We also have procedures in place to respond to any suspected personal data breach. Where legally required, we will notify you and the relevant regulator.

9. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal and regulatory or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please use the Contact details below (paragraph 10).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: [email protected]
• Postal address: Supa Technology Holdings Ltd

Third Floor,
141 Moorgate, London
EC2M 6TX

12. Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.

13. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 17 August 2026.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

14. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.