Privacy Notice

Who We Are

Operandi Group is a trading name of The Spindle Group Ltd. We are the controller of the personal data described in this notice. That means we decide how it is used and we are responsible for it.

How To Contact Us

Email hello@operandigroup.com about anything in this notice. This includes asking what we hold about you, asking us to stop contacting you, or asking us to delete your details.

You can also write to us at the registered office above. We have not appointed a data protection officer, because the law does not require one for a business of our size and type.

The Short Version

• We email businesses we think we can help. We only use business contact details.
• We find those details in public places: Companies House, company websites and business directories.
• We do not use tracking pixels in our emails and we do not set cookies on this website.
• You can tell us to stop at any time. Reply "no" to any email, or write to hello@operandigroup.com. We will stop.

What Data We Hold On Business Contacts

If we have contacted you, or might contact you, about our services, we may hold:

• Your name and job title.
• Your business email address, and sometimes a business phone number.
• The name, number, address and website of the company you work for, and public facts about it such as its size and sector.
• A record of the emails we have sent you and any replies, including whether you asked us not to contact you again.
• Notes from any call or meeting you choose to have with us.

We do not collect sensitive data, such as health or political views. We do not buy data about you as a private individual.

Where We Got It

We did not get your details from you. We found them in public business sources:

• Companies House, for company details and the names of directors.
• Company websites, including your employer's own site.
• Public business directories and business data providers that compile public company information.

We only contact limited companies and limited liability partnerships. We do not send marketing emails to sole traders or ordinary partnerships without their consent.

Why We Use It

• To contact businesses by email about our operations and AI services.
• To reply to you, and to arrange and hold a call if you ask for one.
• To keep a record of who has asked us not to contact them, so that we never do.
• To run and protect our email systems and this website.
• If you become a client, to deliver our services and keep business records.

Our Lawful Basis

We rely on legitimate interests. Our interest is telling businesses about services that could help them, and growing our company. UK data protection law recognises direct marketing as a legitimate interest.

We have weighed that interest against your rights and written the result down. We only use business details, we only contact people in their work role about something relevant to their business, we keep the volume low, and every email lets you opt out. You can ask us for a copy of that assessment.

Where we keep your details on our do-not-contact list, the basis is our legal obligation to respect your objection.

If you become a client, we also rely on the contract between us and on our legal obligations, for example to keep accounting records.

You do not have to give us any data. We do not make decisions about you by automated means alone.

How Long We Keep It

• Prospects: if you do not engage with us, we delete your details 12 months after we last contacted you.
• Conversations: if you reply or talk to us, we keep the record while the conversation is live, then for up to 12 months after it ends.
• Opt-outs: if you ask us not to contact you, we keep your email address or company domain, the date and where we found it on a suppression list, with no end date. We hold nothing else. We keep it only so we can honour your request.
• Clients: we keep contract and financial records for as long as the law requires, usually six years.

Who We Share It With

We do not sell your data. We share it only with service providers who handle it for us, under contract and on our instructions:

We may also share data with our professional advisers, or where the law requires it.

Transfers Outside The UK

Some of our providers store or access data outside the UK, including in the United States. When that happens, we make sure the data is protected by a lawful safeguard. That means the country is covered by UK adequacy regulations, or the transfer uses the ICO's International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses. Email us for more detail.

Visiting This Website

This website sets no cookies and runs no analytics. Our hosting provider records basic technical data, such as your IP address and browser type, to deliver the page and keep it secure. The page loads fonts from Google Fonts, so Google receives your IP address when you visit. If you email us from the site, we use your message only to reply.

Your Rights

You have these rights over your personal data:

• To object to direct marketing, at any time. This right is absolute. Reply "no" to any of our emails, or write to hello@operandigroup.com, and we will stop. We act on it the same working day.
• To object to any other use based on our legitimate interests.
• To be told what we hold, and to get a copy.
• To have wrong details corrected.
• To have your details deleted. We will still keep the minimum on our suppression list, so we never contact you again.
• To ask us to limit how we use your details.
• To data portability, where it applies.

We answer every request within one month. It is free.

How To Complain

If you are unhappy with how we have used your data, please tell us first at hello@operandigroup.com and we will try to put it right.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator, at any time. Visit ico.org.uk/make-a-complaint or call 0303 123 1113.

Changes To This Notice

We will update this notice when the way we use data changes. The date at the top shows when it last changed.