Privacy Policy

This Privacy Policy explains how Compose Sales Partners Ltd collects, uses, and protects personal data when you visit this website or contact us through it. Please read it alongside our Terms of Use and Cookie information below.

1. Who we are

Compose Sales Partners Ltd is the data controller responsible for your personal data in connection with this website. We are a company registered in England and Wales.

For the personal data we process when delivering a client engagement, separate terms apply. That data is governed by the data processing terms in our Master Services Agreement and Data Processing Agreement with the relevant client, not by this Policy. This Policy covers personal data collected through the website only.

2. The personal data we collect

Information you give us

• Enquiry and contact details. When you complete an enquiry form or contact us, we collect the information you choose to provide, which typically includes your name, company, role, region, email address, and the details of your enquiry.

Information we collect automatically

• Usage and analytics data. When you visit the website, we may collect information about your device and how you use the site, such as your IP address, browser type, pages viewed, time spent on pages, and approximate location. This is collected through analytics tools and only where you have consented to non-essential cookies.
• Cookie data. Information collected through cookies and similar technologies, as described in the Cookies section below.

We do not knowingly collect special category data, such as health, ethnicity, or political opinions, through the website, and we ask that you do not include such information in enquiry forms. We do not collect personal data from children through this website.

3. How we use your personal data and our lawful basis

Under the UK General Data Protection Regulation (UK GDPR) we must have a lawful basis for processing your personal data. The information below sets out how and why we use your data and the lawful basis we rely on.

• To respond to your enquiry and correspond with you. Lawful basis: our legitimate interests in responding to enquiries about our services, and taking steps at your request prior to entering into a contract.
• To operate, maintain, and secure the website. Lawful basis: our legitimate interests in running a safe and functioning website.
• To understand and improve how the website is used. Lawful basis: your consent, given through the cookie banner, for analytics cookies.
• To comply with legal and regulatory obligations. Lawful basis: compliance with a legal obligation to which we are subject.
• To establish, exercise, or defend legal claims where necessary. Lawful basis: our legitimate interests in protecting the business.

Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights and freedoms, and we have concluded that our processing is proportionate and does not unduly affect you. You have the right to object to processing based on legitimate interests, as set out below.

We do not use your personal data for automated decision-making that produces legal or similarly significant effects, and we do not carry out profiling of website visitors. We do not operate a marketing mailing list and we will not add you to one from your enquiry.

4. Cookies and similar technologies

Cookies are small text files placed on your device when you visit a website. We use cookies to operate the website, and, with your consent, to understand how it is used. When you first visit the site you will be presented with a cookie banner allowing you to accept or reject non-essential cookies. You can change your preferences at any time using the cookie settings on the site.

The categories of cookies we use are:

Strictly necessary cookies do not require consent. All other cookies are set only where you have given consent. Most browsers also allow you to refuse or delete cookies through their settings. Doing so may affect how the website functions.

5. Analytics

We use Google Analytics, a web analytics service, to help us understand how visitors use the website. Google Analytics uses cookies and collects information such as pages viewed and approximate location, in an aggregated and, where possible, pseudonymised form.

This processing takes place only where you have consented to analytics cookies. Google acts as our processor for this purpose. Information about how Google processes data is available in Google's own privacy documentation.

6. Third parties, embedded content, and links

The website may include embedded content and links from third parties, including LinkedIn, Microsoft services, and email links. These third parties may set their own cookies and collect data about you when you interact with their content.

We do not control these third parties and their processing is governed by their own privacy policies, not this one. We encourage you to review the privacy policies of any third-party services you interact with.

We use the following categories of third-party service providers, who process personal data on our behalf as our processors, or in their own right where indicated:

• Website hosting and infrastructure providers, who host the website and store data on our behalf.
• Analytics providers, such as Google, as described above.
• Communication and productivity providers, such as Microsoft, through which enquiry correspondence is received and managed.
• Professional networking platforms, such as LinkedIn, where you choose to interact with our embedded or linked content.

We only share personal data with third parties where necessary for the purposes set out in this Policy, and we require our processors to protect your data and to act only on our instructions.

7. International transfers

Some of the third-party providers we use, including Google, Microsoft, and LinkedIn, are based outside the United Kingdom or may process data outside the United Kingdom and the European Economic Area.

Where personal data is transferred outside the UK, we rely on appropriate safeguards recognised under UK data protection law, such as the UK International Data Transfer Agreement, the UK Addendum to the European Commission's Standard Contractual Clauses, or transfers to countries the UK Government has determined provide an adequate level of protection. You may contact us for more information about the safeguards in place.

8. How long we keep your personal data

We keep personal data only for as long as necessary for the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. In general:

• Enquiry correspondence is kept for as long as needed to respond to and manage the enquiry, and for a reasonable period afterwards in case of follow-up, typically no longer than 24 months from our last contact, unless it develops into a client relationship governed by separate terms.
• Analytics data is retained for the period set out in the cookie table above.

When personal data is no longer required, we delete it or anonymise it securely.

9. How we protect your personal data

We maintain appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, or alteration. These include access controls, secure infrastructure provided by our service providers, and a commitment to confidentiality.

While we take reasonable steps to protect your data, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

10. Your rights

Under UK data protection law you have the following rights in relation to your personal data:

• The right to be informed about how we use your personal data, which this Policy provides.
• The right of access to a copy of the personal data we hold about you.
• The right to rectification of inaccurate or incomplete personal data.
• The right to erasure of your personal data in certain circumstances.
• The right to restrict processing in certain circumstances.
• The right to data portability in certain circumstances.
• The right to object to processing based on our legitimate interests.
• Rights relating to automated decision-making, although we do not carry out such processing.
• The right to withdraw consent at any time where we rely on consent, such as for analytics cookies.

To exercise any of these rights, please contact us at operations@composesalespartners.com . We will respond within one month, as required by law. There is normally no charge, although we may charge a reasonable fee or decline to act where a request is manifestly unfounded or excessive.

11. Complaints

If you have a concern about how we handle your personal data, we would ask you to contact us first so we can try to resolve it.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection, at ico.org.uk , or by telephone on 0303 123 1113.

12. Changes to this Policy

We may update this Privacy Policy from time to time. The current version will always be published on this website with the date it was last updated. Where changes are significant, we will take reasonable steps to bring them to your attention.

13. Contact us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at operations@composesalespartners.com , or write to us at: