Privacy Policy

Last updated: July 2026

LineTen Limited (“LineTen”, “we”, “us”, or “our”) is strongly committed to protecting personal data. This privacy policy describes how and why we collect and use personal data and provides both information about individuals’ rights and how to exercise them. Personal data is any information relating to an identified or identifiable living person and this privacy policy applies to personal data provided to us, both by individuals themselves or by others. LineTen processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

1. Who we are

LineTen Limited is a limited company registered in England and Wales with registered number 06834644 and VAT registered number 105071070. Our registered office is 1st Floor Sackville House, 143-149 Fenchurch Street, London, EC3M 6BN.

LineTen is the controller of personal data described in this policy. We are established in the United Kingdom and this policy is written primarily by reference to UK data protection law — the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025. Where we process personal data of individuals in the European Economic Area (“EEA”), we also comply with the EU GDPR.

2. To whom this policy applies

This policy applies to any individual for whom LineTen processes personal data, including (but not limited to):

• Customers
• Employees (current and former)
• Commercial suppliers and partners
• Vacancy applicants
• Auditors & regulators

3. Personal data we collect

LineTen only collects personal data which is relevant to our purpose of business and for which a lawful basis exists. Such individuals may include (but are not limited to) employees, customers, vacancy applicants or suppliers, and the data we collect may be personally identifiable information such as: identity (name, gender); contact information (phone number, email address, home address); and technical information (IP address, login username, password). LineTen will only collect, store and use such data where there is a lawful basis of processing. This will typically be by obtaining explicit consent from the individual, or by demonstrating a legitimate interest which makes such processing necessary. It is the responsibility of the individual to ensure that the data we hold is current and accurate. Details of how to inform us about a change in your personal data are found further in this document.

4. How we will collect personal data

We will ask for personal data only when we need it and each item of data which we request will be relevant to the task it is needed for. Data will typically be collected in the form of a paper document or electronically via an online portal.

5. Why we need personal data

LineTen processes your personal data for one of the following reasons: we need to process the data under our contract with you for our services; we have a legitimate interest as a business in processing your data; the processing falls within a recognised legitimate interest defined by law (for example, safeguarding or the prevention of crime), as introduced by the Data (Use and Access) Act 2025; we have a legal obligation to process the data; or we have your consent (which you can withdraw at any time).

6. How we protect personal data

We employ real-time monitoring and undertake regular security reviews to ensure your personal data is protected. Where data is transferred to external parties acting as data processors, we undertake reasonable steps to ensure that third-party data policies meet UK data protection standards.

Our infrastructure is hosted with providers operating data centres in the UK, the EEA (including Ireland), the United States, and South East Asia. Where personal data is transferred outside the UK, we put in place appropriate safeguards before the transfer takes place. Depending on the destination, this includes: reliance on UK adequacy regulations; the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses; or other Article 46 UK GDPR safeguards. In each case we assess whether the protection afforded to personal data at the destination is not materially lower than the standard of protection under UK law. A list of our sub-processors and the countries in which they process data is available by emailing [email protected].

7. What we do with personal data

Personal data collected by us may be:

• Stored and managed by LineTen. We may store personal data in digital or hard copy format in our head offices.
• Transferred to other LineTen group entities. We may share personal data with other LineTen group entities where necessary for administrative and support services.
• Transferred to third-party organisations that provide applications, functionality, data processing or IT services to us — for example, providers of cloud-based software, identity management, website hosting, data analysis, backup, security and storage services. A list of sub-processors is available by emailing [email protected].
• Transferred to third-party organisations that otherwise assist us in providing goods, services or information. We have liaised with such organisations to ensure that personal data held on their systems is stored with at least the same level of security as LineTen’s own standards require. A list of sub-processors is available by emailing [email protected].
• Transferred to government agencies and/or regulators, where necessary for us to adhere to any regulatory or legal requirements.

8. How long we keep personal data

We keep personal data only for as long as necessary for the purposes for which it was collected, taking into account contractual commitments, legal and regulatory retention requirements, and our own record-retention policy. Typical retention periods are set out below; specific circumstances may require a longer or shorter period.

A full copy of our internal retention schedule is available on request by emailing [email protected].

9. Your rights as an individual

Individuals have certain rights over their personal data and, as a data controller, we are responsible for fulfilling these rights. Advice on how to exercise such rights, along with LineTen’s response, is detailed below.

Access to personal data

You have the right to access personal data held by us as a data controller. To exercise this right, email [email protected] providing your name, contact details and details of any specific data to which you would like access. LineTen will verify the identity of the individual making the request and reply as soon as possible within the timescale legally required.

Amendment of personal data

To update personal data submitted to us, email [email protected] providing your name, contact details and any data item(s) that require amendment. Once we receive the request for amendment along with the corrected data, we will update your personal data with the corrected information provided.

Deletion of personal data

You have the right to erase any personal data which is no longer necessary in relation to the purpose for which it was originally required, or for which LineTen has no legitimate interest to continue to store. To request erasure of personal data, email [email protected] providing your name, contact details and any data item(s) that require deletion. Should LineTen determine the data is no longer required in line with the above individual rights, the data will be deleted.

Withdrawal of consent

We do not generally process personal data based on consent (as we can usually rely on another legal basis) but in any circumstances in which we do, you may withdraw such consent at any time. To withdraw consent, email [email protected] providing your name, contact details and indicating to which personal data items the withdrawal of consent applies.

Other data subject rights

This privacy statement is intended to provide information about what personal data we collect about you and how it is used. For a full list of individuals’ rights, visit the ICO’s guide to individual rights.

If you wish to exercise any of these rights, please send an email to [email protected] providing your name, contact details and which rights you would like to exercise.

10. How to complain

If you are unhappy with how we have handled your personal data, please tell us first so we have the chance to put things right. Email [email protected], marking your message “Data protection complaint”, and include your name, contact details and the nature of your concern. We will acknowledge your complaint within 5 working days and provide a substantive response without undue delay, and in any event within 30 days, in line with our obligations under the Data Protection Act 2018 (as amended by the Data (Use and Access) Act 2025).

If, having complained to us, you remain dissatisfied, you have the right to complain to the UK data protection regulator. This is currently the Information Commissioner’s Office (ICO), which is being reconstituted as the Information Commission under the Data (Use and Access) Act 2025.

You can find out more, or lodge a complaint, at ico.org.uk/make-a-complaint.

11. Contact information

If you have any questions about this privacy policy, or a question, comment or complaint about our use of personal data, please contact us at our registered address of 1st Floor Sackville House, 143-149 Fenchurch Street, London, England, EC3M 6BN, or send an email to [email protected].

12. About this privacy policy

LineTen is committed to providing full transparency about its data usage and to allowing individuals to exercise their rights under UK and, where applicable, EU data protection legislation. This privacy policy reflects that commitment and is applicable in all territories in which LineTen operates. It was last reviewed and updated in July 2026 to reflect the changes introduced by the Data (Use and Access) Act 2025, and will continue to be updated as legislation and guidance evolve. The current version of this policy can be found on our company website (lineten.com).