Privacy Policy.

1. Introduction

LOST CIRCLE LTD ("we", "us", or "our") is a UK company that designs, builds and delivers custom software for businesses. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage with our services.

We are committed to protecting your privacy and ensuring compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. As the data controller, we are responsible for how your personal data is processed.

2. Information We Collect

2.1 Information You Provide to Us

When you contact us through our website contact form, we collect the following information to respond to your enquiry:

• Name
• Email address
• Phone number (if provided)
• Company name
• Message content and any other details you choose to share

2.2 Information Collected Through Scheduling Tools

If you use our consultation booking or scheduling tools, we collect information necessary to arrange and manage meetings, including:

• Preferred meeting times and dates
• Timezone information
• Calendar availability
• Any additional context or requirements you provide

2.3 Automatically Collected Information

When you visit our website, we automatically collect certain information about your device, including:

• IP address
• Browser type and version
• Operating system
• Pages you visit and time spent on pages
• Referring website addresses
• Date and time of your visit

2.4 Information About People We Contact Directly

We contact people at businesses who may be interested in our services. If we have contacted you without you first contacting us, this section explains where your details came from and what we hold.

We collect business contact details, which may include:

• Your name and job title
• The company you work for
• Your work email address and work phone number
• The public web page or profile where we found these details
• A record of our emails and calls with you, and your replies

We obtain these details from public sources, such as company websites and professional networking sites like LinkedIn, and from business contact data providers.

We use them to tell you about our services, on the basis of our legitimate interest in doing so (see section 4). Our emails may come from addresses on the lostcircle.co.uk domain as well as lostcircle.uk. Every email we send says who we are, and you can tell us to stop at any time (see section 11).

3. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your enquiries about our software delivery services
• To schedule and manage consultations, discovery calls, and client meetings
• To provide information about our services and capabilities (with your consent or where we have a legitimate business interest)
• To contact people at businesses who may be interested in our services, using business contact details from the sources described in section 2.4
• To deliver and manage our services when you engage us as a client
• To improve our website, services, and client experience
• To analyse website usage patterns and understand how visitors interact with our content
• To comply with legal and regulatory obligations
• To protect our business interests and prevent misuse

4. Legal Basis for Processing

Under UK GDPR, we process your personal data based on the following lawful bases:

• Consent: When you explicitly opt in to receive marketing communications, newsletters, or updates about our services
• Legitimate Interest: For B2B communications with potential clients, website analytics to improve our services, and business development activities where we have a genuine business interest that does not override your rights
• Contract Performance: To deliver our software services, manage client relationships, and fulfil contractual obligations
• Legal Obligation: To comply with UK laws, tax requirements, and regulatory obligations

5. Analytics

We use analytics tools, including Google Analytics, to understand how visitors interact with our website. These tools collect anonymised information such as page views, time spent on pages, user interactions, and traffic sources. This data helps us improve our website content, user experience, and understand which services generate the most interest.

Google Analytics uses cookies and similar tracking technologies. You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on or by adjusting your browser settings to reject cookies. For more information, please see our Cookies Policy.

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with:

• Service Providers: Third-party vendors and processors who assist us in operating our website and providing our services (e.g., hosting providers, email service providers, customer relationship management and email outreach tools, analytics providers)
• Sub-processors: Our service providers may use sub-processors to assist in delivering services to us
• Our Delivery Team: Developers who work for us as contractors, including contractors based in Pakistan, who may access personal data to deliver our services and support our business
• Legal Requirements: When required by law, court order, or governmental authority
• Business Transfers: In connection with any merger, sale of assets, or acquisition

All third-party processors and contractors are contractually obligated to protect your data and use it only for the purposes we specify.

7. International Data Transfers

Part of our delivery team works from Pakistan, so personal data we hold may be accessed from there. The UK has not recognised Pakistan as providing an adequate level of data protection. We therefore protect these transfers with the International Data Transfer Agreement (IDTA) issued by the Information Commissioner's Office (ICO), and we assess the risks of each transfer before it takes place.

Some of our service providers are also located outside the UK and the European Economic Area (EEA). When your personal data is transferred outside the UK, we rely on one of the following safeguards:

• UK adequacy regulations, where the destination is recognised as providing adequate protection
• The ICO's International Data Transfer Agreement, or the ICO's International Data Transfer Addendum to the European Commission's standard contractual clauses
• Other appropriate safeguards permitted by UK GDPR

You can ask for details of the safeguard that applies to your data by emailing info@lostcircle.uk.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Our retention periods are:

• Contact Form Submissions: Retained for 3 years from the date of submission, unless you become a client
• Client Data: Retained for the duration of our business relationship plus 7 years for legal and accounting purposes
• Marketing Communications: Retained until you opt-out or withdraw consent
• People We Contact Directly Who Do Not Reply: Deleted 12 months after our last contact with you
• People We Contact Directly Who Reply but Do Not Become Clients: Deleted 24 months after our last conversation with you
• People Who Ask Us to Stop Contacting Them: We keep only your email address and company name, on a do-not-contact list, so that we do not contact you again
• Analytics Data: Retained in aggregated and anonymised form

9. Security Measures

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and software updates
• Access controls, authentication procedures, and principle of least privilege
• Staff training on data protection and security best practices
• Secure hosting infrastructure and trusted service providers

However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

10. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data (subject to certain conditions)
• Right to Restrict Processing: Request limitation of how we process your data
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing based on legitimate interests, and object to direct marketing at any time (see section 11)
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise any of these rights, please contact us at info@lostcircle.uk. We will respond to your request within one month, though we may extend this period by a further two months if your request is complex. We will inform you if this extension is necessary.

11. Your Right to Object to Direct Marketing

You can tell us to stop contacting you for marketing at any time, and we will. This applies whether you opted in or we contacted you first. You do not need to give a reason, and we will not refuse.

To stop hearing from us, you can:

• Reply to any of our emails and ask us to stop
• Click the unsubscribe link in any marketing email that includes one
• Email us at info@lostcircle.uk

We will then add your email address and company name to our do-not-contact list, so that we do not contact you again, including if your details later appear in another list we use.

Please note that even if you opt out of marketing communications, we may still contact you regarding your account, our services, or to respond to your enquiries.

12. Cookies

Our website uses cookies and similar tracking technologies. For detailed information about the cookies we use and how to manage them, please see our Cookies Policy.

13. Children's Privacy

Our services are directed to businesses and professionals. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have inadvertently collected information from a child, please contact us immediately and we will take steps to delete such information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. We will notify you of any material changes by posting the updated Privacy Policy on this page and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. How to Contact Us

If you have questions about this Privacy Policy, wish to exercise your rights under UK GDPR, or have concerns about how we handle your personal data, please contact us:

If you are unhappy with how we have handled your personal data, please tell us first by emailing info@lostcircle.uk. We will acknowledge your complaint within 30 days, look into it, and tell you the outcome without undue delay.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe we have not handled your personal data in accordance with UK GDPR. You can contact the ICO at ico.org.uk or by calling 0303 123 1113.