1. About this policy
ATC Initiative Ltd ("ATC", "we", "us" or "our") is the controller of personal information collected through this website and related business enquiries. This policy explains what we collect, why we use it, who we share it with, how long we keep it and your rights.
It applies when you visit atcinitiative.com, make a business enquiry or otherwise contact us about ATC’s services. A supplementary notice may apply to a specific engagement, recruitment process or other activity.
2. Information we may collect
- Identity and contact details, such as your name, role, organisation, email address, telephone number and location;
- Enquiry information, including your company website, business, UK market status, objectives, requirements and material you choose to provide;
- Correspondence and relationship records, including emails, meeting notes, proposals, quotations and follow-up communications;
- Technical and usage information, such as IP address, browser, device, access time, referring page and use of the website;
- Due diligence, contractual, invoicing and payment information needed to establish or manage a client relationship.
3. Sources of information
You will usually provide information directly by email, contact form, meeting or another communication channel. We may also receive relevant business contact information from your organisation or colleagues, public sources, event organisers, referrers, and professional or commercial networks.
4. Purposes and lawful bases
| Responding to an enquiry, assessing fit and discussing an engagement | Steps at your request before a contract; and/or our legitimate interests |
| Preparing proposals, quotations and contracts, and delivering services | Contract or steps before a contract |
| Managing relationships, coordinating advisers and keeping records | Contract, legal obligation and our legitimate interests |
| Securing the website and understanding overall performance | Our legitimate interests; and consent for non-essential technologies where required |
| Sending requested updates or permitted business information | Consent or legitimate interests, subject to electronic marketing rules |
| Meeting accounting, tax, regulatory and dispute requirements | Legal obligation and establishing, exercising or defending legal claims |
5. Required information
You are not generally under a legal obligation to provide personal information. If information is necessary to respond, assess an engagement or perform a contract, we may be unable to proceed without it. Required fields will be identified at collection.
6. Sharing information
We share information only where necessary and with appropriate safeguards. Recipients may include website hosting, IT, communications and business-system providers; lawyers, accountants, tax, compliance, insurance, recruitment and other professional advisers; delivery partners; and regulators, law-enforcement bodies or public authorities entitled to receive it.
ATC does not sell personal information. Professional advisers may act as independent controllers. Providers acting for us must be subject to appropriate contractual terms.
7. International transfers
Because ATC supports Asian businesses operating in the UK, some communications or engagements may involve people or organisations outside the UK. Where information is transferred internationally, we assess the arrangement and use an adequacy decision, recognised contractual clauses or another appropriate safeguard where required.
8. Retention
General enquiries that do not become client relationships will normally be retained for no more than 24 months after the last substantive contact. Client, contractual, transaction and financial records will normally be retained for six years after the relationship ends, unless legal, regulatory or dispute-related reasons require a different period. Technical logs are generally retained for less time.
9. Your rights
Depending on the circumstances, you may ask us to access, correct or erase your information; restrict or object to processing; receive portable data; and withdraw consent where consent is the basis. Legal conditions and exemptions may apply.
To exercise a right, email info@atcinitiative.com. We may need to verify your identity. You may also complain to the UK Information Commissioner’s Office (ICO), although we would welcome the opportunity to address your concern first.
10. Security, external links and automated decisions
We use measures proportionate to the nature and risk of the information, but no internet transmission is completely secure. Third-party websites have their own privacy practices. We do not currently make decisions about website visitors based solely on automated processing that produce legal or similarly significant effects.
11. Contact and changes
Controller: ATC Initiative Ltd, company number 11429515, registered office: Corinthian House, Unit Co.9G, 17 Lansdowne Road, Croydon, London CR0 2BX. For privacy matters, contact info@atcinitiative.com.
We may update this policy when our business, technology or legal obligations change. The latest update date will appear on this page.