Privacy Policy

Introduction

We treat privacy and confidentiality very seriously at Change the Record (referred to in this notice as “we”, “us” or “our”). We comply with all aspects of the UK’s data protection legislative framework, which includes the UK General Data Protection Regulation (GDPR) and other UK legislation.

Scope of this notice

We respect the right of individuals to privacy. Our Privacy Notice explains:

• Who we are
• What kinds of personal data we may hold about you
• What we do with personal data
• The lawful bases on which we rely
• How we obtain data about you
• How long we keep information
• Who we share information with
• Transfers
• Your rights
• How to complain

Who we are

Our company is Change the Record Advertising & Marketing Ltd. Our registered office is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, and our Registered Company Number is 16234163.

In the course of providing marketing services to our clients and running our businesses, we gather and use personal information about a number of different categories of people. We have developed this privacy notice in order to be as transparent as possible about the personal information we collect and use.

Individuals wishing to contact us about data protection issues may do so by writing to us at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ or by emailing us at privacy@change-the-record.com

What kinds of personal information we may hold about you

The personal information that we collect includes:

• Basic information, such as your name (including name prefix or title), the company you work for, and your title or position.
• Bontact information, such as your postal address, email address and phone number(s).
• Marketing preferences.
• If you are our client, we will collect information about your circumstances that have led to you wishing to use our services. We also keep records of your contact with us.
• Technical information collected when you visit our website or digital or in relation to materials and communications we send to you electronically, which includes information about the type of device you are using, your IP address and geographic location, your operating system and version, browser type, the content you view and the search terms you enter.

What we do with personal data

We may use this personal data for the following purposes:

• to send you relevant marketing communications about our services
• to undertake research and analysis
• for identity validation and fraud reduction
• to communicate with you in relation to the provision of services by us
• to enable us, our clients or other suppliers of ours or our clients to communicate with you in relation to the provision of goods or services by you or the person that you work for
• to understand how people use our website so that we can make it more intuitive.

The lawful bases on which we rely are

Contract

Processing of your personal data is necessary for us to administer the pre-contract and contractual relationship between ourselves and our clients/suppliers in connection with the performance of a contract.

Legal obligation

This applies where we need to collect and use your personal information to comply with applicable laws and regulatory requirements.

Consent

We may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).

Legitimate interests

Change the Record uses personal data based on its legitimate commercial interests.

The data protection legislative framework recognises that it is in our legitimate business interests to collect and use personal information for marketing reasons. We do not need your consent to do this lawfully, but we are obliged to inform you that you have a right to object to this. The law also allows us to send marketing communications by electronic means to our existing clients and business contacts without needing consent. Again, you have the right to object to this activity if you wish.

How we obtain data about you

The personal data we have comes from various sources.

• You give us your personal information directly when you engage with us, including via our websites or digital media channels
• We obtain additional information in the course of undertaking checks in order to comply with our statutory and regulatory obligations, or where such checks are in our legitimate business interests
• We obtain contact details and other information from our business contacts
• We collect data from public information sources such as telephone directories, social media, the internet and news articles, and occasionally buy marketing lists of business contacts
• We collect personal information while monitoring our technology tools and services, including our websites, email and social media communications. For information about our use of tracking devices and cookies, please refer to our Cookies policy here.

How long we keep information

Our policy is to not hold personal information for longer than is necessary. We have established data retention timelines for all of the personal information that we hold based on why we need the information. The timelines take into account any statutory or regulatory obligations we have to keep the information, our legitimate business interests, best practice and our current technical capabilities. We have developed a Data Retention Policy that captures this information. We delete or destroy personal information securely in accordance with this policy.

Who we share information with

A number of third parties may have access to your personal information or we may share or send it to them. This includes:

• Regulatory authorities and organisations we’re legally obliged to share personal information with.
• Business partners, suppliers and subcontractors for the performance of any contract we enter into with you.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may also pass data to other companies that process personal data on our behalf to help us conduct our business. When we do so, we ensure that appropriate contractual safeguards are put in place.

Transfers

We do not send personal data outside the European Economic Area (EEA) as a matter of course.

We rely upon the EU GDPR adequacy decision for transfers of data between the UK and the EEA.

Transfers of personal data outside the EEA can arise where we are acting for business clients with interests outside the EEA that:

• have operations or employees/contractors that are based outside the EEA
• buy goods or services from businesses or organisations that are based outside the EEA
• are entering into transactions with business, organisations or individuals based outside the EEA

If we are required to transfer personal data outside of the EEA, we will ensure that we do so in a legally compliant manner and take steps to ensure the information is protected in the same way as if it were being used in the EEA.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by not opting in to be contacted for marketing purposes. You can also exercise the right at any time by contacting us at privacy@change-the-record.com

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also contact the Information Commissioner’s Office via their website at www.ico.org.uk/concerns or write to them at:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Changes to this Privacy Notice

Change the Record reserves the right to update and revise this Privacy Notice from time to time to take into account legislative and other developments. Any changes we may make to our Privacy Notice will be posted on this page and contain an “effective date” reflecting when the last changes occurred.

Effective Date: 1 September 2025.