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Privacy

Last Updated: 9 September 2025
Version: 1.0

1. INTRODUCTION

This Privacy Policy explains how Unusual Group Limited (and its subsidiaries) ("we", "us", "our", or "Unusual Group") collects, uses, shares, and protects personal data through our website www.unusualgroup.com ("Website") and related services.

We are committed to protecting your privacy and handling your personal data transparently, lawfully, and securely in compliance with:

- UK General Data Protection Regulation (UK GDPR)
- EU General Data Protection Regulation (EU GDPR) 
- Data Protection Act 2018
- Privacy and Electronic Communications Regulations (PECR)
- International privacy laws where applicable

Data Controller Details: 
Unusual Group Limited  
Company Number: 12724959  
Registered Office: 124 City Road, London, Greater London, England, EC1V 2NX  
Contact: hello@unusualgroup.com

2. DATA WE COLLECT

2.1 Information You Provide Directly

Contact Information

- Name
- Email address
- Phone number (if provided)
- Company name and position
- LinkedIn profile (if provided)
- Message content and enquiries

Business Information

- Agency details (for potential partners)
- Investment interests
- Business needs and challenges
- Professional background

Event and Marketing Data

- Event registration details
- Marketing preferences
- Newsletter subscriptions
- Webinar attendance

2.2 Information Collected Automatically

Technical Data

- IP address
- Browser type and version
- Device information (type, operating system)
- Time zone setting
- Browser plug-in types and versions
- Screen resolution

Usage Data

- Pages visited and time spent
- Click patterns and navigation paths
- Referring website
- Download history
- Search queries on our Website
- Date and time of access

Location Data

- Approximate geographic location (from IP address)
- Country and region

2.3 Cookie Data

We use cookies and similar technologies. See Section 9 for details on:

- Essential cookies
- Analytics cookies
- Functional cookies
- Marketing cookies (with consent)

2.4 Data We Do Not Collect

We do not intentionally collect:

- Sensitive personal data (health, political opinions, religious beliefs)
- Financial account details
- Government identification numbers
- Data from children under 16

3. HOW WE COLLECT DATA

3.1 Direct Interactions

- Website contact forms
- Email correspondence
- Phone conversations
- Newsletter sign-ups
- Event registrations
- Business meetings

3.2 Automated Technologies

- Cookies and tracking pixels
- Server logs
- Google Analytics (anonymised)
- Heat mapping tools (session recordings with consent)

3.3 Third-Party Sources

- LinkedIn (public profiles)
- Companies House (public records)
- Industry databases (publicly available)
- Partner referrals (with consent)
- Marketing partners (with lawful basis)

‍

4. LEGAL BASIS FOR PROCESSING

We only process personal data when we have a lawful basis:

4.1 Legitimate Interests

We process data based on legitimate interests for:

- Responding to enquiries about our services
- Maintaining business relationships
- Network security and fraud prevention
- Internal administration and record-keeping
- Improving our Website and services
- Direct marketing to businesses (B2B)

Balancing Test. We've assessed that these interests don't override your fundamental rights and freedoms.

4.2 Consent

We obtain explicit consent for:

- Marketing emails (where required)
- Non-essential cookies
- Sharing data with certain third parties
- Processing sensitive data (if ever required)

You can withdraw consent at any time by emailing hello@unusualgroup.com.

4.3 Contract

We process data as necessary to:

- Provide requested services
- Fulfil partnership agreements
- Deliver contracted support

4.4 Legal Obligations

We process data to comply with:

- Financial regulations
- Tax requirements
- Court orders
- Legal proceedings

5. HOW WE USE YOUR DATA

5.1 Primary Purposes

Service Delivery

- Respond to your enquiries
- Assess partnership opportunities
- Provide strategic advisory services
- Manage our relationship with you

Communication

- Send requested information
- Provide updates on our services
- Share relevant industry insights
- Announce events and opportunities

Business Operations

- Maintain internal records
- Improve our services
- Conduct market research
- Analyse Website performance

5.2 Marketing

B2B Marketing

- We may send business-related marketing based on legitimate interests
- You can opt out at any time via unsubscribe links or emailing us

Personalisation

- We may personalise content based on your interests
- This is based on legitimate interests or consent

5.3 What We Don't Do

We will never:

- Sell your personal data
- Share data without lawful basis
- Use data for unrelated purposes
- Make solely automated decisions affecting you
- Transfer data to countries without adequate protection (without safeguards)

6. DATA SHARING AND DISCLOSURE

6.1 Within Our Organisation

- Unusual Group subsidiaries (for service delivery)
- Authorised employees (on need-to-know basis)
- Board members (where necessary)

6.2 Service Providers (Data Processors)

We share data with trusted providers who assist us:

Technology Providers

- Cloud hosting (AWS - UK/EU servers)
- Email services (encrypted providers)
- CRM systems (GDPR-compliant)
- Analytics platforms (anonymised data)

Professional Services

- Legal advisors (under confidentiality)
- Accountants (for regulatory compliance)
- IT support (under strict agreements)

All processors are bound by data processing agreements ensuring GDPR compliance.

6.3 Other Disclosures

We may disclose data when:

- Required by law or court order
- Protecting our legal rights
- Preventing fraud or security threats
- Business sale or merger (with notice)

6.4 International Transfers

Primary Processing: UK-based

International Transfers: If we transfer data outside the UK/EU, we ensure:

- Adequacy decisions are in place, or
- Standard contractual clauses (SCCs) are used, or
- Your explicit consent is obtained

We'll inform you of any international transfers and safeguards applied.

7. DATA RETENTION

Deletion Process: After retention periods, data is securely deleted or anonymised.

8. YOUR RIGHTS

Under GDPR, you have the following rights:

8.1 Right to Access (Subject Access Request)

- Request copies of your personal data
- Understand how it's processed
- Verify lawfulness of processing

8.2 Right to Rectification

- Correct inaccurate data
- Complete incomplete data
- Update outdated information

8.3 Right to Erasure ("Right to be Forgotten")

Request deletion when:

- Data no longer necessary
- Consent withdrawn
- Unlawful processing
- Legal obligation to erase

8.4 Right to Restrict Processing

Limit processing when:

- Accuracy contested
- Processing unlawful
- We no longer need data but you need it for legal claims
- You've objected pending verification

8.5 Right to Data Portability

- Receive your data in structured, common format
- Transfer to another controller
- Applies to consent/contract-based processing

8.6 Right to Object

Object to processing based on:

- Legitimate interests
- Direct marketing
- Statistical/research purposes

8.7 Rights Regarding Automated Decisions

- Not be subject to solely automated decisions
- Request human intervention
- Express your point of view
- Contest decisions

8.8 Right to Withdraw Consent

- Withdraw at any time
- Doesn't affect prior lawful processing
- Must be as easy as giving consent

8.9 How to Exercise Rights

- Email: hello@unusualgroup.com
- Post: Address above
- Response time: Within 30 days
- Fee: Usually free (excessive requests may incur fee)
- Identification: We may request ID verification

9. COOKIES AND TRACKING

9.1 What Are Cookies?

Small text files stored on your device that help us improve your experience and understand Website usage.

9.2 Cookie Categories

Essential Cookies

- Required for Website operation
- Security and authentication
- No consent required

Analytics Cookies

- Google Analytics (anonymised IP)
- Usage patterns and improvements
- Consent required

Functional Cookies

- Remember preferences
- Enhanced functionality
- Consent required

Marketing Cookies

- Measure campaign effectiveness
- Retargeting (if implemented)
- Consent required

9.3 Managing Cookies

Browser Controls

- Most browsers allow cookie blocking/deletion
- See browser help section for instructions

Our Cookie Settings

- Manage preferences via cookie banner
- Opt out of non-essential cookies

Third-Party Opt-Outs

- Google Analytics: tools.google.com/dlpage/gaoptout
- General: youronlinechoices.com

9.4 Other Tracking Technologies

- Pixel tags (email open rates)
- Local storage
- Session storage

10. DATA SECURITY

10.1 Technical Measures

- SSL/TLS encryption for data transmission
- Encrypted storage for sensitive data
- Firewalls and intrusion detection
- Regular security updates and patches
- Access controls and authentication
- Regular penetration testing

10.2 Organisational Measures

- Staff training on data protection
- Confidentiality agreements
- Limited access (need-to-know basis)
- Clean desk policy
- Secure disposal procedures
- Incident response plan

10.3 Data Breach Procedures

In case of a breach:

- Investigate and contain immediately
- Assess risk to individuals
- Notify ICO within 72 hours (if required)
- Notify affected individuals (if high risk)
- Document and learn from incidents

11. THIRD-PARTY WEBSITES

Our Website may contain links to third-party sites. We're not responsible for their privacy practices. Please review their policies before providing personal data.

12. CHILDREN'S PRIVACY

Our Website isn't directed at children under 16. We don't knowingly collect data from children. If we discover such data, we'll delete it immediately. Parents/guardians should contact us if concerned.

13. INTERNATIONAL VISITORS

13.1 Jurisdiction

This Website operates from the UK. If you're accessing from elsewhere:

- Your data may be transferred to the UK
- UK data protection laws will apply
- We'll respect your local privacy rights where applicable

13.2 Additional Rights for EU Residents

EU residents maintain all GDPR rights when accessing from the EU.

13.3 California Residents (CCPA)

While we don't target California residents, if applicable:

- Right to know what data we collect
- Right to deletion
- Right to opt-out of data sales (we don't sell data)
- Non-discrimination for exercising rights

14. AI AND AUTOMATED PROCESSING

14.1 Our Use of AI

We may use AI for:

- Content generation
- Data analysis
- User experience improvement

14.2 Your Rights

- We don't make solely automated decisions affecting you
- Any AI use includes human oversight
- You can request human review of any automated processing

15. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. Changes will be posted here with an updated date. Material changes will be notified via:

- Website notice
- Email (for registered users)

Please review regularly for updates.

16. COMPLAINTS

If you're unhappy with our data handling:

First Step: Contact us at hello@unusualgroup.com
Supervisory Authority: You can lodge a complaint with:
UK Residents:
Information Commissioner's Office (ICO)  
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF  
Helpline: 0303 123 1113  
Website: ico.org.uk
EU Residents:  
Your local data protection authority  
List available at: edpb.europa.eu

17. CONTACT US

For any privacy questions, concerns, or to exercise your rights:

Data Protection Contact:

Unusual Group Limited  
124 City Road, London, Greater London, England, EC1V 2NX  
Email: hello@unusualgroup.com

Response Commitment:* 

- Acknowledge within 3 business days
- Resolve within 30 days
- Complex requests may take longer (we'll explain why)

18. DEFINITIONS

Personal Data: Information relating to an identified or identifiable natural perso
Processing: Any operation performed on personal data
Data Controller: Entity determining purposes and means of processing
Data Processor: Entity processing data on controller's behalf
Consent: Freely given, specific, informed, unambiguous indication of wishes
Data Subject: The individual whose personal data is processed

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© 2025 Unusual Group Limited. All rights reserved.
This Privacy Policy forms part of our Website Terms of Use.

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hello@unusualgroup.com
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