Privacy and Cookie Policy

This is the Privacy and Cookie Policy for SquareWell Partners Ltd (“SquareWell”) and AQTION platform (“AQTION”) (both referred as “we”, “us” and “our”). This policy explains who we are, why and how we collect, store and use (together, “process”) your personal information (also referred to as personal data) when you use AQTION, your rights and how to contact us if you need to. Our contact details are set out at the end of this policy.

We are committed to protecting your privacy; as such, please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By using or accessing SquareWell or AQTION, respectively located at www.squarewell-partners.com and www.aqtion-platform.com, you are accepting the practices described in this Privacy Policy.

We are the data controller in relation to the personal information processed in accordance with this policy (except where this policy explains otherwise). This means we have responsibilities to treat your personal information in accordance with applicable data protection and privacy laws.

• Information Processing Summary

• Legal Bases of Processes Explained

• Who We Share Your Personal Information With

• Where We Store Your Information

• How We Protect Your Information

• How Long We Keep Your Information

• Your Rights

• Changes to This Policy

• Contact Us

‘Data Controller’ – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law, the controller or the specific criteria for its nomination may be provided for by law.

‘Data Processor’ – a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Any further detail on definitions can be found in Article 4 of the European Union’s General Data Protection Regulation (the “GDPR”).

We will process the following types of personal information:

• First and last name
• Job title
• Your employer
• Your professional address, phone number(s), and e-mail address
• Your social media handle and profile link
• Technical information (see the Cookies section below for more detail)

Where we are provided with your personal information by your employer (where they are a client or prospective client of ours) certain third parties and public sources, we may not be the controller of that personal information. However, we will treat this personal information in accordance with applicable data protection and privacy laws, and this policy.

The following table sets out the sources and uses of the personal information we process. We also explain what legal basis allows us to undertake the processing.

Source of Personal Information	Uses We Make of This Personal Information	Our Legal Basis For This Processing (See Explanations Below)
Information you or your employer gives to us (by phone, email, in person, social media or through our website).	To provide our service to you and to notify you of any changes to our service. To perform any other obligations under our contract with you or your employer. To provide information to you which you have requested. To invite you to events (which may be webinars or in-person) To provide you with thought leadership pieces on topics we think may be of interest to you. To provide you with information about our services we feel may interest you or your employer. See "Your rights" To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.	Our legitimate interests Contract
Information we obtain from public or third-party sources, such as public websites, professional third parties. Provided by clients in their capacity as Data Controllers, publications from our clients or prospective clients, or our business partners.	To invite you to events (which may be webinars or in-person). To provide you with access to thought leadership pieces on topics we think may interest you or your employer. See "Your rights". To enable our clients to contact themselves their investors. To administer our site and for internal operations, including troubleshooting, data analysis , testing, research, statistical and survey purposes.	Our legitimate interests
Either of the above sources.	To promote our service or business to you.	Consent

Legitimate interests: Processing your data is necessary for our legitimate interests or the legitimate interests of a third party. Our legitimate interests are:

• Performing a contract with our clients (our clients may include your employer)
• Gaining insights on how you use our website and service
• Delivering, developing and improving our website, products and service for the benefit of existing, and prospective clients
• Enabling us to enhance, customise or modify our website, service and communications
• Improving our data security
• B2B promotional or marketing purposes

In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests.

Contract: Processing your personal information is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.

Consent: We will process your personal information for promotional or marketing purposes where you have given us your express consent for us to do this. You can stop further marketing at any time by sending an email to enquiries@squarewell-partners.com or enquiries@aqtion-platform.com.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

We may use your personal data to form a view on what services or other offerings we think you may want or need, or what may be of interest to you. You may receive marketing communication from us if you have requested information from us or have used our services and you have not opted out of receiving that marketing or where we are otherwise legally permitted to send you marketing. Please note you will always have the opportunity to unsubscribe from our publications via an unsubscribe link in our communications to you. 

We will not sell or rent individual personal information without consent. Information submitted to us is only available to our employees managing this information for the purposes set out above.

We may share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal information under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.

• Appropriate third parties including some of our business partners, suppliers or sub-contractors as set out below:

Company	Purpose of Processing	Location	Privacy Protection
Digital Ocean	Storage, reviewing and deletion of data to enable us to provide our service.	USA	EU-US Privacy Shield certified
Asana	Storage, reviewing and deletion of data for project management purposes	USA	EU-US Privacy Shield certified
Calendly	Storage and reviewing of data to enable sales call scheduling.	USA	EU-US Privacy Shield certified
Saleshandy	External communications from us.	USA	EU-US Privacy Shield certified
Sharepoint	Storage, reviewing and deletion of data to enable us to provide our service.	USA	EU-US Privacy Shield certified

 

• Our clients and regulators for the performance of any contract we enter into or other dealings we have in the normal course of business with you or your employer;
• Our auditors, legal advisors and other professional advisors; and
• Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets subject to the terms of this policy.
• If SquareWell Partners Ltd or AQTION or substantially all of its assets are acquired by a third party, in which case personal information held by it about its clients will be one of the transferred assets.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of service or other agreements with you or your employer; or to protect the rights, property, or safety of SquareWell or AQTION, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

We may transfer your personal information outside the EEA:

• In order to store it.
• In order to enable us to provide services to and fulfil our contract with you or your employer.
• Where we are legally required to do so.
• In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
• For the reasons set out in the previous section ‘Who we share your personal information with’.

We may transfer your personal information to the countries and using the safeguards outside the EEA set out in section ‘Who we share your personal information with’.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our servers (which may be supplied by third-parties as mentioned above). Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our website or service may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies. Please check these policies before you submit any personal information to these websites.

SquareWell or AQTION do not accept any responsibility or liability for these policies or any content on external sites and does not necessarily endorse the views expressed within them. SquareWell or AQTION have no control over the availability of any of these websites.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

In order to maintain the security of our systems, protect our staff, record transactions, and, in certain circumstances, to prevent and detect crime or unauthorised activities, we reserve the right to monitor all Internet communications including web and email traffic into and out of our domains.

Data protection legislation gives you a number of rights in respect of your personal information that we process. You have the right, under certain circumstances:

• To be provided with a copy of your personal information held by us;
• To request the rectification or erasure of your personal information held by us;
• To request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
• To object to the further processing of your personal information, including the right to object to marketing (as set out below);
• To request that your provided personal information be moved to a third party.

You can also change your preferences and object to receiving further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to the email address below.

You can exercise any of the other rights listed above at any time by contacting us at enquiries@squarewell-partners.com or enquiries@aqtion-platform.com. Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at enquiries@squarewell-partners.com or enquiries@aqtion-platform.com.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (see here).

The Information Commissioner (ICO) is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal information, as well as deal with any complaints that you have about our processing of your personal information. For more information on the ICO, and how to make a complaint, please visit their website at www.ico.org.uk.

Any changes we make to this policy will be posted on our website at www.squarewell-partners.com or www.aqtion-platform.com and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on 17 November 2023.

We welcome your feedback and questions. If you wish to contact us, please send an email to enquiries@squarewell-partners.com or enquiries@aqtion-platform.com.

Like most websites, we use cookies to distinguish you (or your device) from other users of our website. Cookies help us to improve our website to provide you with a better browsing experience.

Cookies are small amounts of information that are stored on your browser or the hard drive of your device to enable our server to collect certain information from your web browser. Cookies in themselves do not identify the individual, but do collect information about your computer, browser, online session, the websites you visit and other information.

We may use the following types of cookies:

• Strictly necessary cookies - These are cookies that are required for the operation of our Services and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical / performance cookies - They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies - These are cookies that are used to recognise you when you return to our website and AQTION platform. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region). These cookies make your browsing more secure or provide functionalities that are previously requested by you. As they are necessary for the operation of the AQTION platform, these cookies are enabled by default and cannot be refused. We may use cookies necessary to save your selection of cookies, to stabilize your navigation or to make it more secure.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be able to access all or parts of our site. To learn more about cookies and how to manage or delete them, visit www.aboutcookies.org.

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site.

Except for essential cookies, all cookies used on our site will expire after a certain period of time. You can find more information about the individual cookies we use and the purposes for which we use them here:

Cookie	Name	Purpose and Lawful Basis	More Information
Google Analytics	_utma _utmb _utmc _utmz	These cookies are used to collect information about how visitors use our site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.	Google's Privacy Policy Google's official "Cookies & Google Analytics" page How to opt-out of Google Analytics
Linkedin		SquareWell and AQTION’s websites provide the ability to share content on LinkedIn. LinkedIn may deliver cookies.	LinkedIn's Privacy Policy.

SquareWell or AQTION may update its Cookie Policy and the lists of cookies from time to time. If you have more questions, you can contact us at enquiries@squarewell-partners.com or enquiries@aqtion-platform.com.