PRIVACY POLICY

https://www.ceo-cf.com respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Who are we?

Depending on the service provided, CEO CF LTD (collectively referred to as "we", "us" or "our" in this privacy policy) may act as a data processor, a joint data controller or a data controller in our own right to manage and improve the service.

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

  • Full name of legal entity: CEO CF LTD

  • Email address: info@ceo-cf.com (general)

  • Data protection enquiries: dpo@ceo-cf.com (alias routed to the CEO CF data-protection lead)

  • Postal address: 4 Quern House Mill Court, Great Shelford, Cambridge, England, CB22 5LD

  • ICO registration reference (UK): ZB506419 (registered as data controller)

This policy was last updated on 16/04/2025.

2. How do you use my data?

When you create and log into your account, we will collect your name, email address, phone number, address, company name and address (if applicable) and your payment details. We collect this in order to take steps to enter into a contract with you and allow you to purchase our services.

When you sign up to receive our news updates, we will collect your name and email address to provide you with our news updates in line with any preferences you have told us about. When we send you our news updates because you have opted-in to receive them, we rely on your consent to contact you.

You can unsubscribe from our updates at any time by responding to any email you receive from us to tell us you wish to unsubscribe or by emailing info@ceo-cf.com.

When you contact us either by phone, email, via our 'contact us' page or via social media, we will  usually  collect  your  name,  social  media  handle  and  contact  details,  because  it's  in  our legitimate interest to make sure we can properly respond to your query.

When you use our website and consent to our use of cookies, we will collect information about how you use our website. We use this information to improve our website and to better understand how people use it. More detail on the information we collect and how we do this is set out in our Cookie Policy.

If our business is sold, we process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the buyer of our business may not be able to provide services to you.

3. Who do you share my data with?

Business partners, suppliers and subcontractors for the performance of the contract we enter into with them or you. Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.

4. Where do you store my data?

We use the following sub-processors to handle your personal data, each under an Article 28 GDPR-compliant Data Processing Agreement:

  • Google Workspace — UK/EU residency, member emails and shared docs

  • Notion ('Treasurer') — US, our member-data store, under SCCs and the UK IDTA

  • Motion — US, AI notetaker on prep calls (with documented member consent)

  • AdobeSign — US/EU, e-signatures for the Membership Agreement and NDA

  • WhatsApp (Meta) — Ireland/US, trust-group communications

  • FreeAgent — UK, accounting and invoicing

  • Lasso — whistleblowing platform

The full and current list is available on request to info@ceo-cf.com..

When working with third parties we may need to transfer your personal data outside of the UK and / or EU.

Whenever we transfer your personal information outside of the UK and the EU, we ensure it receives additional protection as required by law. To keep this policy as short and easy to understand as possible, we haven't set out the specific circumstances when each of these protection measures are used. You can contact us using the details above for more information on this.

5. How long do you keep my data for?

Specific retention periods are set out in our Data Retention & Ownership Policy. In summary: active member records are retained for the duration of membership; alumni records are retained for seven (7) years post-membership-end then anonymised or deleted; we are required to retain certain financial records for at least six (6) years to comply with UK accounting and tax law. Members may request earlier erasure via the data subject rights process below.

In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work and our services.

6. 5a. What happens if there is a data breach?

If a personal data breach occurs, we assess the risk to your rights. Where the risk is more than minimal, we notify the ICO within 72 hours (Article 33 GDPR). Where the risk is high, we also notify you directly without undue delay (Article 34). We keep an internal breach register and run a root-cause review for every notifiable breach.

7. What are my rights under data protection law?

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This

enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any

incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal

data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to

  • Object to processing (see below), where we may have processed your information unlawfully or

where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those

of a third party) and there is something about your particular situation which makes you want to object  to  processing  on  this  ground  as  you  feel  it  impacts  on  your  fundamental  rights  and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the

processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a

third  party  you  have  chosen,  your  personal  data  in  a  structured,  commonly  used,  machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw

your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to lodge a complaint with us or the Information Commissioner's Office, the supervisory authority for data protection issues in England and Wales. If you are based in the EU you can find your relevant supervisory authority here.

Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.

8. Do we review this policy?

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.