Privacy Policy

PRIVACY NOTICE & PRIVACY POLICY

This privacy policy sets out how Forefront Initiative Limited (hereafter referred as “Forefront”, “we” or “our”) uses and protects your personal data.

1. Important information and who we are Privacy policy

This privacy policy gives you information about how Forefront Initiative Limited collects and uses your personal data through your use of this website, including any data you may provide when you register with us or sign up to our newsletter or purchase our service.

Controller

Forefront is the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact the us using the information set out in the contact details section (paragraph 10).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.

• Photography & Video data includes your image, appearance, voice, or likeness ("Media") via photographs or video recordings during property site visits, events, meetings, or on our premises.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.

• Usage Data includes information about how you interact with and use our website, products and services.

• Marketing and Communications Data includes your navigation on our website and preferences in receiving marketing from us and our third parties and your communication preferences.

We do not directly engage in community or children-focused activities. However, we may collaborate with third-party organisations (“Third Parties”) who conduct such activities, for example, workshops in our gallery and premises. These partners are responsible for their own privacy policies and compliance. We do not store or process personal data collected by these partners. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you:

• apply for our services;

• subscribe to our service or publications;

• register for our events;

• request marketing to be sent to you;

• enter a promotion or survey; or

• give us feedback or contact us.

• Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

• Promotional events: We may take photographs and videos of attendees at our events to promote our events and services which may include posting on social media platforms like Instagram, Facebook, publishing on our website, and inclusion in press releases or other marketing materials. By participating in our events, you consent to our use of Media free of charge, worldwide, and in perpetuity. You waive any right to approve specific uses or claim compensation. We may maintain visitor logs for security and operational purposes. These logs could include personal details such as name, contact information, and, where demographics are requested, potentially sensitive data like age or ethnicity. We only collect such data when necessary and in compliance with applicable data protection laws. If you register for an event, your name and contact details may be included on an invite list. These lists may be shared with partner or collaborator organisations involved in hosting the event. We ensure that any sharing is limited to what is necessary for event coordination and that partners adhere to appropriate data protection standards.

• Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data is collected from the following parties:

• analytics providers such as Google based outside the UK;

• advertising networks; and

• search information providers.

• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services and from third-party credit check providers.

• Identity and Contact Data is collected from data brokers or aggregators.

• Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

We may have to share your data with third parties, including but not limited to third-party service providers such as GoDaddy, CPanel, other entities in the group, our legal advisers, and other professional advisers.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.

4. How we use your personal data Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Since the personal data also includes photographs and videos and because individuals are identifiable in these images, this processing is considered personal data. We rely on our legitimate interests as the lawful basis, which allows us to use attendee images for marketing and promotional purposes. We ensure that this is done fairly and transparently.

• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You have the right to opt out of receiving promotional communications at any time by following the opt- out links on marketing material or by contacting us by post or email by contacting us at hello@forefront.place (see ‘How to contact us’).

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.

5. Disclosures of your personal data

We may share your personal data where necessary with third parties.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal dat.

7. Data security

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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about you (including contact, identity and financial details) for legal, regulatory and tax purposes. Please see below confirming our retention periods:

Accident books, reports and records — 6 years from the date of the last entry (if an accident relates to a child or young adult — until that person reaches 21 years)

Application forms and interview notes for unsuccessful candidates — 3 months from the date such candidate is unsuccessful.

Other HR records — 2 years

Your personal information such as your name, age, date of birth, bank information, address, telephone numbers, and personal email addresses — 6 years or a date you notify us in writing to delete your data in accordance with this Privacy Policy, whatever comes earlier.

Your navigation history on our website and purchase history — 3 years or a date you notify us in writing to delete your data in accordance with this Privacy Policy, whatever comes earlier.

Financial/Accounts records — 6 years

Application forms, CVs and interview notes for unsuccessful candidates — 3 months from the date such candidate is unsuccessful

Marketing — 3 years unless you ‘opt out’ of the marketing material or exercise your right to withdraw in accordance with this policy.

Complaints records — 1 year from the conclusion of the complaint

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. Once you are no longer contractor or engaged by Forefront we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• Request the transfer of your personal information to another party. If you want to review, verify correct or request erasure of your personal information, object to the processing of your personal data, or request that we keep a copy of your personal information to another party, please contact hello@forefront.place

If you wish to exercise any of the rights set out above, please contact us. See Contact details (paragraph 10).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure

that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: hello@forefront.place

• Postal address: The Old Rectory, 29 Martin Lane, London EC4R 0DJ

• Telephone number: +44(0)207 078 8087

11. Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). You can contact them via: Website: www.ico.org.uk; Telephone: 0303 123 1113

However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. You can email your concerns at hello@forefront.place

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on November 2025.

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, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.