Third Party Data Privacy Notice

This Data Privacy Notice explains how Complexio Limited (“Complexio”, “we”, “us”, or “our”) collects, uses, and processes personal data about employees and personnel of suppliers, customers and business partners.

1. Processing of personal data

Personal data we process

As part of our communication and interaction with you — whether as an employee or personnel working for a customer, business partner, supplier, or other business contact — Complexio collects and processes personal data about you for the purpose of administering our relationship with the company you represent or work for and/or you.

Legal basis

Fulfilment of agreement. To fulfil the agreement between the company you work for (or you) and Complexio, we may collect and process the following personal data:

  • Name and contact information, including email address and phone number

  • Title and job function and workplace/company name

Legitimate interest. For the purpose of administering our relationship with you or the company you
work for, Complexio may also process personal data based on our legitimate interest. This may
include the same categories of data listed above, as well as:

  • Records of correspondence and communication history

  • Information relevant to the delivery of services or products

  • Email metadata (sender, recipient, timestamps, subject lines) and email content (body text) including communication patterns; and

  • Relevant email attachments.

Source of your personal data

We generally receive your personal data directly from you through emails, meetings, phone calls, or other correspondence, or from the company you represent.

AI System Data Processing

Complexio operates an AI-powered system designed to optimise business processes, improve operational efficiency, and provide business insights. The processing of personal data through the Complexio AI system is carried out on the basis of legitimate interest — to deliver and improve the AI-powered services we provide, where it is assessed that Complexio’s interest in processing overrides your interest because processing is limited to company email that you can reasonably expect to be analysed and appropriate technical and organisational safeguards protect your privacy.

Third parties with whom we share personal data

Complexio will generally not share your personal data with third parties. However, your personal data may be processed by our technology service providers and platform partners acting under our instruction and in accordance with appropriate data processing agreements.

Data retention

Complexio will retain your personal data for as long as we maintain a relationship with you and thereafter for as long as there is a legitimate purpose for keeping it, including where we are required by applicable law to retain the data.

2. Transfer of data outside of the EU/EEA

To the extent personal data is processed by our technology service providers, clients and/or counter parties that are established outside of the EU/EEA, such transfer will be subject to the EU-Commission’s standard contractual clauses.

3. Your Rights

  • Under the GDPR, you have the following rights regarding your personal data:

  • Right to information and access — you have the right to access and obtain information on the personal data Complexio processes and stores about you

  • Right to rectification and restriction — you may request correction of inaccurate or incomplete personal data or to restrict the processing of your personal data.

  • Right to data portability — you may request to receive your personal data in a structured ,commonly used, machine-readable format

  • Right to object — you may object to processing by sending an email to us

  • Right to erasure – you may request that Complexio delete personal data we hold about you where it is no longer necessary for the purposes for which it was collected.

To exercise any of these rights, please contact us by sending an email to dataprotection@complexio.com. Please note that some rights may be subject to conditions and limitations under applicable law.

You also have the right to lodge a complaint with your local supervisory authority if you believe that our processing of your personal data does not comply with applicable data protection law.

4. Contact Information

Complexio Ltd is the data controller for the personal data described in this notice. Our contact details are:
Complexio Limited
First Floor, 5 Fleet Place
London EC4M 7RD
United Kingdom
Email: dataprotection@complexio.com