PRIVACY POLICY

This Privacy Policy explains how we collect, use, store, and protect personal data collected through our digital advertisements, validation campaigns, and service channels.

Until a Limited (LTD) company is formally incorporated and assumes responsibility for the operations described in this Privacy Policy, the Data Controller is Jaspreet Bains, trading as DirectElectricians, operating as an individual trader in the United Kingdom.

Contact Email: contact@direct-electricians.com

Following incorporation, the relevant LTD entity will become the Data Controller where it assumes responsibility for the processing described in this Privacy Policy. This Privacy Policy will be updated accordingly.

This Privacy Policy applies to individuals whose personal data we collect during our pre-launch operational testing, regional advertising, and intake verification activities.

This includes:

• Authorised representatives, directors, or employees of corporate Electrical Contracting Companies ("Clients").
• Individual electricians, tradespeople, or technicians submitting enquiries ("Candidates").
• Visitors interacting with our Meta advertisements, Meta Lead Forms, landing pages, or Calendly scheduling links.

We collect and process personal data that is reasonably necessary for the purposes described in this Privacy Policy, including evaluating commercial interest and testing our upcoming electrotechnical matching marketplace.

3.1 Electrical Contracting Companies (Clients)

We may collect:

• Identity and Contact Data: Full name, business email address, corporate telephone number, and official job title.
• Corporate Specifications: Company name, registered company number where applicable, workforce size, regional project locations, and labour requirements.
• Scheduling Data: Appointment details, time zones, and booking notes provided through our third-party scheduling interface.

3.2 Individual Electricians (Candidates)

We may collect:

• Identity and Contact Data: Full name, mobile telephone number, personal email address, and general geographic area or postcode.
• Professional Information: Certification tiers, reported Joint Industry Board (JIB) / Electrotechnical Certification Scheme (ECS) registration card status, trade specialisms such as commercial, industrial, solar, or EV installation, and current professional availability.

We do not intend to collect special-category personal data through our standard intake forms. If you voluntarily provide information that falls within a special category of personal data, we will assess the applicable legal requirements before processing it.

We obtain your personal data directly from you when you voluntarily provide information through our Meta Lead Forms, landing-page contact fields, or Calendly scheduling links.

During this market-validation phase, we do not intentionally obtain personal data from third-party data brokers or external public registries.

We process personal data for the following commercial and operational purposes:

• To coordinate, schedule, and conduct professional demos to assess corporate project criteria or candidate suitability.
• To contact you before a scheduled demo, including by telephone, SMS, or email, where reasonably necessary to confirm your details, understand your requirements, verify that the demo is appropriate for your circumstances, or determine whether our services are relevant to you.
• To gauge regional market demand and understand local labour availability.
• To validate and develop our planned software-based matching platform.
• To build and maintain an internal registry of interested contractors and tradespeople prior to formal platform deployment.
• To communicate with you regarding an enquiry, demo, or other service interaction you have requested.
• To comply with applicable legal and regulatory requirements where necessary.

We will not use your personal data for materially different purposes without providing appropriate privacy information or obtaining consent where required.

Depending on the circumstances and the purpose of processing, we may rely on the following lawful bases under the UK GDPR:

Legitimate Interests — Article 6(1)(f)

We may rely on legitimate interests where necessary to communicate with business representatives, administer business enquiries, understand market demand, and develop and validate our commercial matching service.

Where we rely on legitimate interests, we will consider whether the processing is necessary and whether our interests are appropriately balanced against your rights and freedoms.

Consent — Article 6(1)(a)

Where required, we rely on your freely given, specific, informed, and unambiguous consent to collect and use personal data for specified purposes, including certain marketing communications or other processing activities where consent is specifically required.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

We conduct direct marketing in accordance with the Privacy and Electronic Communications Regulations ("PECR") and applicable UK data-protection law.

We distinguish between operational communications and direct marketing.

Operational communications may include appointment confirmations, responses to enquiries, pre-demo confirmation calls, demo information, or other communications reasonably necessary to provide a service or respond to a request you have made.

Direct marketing includes promotional communications about our services, platform, opportunities, or related commercial activities.

Corporate Subscribers

Where permitted by PECR, we may send direct marketing by electronic mail to corporate subscribers, including limited companies and other corporate bodies, without obtaining prior consent.

Such communications will identify us as the sender and provide a valid mechanism for opting out or unsubscribing. Where personal data relating to an identifiable individual is processed, the UK GDPR will also apply.

Individual Subscribers and Sole Traders

Sole traders and certain partnerships are treated as individual subscribers under PECR.

We will only send promotional electronic marketing to individual subscribers where we have the required consent or another applicable legal basis permitted by PECR, including where the statutory soft opt-in requirements are satisfied.

All marketing communications will clearly identify us as the sender and provide a clear and functional mechanism to opt out or unsubscribe.

You may object to direct marketing at any time.

We do not sell your personal data.

We may share personal data with trusted third-party service providers that process information on our behalf and are necessary to operate our digital validation pipeline. These may include:

• Cloud infrastructure and database providers used to securely host and store personal data.
• Communication and messaging providers used to send operational communications or, where lawfully permitted, marketing communications.
• Scheduling service providers, including Calendly, used to manage demo bookings.
• Advertising and technology providers, including Meta, where necessary to operate our advertising, lead-generation, measurement, or related digital services.

Where appropriate, we require service providers processing personal data on our behalf to provide appropriate contractual and security protections.

We do not share candidate professional credential information with clients, or client project information with candidates, unless there is a lawful basis to do so and, where appropriate, the relevant individual has been informed or has provided the required authorisation.

Our validation campaigns may use Meta Lead Forms, advertising tools, tracking technologies, and related services provided by Meta Platforms Ireland Limited ("Meta").

Depending on the specific processing involved, Meta may act as an independent controller or joint controller in relation to certain processing activities associated with Meta Lead Forms and advertising. Meta processes information in accordance with its own applicable privacy and data policies.

Once personal data is transferred to us, we process that data in accordance with this Privacy Policy and applicable UK data-protection law.

For coordinating and booking our demos, we utilise processing tools provided by Calendly LLC. When you choose to schedule a demo, your name, contact methods, and calendar metadata are processed through Calendly to populate our scheduling diary and arrange the requested communication.

Pre-Demo Confirmation

Where you request or schedule a demo, we may contact you before the scheduled demo by telephone, SMS, or email to confirm the information you have provided, clarify your requirements, confirm that you appear to be an appropriate participant for the demo, or determine whether the demo is relevant to your circumstances.

This may involve asking brief questions about your business, project requirements, trade experience, availability, location, or other information relevant to the purpose of the demo.

Where we determine that a demo is not appropriate or relevant, we may cancel or decline the appointment and will handle your personal data in accordance with this Privacy Policy and applicable data-protection law.

When you visit our landing pages or interact with our Calendly booking links, basic cookies, pixels, or local storage technologies may be deployed by third-party platforms, such as Meta or Calendly, to monitor ad conversion performance, measure ad traffic, or manage web session states.

Where required, we will implement an appropriate consent mechanism, such as a compliant cookie banner, on our digital touchpoints to ensure users can actively control, accept, or decline non-essential tracking and advertising technologies in accordance with applicable PECR requirements.

While our primary databases are configured to prioritise hosting within the United Kingdom or the European Economic Area (EEA), certain third-party cloud applications and ad platforms, such as Meta or Calendly, may process, transmit, or store personal data across international borders, including to the United States.

Where restricted international transfers occur, they will be governed by an applicable lawful transfer mechanism recognised under UK data-protection law. Depending on the circumstances, this may include UK adequacy regulations, the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or another applicable safeguard.

We retain your personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Unless a longer period is required or permitted by law, we intend to retain relevant commercial contact information and professional information for a maximum of 24 months from your last active interaction.

We may delete or anonymise information earlier where it is no longer reasonably required.

Where information must be retained for legal, regulatory, accounting, dispute-resolution, or other legitimate purposes, we may retain it for the period required for that purpose.

We maintain appropriate technical and organisational safeguards designed to protect your personal data from unauthorised access, accidental loss, alteration, misuse, or disclosure.

These measures include restricted internal database access permissions, multi-factor authentication (2FA) across applicable administrative cloud tools, and encryption of data in transit.

No method of electronic storage or transmission can be guaranteed to be completely secure.

Under the UK GDPR, you may have the following rights regarding your personal information, subject to statutory conditions, limitations, and exceptions:

• The Right to Access: You can request a copy of the personal data we hold about you.
• The Right to Rectification: You can request that we correct inaccurate or incomplete personal data.
• The Right to Erasure: You can request the erasure of your personal data where the legal requirements are met.
• The Right to Restriction: You can ask us to restrict processing activities under specific conditions.
• The Right to Object: You have the right to object to processing based on legitimate interests and have an absolute right to object to direct marketing.
• The Right to Data Portability: You can request the digital transfer of your personal data to another service provider where applicable.
• The Right to Withdraw Consent: Where processing relies on your consent, you can withdraw it at any time. The withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

To exercise any of these legal rights, please contact us directly using the contact details provided below.

We do not make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects on candidates or contracting firms during this validation phase.

If this changes as our matching platform develops, we will review our data-protection obligations and update this Privacy Policy where required.

If you have any questions or concerns regarding how we process your personal data, please contact us directly using the contact details provided below so that we can attempt to resolve your concern.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.

ICO website: https://ico.org.uk/

We reserve the right to update this Privacy Policy as our operations, services, technology, or legal obligations change.

Where appropriate, we will publish an updated version at this URL and revise the "Last Updated" date.

Following incorporation, the relevant LTD entity will become the Data Controller where it assumes responsibility for the processing described in this Privacy Policy. This Privacy Policy will be updated accordingly.

To exercise your legal rights or submit enquiries regarding this Privacy Policy, please contact:

Name: Jaspreet Bains trading as DirectElectricians

Email: contact@direct-electricians.com