Privacy Policy

Last updated: 30.10.2019

INTRODUCTION LTD and its group companies and affiliates (hereinafter – “” or “we”) understand that You are aware of and care about Your personal data protection, and we take that seriously. This Privacy Policy forms an integral part of the Terms & Conditions and describes policies and practices regarding our collection and use of Your personal data, as well as sets forth Your privacy rights. We recognise that personal data protection is an ongoing responsibility, and we may from time to time update this Privacy Policy, as we undertake new personal data processing practices.

“You” in this Privacy Policy may refer to a visitor of our Website (hereinafter – “Visitor”), a company including any shareholders, beneficial owners, principals, directors, and staff members accessing our Website (hereinafter – “Company”), or a customer of a Company (hereinafter – “Customer”). “Visitor” may include “Company” and/or “Customer” where appropriate. We will do our best to clarify who we are referring to at various points in this Privacy Policy.


Personal data:

We may collect and process the following personal data about You:

  1. Information that You as a Visitor, Company or Customer provide by using our website (hereinafter – the “Website”). Such information may include Your name, surname, e-mail address, telephone number and the name of Your company;
  2. Information and documentation that You as a Company provide to us in order to conclude an agreement. Such information may include, but is not limited to, Your name, telephone number, e-mail address, company name, company number and current position;
  3. Information and documentation that You as a Visitor provide to us during the process of applying for a job vacancy. Such information may include Your name, date of birth, home address, country, telephone number, e-mail address, company name, current position, previous places of employment, education and other information which You provide;
  4. A record of correspondence/communication and/or the telephone call in the event You contact us. Such record may include Your name, surname, e-mail address, telephone number, name of Your company and other personal data You may disclose to us during such communication;
  5. Where You as a Company or Customer have been granted access to the Website Tools – your name, surname, physical address, telephone number, e-mail address, details of Your visits, including, but not limited to, location data, weblogs, other communication data and the resources that are accessed by You;
  6. Where You as a Company or Customer use the Website Tools,– Your personal data, including, but not limited to, name, surname, e-mail address, telephone number, details regarding whether Your payment has been successful or not and payment history;
  7. Information about You as a Company or Customer, which we receive from other sources, including, but not limited to, our business partners, service providers and subcontractors. Such information may include the data provided by payment service providers and other third parties, as well as publicly available information. It may also include information about You as a Customer which we receive from the Company, including Your name, surname, physical address and e-mail address.

Other data:

We may also collect non-personal information about You, which does not identify You as a specific individual. Such non-personal information that we may collect includes:

  1. Browser and device data, for instance, IP address, operating system and browser type. This is statistical data about the Website users' browsing actions and patterns and does not identify any individual;
  2. Cookie data, such as time spent on the Website, pages visited, language preferences, and other anonymous traffic data;
  3. Company data, such as a company’s name, product and service offerings, jurisdiction.


We use Your personal data, in the capacity of a Company, in order to conclude contracts and carry out our contractual obligations. In this regard, we rely on a contract entered into by You and as the valid ground for the processing of Your personal data.

We use Your personal data to enable You, in the capacity of a Customer, to use the Website Tools and make payments for the services provided by the Company. In this regard, we rely on the legitimate interests pursued by us, and the Terms and Conditions entered between You and us.

We may also process Your personal data in situations, where we are required to comply with legal obligations.

Examples of how we may use Your personal data include:

  • to register and authenticate you on our Website;
  • to offer You personalised Website Tools;
  • to provide You with information regarding our Website Tools;
  • to notify You about changes to our Website Tools;
  • to ensure that content from the Website is presented in the most effective manner and to keep our Website safe and secure;
  • to administer our Website;
  • to verify Your identity for legal/regulatory compliance purposes;
  • to respond to Your inquiries and provide customer support.


We will store Your personal data for the period necessary to fulfil the purposes listed above, unless a longer retention period is required or permitted by law. Please be aware that we may be required to retain Your personal data for various legal or regulatory reasons. This means that in the event where You, in the capacity of a Company or a Customer, cease to make use of our Website or Website Tools, we will still retain certain personal data in order to carry out our legal obligations.


The Website and Website Tools are not intended for persons under the age of sixteen and we kindly ask such persons to not disclose their personal data to us.


In certain circumstances we may disclose the personal data we have gathered about You to the following categories of recipients:

  • The recipient of the payment/invoice issuer. We disclose payer data to the recipient of the payment/invoice issuer to comply with the contractual obligations between the recipient of the payment/invoice issuer and You as his client. Please note that your personal data is processed in parallel in accordance with the privacy policy of your particular recipient of the payment/invoice issuer;
  • Our group companies. In order to provide our services to You as a Company and the Website Tools to You as a Company or Customer, we share personal data with our group companies;
  • Third-party financial institutions. This may include credit/financial institutions;
  • Third-party service providers. We disclose personal data to our service providers only when it is necessary to ensure the provision of our services to You as a Company and the Website Tools to You as a Company or Customer, including, but not limited to processing of payments/transactions;
  • Third parties in relation to transfer of business. For instance, if we sell any business or assets or merge with another business entity, it may be necessary to disclose personal data to the prospective business owners or partners;
  • Third parties in relation to a legal obligation or if we are permitted to do so by law. In certain circumstances we may be under an obligation to disclose or share Your personal data with auditors, regulatory authorities or law enforcement bodies in order to comply with a legal obligation. We may also disclose personal data, if it is permitted by law, in order to enforce or apply the Terms and Conditions or other agreements or to protect our rights, property, customers or others.

Your personal data may be transferred to and processed at a destination outside the European Economic Area (hereinafter – “EEA”). It may also be processed by staff operating outside the EEA who work for our service providers. Where such transfers of personal data take place, we have ensured that appropriate safeguards are in place, in order to ensure that Your personal data is treated in a secure manner and in line with this Privacy Policy.


You have certain rights in respect to the way we treat Your personal data:

  • You are entitled to access Your personal data and receive information regarding Your personal data that we process. You can do so by either signing in to Your Personal Office account or by contacting us at;
  • You are entitled to rectify the information we have about You if it is inaccurate. You can do so by either signing in to Your Personal Office account or by contacting us at;
  • You are entitled to object to the processing of Your personal data;
  • You have the right to revoke Your consent for processing of Your personal data in situations, where such processing is based on Your consent;
  • You may also request us to erase Your personal data or cease the processing of Your personal data. However, please note that this right may be subject to certain exemptions. Namely, in situations, where we are under a legal obligation to retain Your personal data, we will not be able to fulfil Your request and, in such an event, we will inform You accordingly;
  • You may also request us to provide Your personal data to You or transmit it directly to another controller and we will comply with such request, provided that the personal data processing previously carried out by us was based on Your consent or was necessary for the performance of a contract and where it is technically feasible;
  • You have the right to lodge a complaint to the Information Commissioners’ Office if You believe that we have not complied with the requirements of the General Data Protection Regulation with regard to Your personal data.


The Website uses cookies to distinguish You from other Visitors of the Website. This helps to provide You with a good experience while browsing the Website, and also allows us to improve the Website.

A cookie is a small text file saved by a website to Your computer or mobile device when You open the Website. We use third-party cookies, such as Google Analytics.

You have the right to decline the collecting and use of specific information about You through our use of cookies when You visit the Website. Your browser may communicate a refusal to receive certain kinds of cookies. Please note that You may be unable to use all the advantages of the Website without cookies.


All information provided by You to us is stored on secure servers and we use appropriate organisational, technical and administrative measures to protect Your personal data. Once Your information is received, we use strict procedures and security features to prevent any unauthorised access. However, please note that no transmission of information via the internet is completely secure and no storage system is guaranteed to be entirely secure. If You have any reason to believe that Your interaction with us is no longer secure, please contact us immediately.


We may change or update this Privacy Policy. Any changes we may make to this Privacy Policy in the future will be posted on the Website and any such changes will be effective starting from the date when we post the revised Privacy Policy.

We may provide You with notifications regarding the changes in the Privacy Policy by posting them on our Website.


We have appointed a data protection officer, whom You may contact, should You have any questions or concerns regarding our personal data processing practices. Our data protection officer’s contact information is as follows:


If You wish to contact us regarding this Privacy Policy, please use the e-mail address or the following address: LTD
85 Great Portland Street,
London, England,