Privacy Policy

Effective Date: 19 June 2025
Last Updated: 18 June 2025

This Privacy Policy explains how Willow & Bean Co. Ltd, trading as BeanSecure.net (“We”, “Us”, “Our”), collects, uses, processes, and protects your personal data when you visit our website at BeanSecure.net (the “Website”) or use any of our services, including the AXIS AI system, Professional Services, and the ‘Individual Assist’ tool (collectively, the “Services”).

We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy is designed to be compliant with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Important Information and Who We Are

Data Controller: Willow & Bean Co. Ltd Company Number: 16128200 Registered Office: Bartle House, 9 Oxford Court, Manchester, M2 3WQ Contact Email: [email protected]

For any questions about this Privacy Policy or our data protection practices, please contact us using the details above.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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, username or similar identifier, marital status, title, date of birth, and gender.
• Contact Data: Includes billing address, email address, and telephone numbers.
• Financial Data: Includes bank account and payment card details (note: we do not directly store full payment card details; these are handled by secure third-party payment processors).
• Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us.
• 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, and other technology on the devices you use to access this Website.
• Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data: Includes information about how you use our Website and Services.
• Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Service-Specific Data (Confidential Information): This refers to the information, queries, and data that You submit to the AXIS System or provide during the course of Professional Services. We treat this data as strictly confidential.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3. How is Your Personal Data Collected?

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

• Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
  • Apply for our products or services.
  • Create an account on our Website.
  • Subscribe to our services or publications.
  • Request marketing to be sent to you.
  • Give us feedback or contact us.
  • Submit queries or data to the AXIS System or provide information during Professional Services.
• Automated technologies or interactions: As you interact with our Website, we will automatically collect Technical Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for more details.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google.
  • Contact, Financial and Transaction Data from providers of technical, payment, and delivery services.
  • Identity and Contact Data from publicly available sources such as Companies House.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Confidentiality and Use of Service-Specific Data (AXIS and Professional Services)

We treat all information, queries, and data that You submit to the AXIS System or provide during the course of Professional Services as strictly confidential. We will not use any of your confidential data to train our artificial intelligence models or for any purpose other than providing the Services directly to you, unless we have obtained your explicit, prior written consent. All data is processed in accordance with the security and confidentiality obligations set out in this Privacy Policy.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes stated in the table in Section 4 above.

• Internal Third Parties: Other companies within the Willow & Bean Co. Ltd group acting as joint controllers or processors who provide IT and system administration services and undertake reporting.
• External Third Parties:
  • Service providers acting as processors who provide IT and system administration services, payment processing, and website hosting.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Specific Service Providers for Professional Services: Where you engage us for Professional Services, we may, with your explicit consent or where necessary for the performance of the service, share relevant data with trusted third-party experts (e.g., cybersecurity specialists, external legal counsel) strictly on a need-to-know basis and under confidentiality agreements.

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 do not generally transfer your personal data outside the UK or the European Economic Area (EEA).

Should it become necessary to transfer your data outside the UK/EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the UK Government or European Commission which give personal data the same protection it has in the UK/EEA.
• Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Data Privacy Framework or UK Extension to the EU-US Data Privacy Framework, which require them to provide similar protection to personal data shared between the UK/EU and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

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 procedures in place 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

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.

• For account data, we will retain your data for as long as your account is active and for a period thereafter to deal with any queries or legal obligations.
• For Professional Services data, we retain data for the duration of the engagement and for a statutory period thereafter (e.g., 6 years for contract retention in the UK).
• Data submitted to the AXIS System for information purposes (not for training models) is retained for operational purposes and then securely deleted or anonymised.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include 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 to continue 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

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. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

11. Changes to the Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on 19 June 2025.

We may make changes to this policy from time to time. When we do, we will update the “Effective Date” at the top of this policy and post the revised policy on our Website. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

© Willow & Bean Co. Ltd | 2025