PRIVACY POLICY

Captive Seven Ltd.

Last Updated: [14/02/2025]

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 1.⁠ ⁠Introduction

Captive Seven Ltd. (“Full Spoon”, “we”, “us”, “our”) is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store and protect personal data when you:

• Visit our website

• Book consultations

• Purchase services through the platform

• Register as a specialist

• Contact us

• Subscribe to updates

We act as a Data Controller for customer and specialist data collected through our platform.

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 2.⁠ ⁠Who We Are

Captive Seven Ltd.

Company Number: 08602416

Email: hello@fullspoon.co.uk

For all data protection queries, please contact:

hello@fullspoon.co.uk

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 3.⁠ ⁠The Data We Collect

We may collect and process the following personal data:

A. Customer Data

• Full name

• Email address

• Telephone number

• Business name

• Billing address

• Payment details (processed via secure third-party provider)

• Consultation notes (where relevant)

• Communication records

B. Specialist Data

• Full name

• Company name (if applicable)

• Registered address

• Email address

• Telephone number

• Bank details (for payout purposes)

• Professional credentials

• Availability

• Service descriptions

• Performance metrics (booking volume, reviews etc.)

C. Technical Data

• IP address

• Browser type

• Device information

• Cookies and usage data

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 4.⁠ ⁠How We Collect Your Data

We collect data when you:

• Fill in forms on our website

• Book consultations

• Subscribe to updates

• Apply as a specialist

• Contact us by email

• Use our platform services

We may also collect data automatically via cookies.

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 5.⁠ ⁠Legal Basis for Processing (GDPR Article 6)

We process personal data under the following lawful bases:

A. Contractual Necessity

To:

• Facilitate bookings

• Process payments

• Administer specialist agreements

• Deliver platform services

B. Legitimate Interests

To:

• Improve our services

• Maintain platform security

• Manage specialist performance

• Prevent fraud

C. Legal Obligation

To:

• Comply with HMRC and regulatory requirements

• Maintain financial records

D. Consent

For:

• Marketing communications

• Non-essential cookies

You may withdraw consent at any time.

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 6.⁠ ⁠How We Use Your Data

We use personal data to:

• Operate and manage the Full Spoon platform

• Facilitate bookings between clients and specialists

• Process payments and distribute specialist earnings

• Provide customer support

• Maintain service quality standards

• Send service-related communications

• Send marketing communications (if opted in)

• Comply with legal and regulatory obligations

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 7.⁠ ⁠Payments & Financial Data

Payments are processed securely via third-party providers (e.g., Stripe).

Full Spoon does not store full card details.

As a platform acting as an agent, we collect customer payments and distribute earnings to specialists, deducting the agreed platform fee.

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 8.⁠ ⁠Data Sharing

We may share data with:

• Specialists (for booked consultations)

• Payment processors

• Accountants and legal advisors

• Hosting providers

• IT service providers

• Regulatory authorities where required

We do not sell personal data.

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 9.⁠ ⁠International Transfers

If we transfer data outside the UK or EEA, we ensure:

• Adequacy decisions apply; or

• Standard Contractual Clauses (SCCs) are in place; or

• Equivalent safeguards are implemented.

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10.⁠ ⁠Data Retention

We retain personal data:

• For the duration of your relationship with Full Spoon

• For 6 years for accounting and legal compliance (UK requirement)

• Until you request deletion (where legally permissible)

Consultation notes may be retained for business continuity and dispute protection.

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11.⁠ ⁠Data Security

We implement appropriate technical and organisational measures, including:

• Secure hosting

• Encrypted communications (SSL)

• Restricted access controls

• Password protection

• Secure payment processing

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12.⁠ ⁠Your Rights Under GDPR

You have the right to:

• Access your data

• Rectify inaccurate data

• Request erasure (“right to be forgotten”)

• Restrict processing

• Object to processing

• Data portability

• Withdraw consent

• Lodge a complaint with the ICO

UK Supervisory Authority:

Information Commissioner’s Office (ICO)

www.ico.org.uk

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13.⁠ ⁠Cookies

We use cookies to:

• Ensure website functionality

• Analyse traffic

• Improve performance

You can manage cookie preferences via your browser settings.

A separate Cookie Policy may apply.

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14.⁠ ⁠Marketing Communications

We will only send marketing emails where:

• You have opted in; or

• We have a lawful soft opt-in (existing business relationship).

You may unsubscribe at any time.

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15.⁠ ⁠Children’s Data

Our services are not directed at individuals under 18 years of age.

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16.⁠ ⁠Changes to This Policy

We may update this Privacy Policy periodically.

The latest version will always be published on our website.