Effective Date: January 5, 2026 | Version: 1.0

Privacy Policy

1. Introduction

Neuvantage Business Services Limited ("we", "our", or "us") is the data controller responsible for your personal data. We are dedicated to acting as the "Regulatory Shield" for our clients, treating your data with the same rigour and precision that we apply to our Operational Profit Architecture services.

As a Member in Practice regulated by the Chartered Institute of Management Accountants (CIMA), we adhere to strict ethical codes regarding confidentiality and professional behaviour. This policy details how we collect, use, store, and protect your personal data when you visit our website, undergo a PROFIT-ABILITY™ Audit, or engage our services.

2. The Data We Collect

We collect and process different kinds of personal data to deliver our financial and operational services. We have grouped these as follows:

• Identity Data: First name, last name, username or similar identifier, title, date of birth, and gender.
• Contact Data: Billing address, delivery/operational site address, email address, and telephone numbers.
• Financial Data: Bank account details, payment card details, and granular business financial records (Profit & Loss, Balance Sheets, Cash Flow Forecasts) required for our Dynamic Liquidity Models.
• Operational Data: Employee performance metrics, process workflow data, and internal error rates collected during the PROFIT-ABILITY™ Diagnostic or Audit phases.
• Compliance & ID Data (Mandatory): Passport copies, driving licences, and proof of address documents. Note: As a supervised entity, we are legally mandated to collect this for "Know Your Customer" (KYC) and Anti-Money Laundering (AML) checks.
• Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, and browser plug-in types.

3. How We Collect Your Data

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

• Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms on our website (e.g., the Fuel Efficiency Calculator), engaging in the PROFIT-ABILITY™ Diagnostic, or by corresponding with us by post, phone, email, or via our Google Spaces project management channels.
• Automated Technologies: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns.
• Third Parties & Public Sources: We may receive personal data about you from sources including:
  • Companies House (for corporate structure verification).
  • Trusted Partners (such as payroll or tax compliance providers) where you have authorised a "One-Stop Shop" engagement.
  • Sanctions lists (HM Treasury) for regulatory checks.

4. How We Use Your 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:

A. Performance of a Contract

• To register you as a new client.
• To deliver our core services: Operational Profit Architecture, Waste Audits, Cash Flow Certainty modelling, and Pricing Strategy implementation.
• To process and collect payments for our fees.

B. Legal Obligation

• Anti-Money Laundering (AML): To verify the identity of Persons with Significant Control (PSC) and screen against sanctions lists before engagement.
• Reporting: To comply with CIMA regulations and, where necessary, report to authorities such as the National Crime Agency (NCA) under the Proceeds of Crime Act 2002.

C. Legitimate Interests

• To use data analytics (via Looker Studio) to improve our website, products/services, marketing, and customer relationships.
• To manage our relationship with you, including notifying you about changes to our terms or privacy policy.

5. Data Sharing & Disclosure

We may share your personal data with the parties set out below. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

• Trusted Partners: Specific third-party service providers (Payroll, Tax, HR) whom we introduce to handle compliance tasks outside our Management Accounting scope. We do not white-label; these relationships are transparent.
• Technology Providers: We utilise the Google Workspace Ecosystem (Drive, Sheets, AppSheet, Looker Studio) as our secure operating system. Data is processed securely within this infrastructure.
• Professional Advisers: Lawyers, bankers, auditors, and insurers.
• Regulators: CIMA, HM Revenue & Customs (HMRC), and other authorities.

6. International Transfers

Our primary operating environment is the Google Cloud Platform. While we are UK-based, data processed via Google Workspace may be stored on servers located outside the UK. We ensure your personal data is protected by requiring all our service providers to follow the same rules when processing your personal data, utilising UK-approved International Data Transfer Agreements (IDTA) or ensuring adequacy decisions are in place.

7. Data Security (The "Digital Vault")

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way.

• Access Control: We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.
• Encryption: We utilise industry-standard encryption for data at rest and in transit within our Financial Cockpit ecosystem.
• Incident Response: We have put in place procedures to deal with any suspected personal data breach and will notify you and the ICO 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 necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• Client Files: By law, and in accordance with CIMA guidelines, we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
• Clean Exit Protocol: Upon termination of a contract, we execute our "Clean Exit" protocol. We revoke our access to your systems and transfer an "Exit Pack" of your data back to you. We do not retain "ghost access" to your banking or operational platforms.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data (a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data (Note: We may not always be able to comply due to AML record-keeping requirements).
• Object to processing of your personal data.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.