Privacy Notice – 5 Circles Limited
Effective date: 18 October 2026
Last updated: 18 October 2026
Data controller: 5 Circles Limited
ICO registration number: ZC024865
Registered office: 23 Frosterley Drive, Great Lumley, County Durham, DH3 4SJ
Companies House number: 16746844
Privacy contact: Maxine Fox
Email: maxine@5circles.co.uk
Telephone: 07852 955800
1. About this privacy notice
5 Circles Limited is a UK business consultancy. When we decide why and how personal information is used, we act as the data controller. This notice explains what personal information we collect, how and why we use it, who we share it with, how long we keep it and the rights available to you under UK data protection law.
This notice applies to clients, prospective clients, suppliers, business contacts, event attendees, website visitors and other people who interact with us. It does not form part of any contract.
2. Personal information we collect
Depending on how you interact with us, we may collect:
· identity and contact details, including your name, job title, organisation, postal address, email address and telephone number;
· business and professional information, including your role, business interests, requirements and relevant professional background;
· contract and transaction information, including services requested or provided, correspondence, invoices and payment records;
· communications and meeting information, including emails, enquiry details, notes and feedback;
· marketing preferences, including whether you wish to receive updates and how you prefer us to contact you; and
· technical and usage information, such as IP address, browser type, device information and website activity where collected through cookies or similar technologies.
We do not intentionally collect special category information or criminal-offence information unless it is necessary, lawful and you have been given additional information about the processing.
3. How we collect personal information
We collect information directly from you when you contact us, complete a form, attend an event, engage us, correspond with us or use our website. We may also receive information from your organisation, professional contacts and referrals, service providers, event partners, and publicly available sources such as company websites, Companies House and professional networking platforms.
Where we obtain your information from another source, we will provide privacy information within the period required by law unless an exemption applies.
4. How we use your information and our lawful bases
We use personal information only where the law allows us to do so:
· Enquiries and relationship management: to respond to enquiries, discuss potential work and manage business relationships. We rely on steps taken at your request before entering a contract and our legitimate interests in developing and operating our consultancy.
· Providing services: to agree, deliver and administer consultancy services. We rely on performance of a contract or steps taken before entering a contract.
· Administration and finance: to manage contracts, invoices, payments, records and business operations. We rely on contract, legal obligations and our legitimate interests in running the business and recovering sums due.
· Legal and regulatory compliance: to meet tax, accounting, data protection and other legal duties, and to establish, exercise or defend legal claims. We rely on legal obligations and, where relevant, legitimate interests.
· Service improvement and security: to improve our services and website, maintain systems, prevent misuse and protect our business. We rely on our legitimate interests in operating securely and effectively; where consent is legally required for cookies or similar technologies, we rely on consent.
· Marketing: to send relevant business updates, invitations and information about our services. We rely on consent where required by the Privacy and Electronic Communications Regulations 2003, or on legitimate interests where permitted, while respecting your right to object.
Where we rely on legitimate interests, we consider whether the processing is necessary and balance our interests against your rights and reasonable expectations. You may ask us for further information about this assessment.
5. When information must be provided
Some information is required so that we can enter into or perform a contract, issue invoices, receive payment or meet legal obligations. If you do not provide information that we reasonably need, we may be unable to respond fully, provide services or continue a business relationship. We will explain any specific requirement and the likely consequences at the time.
6. Sharing personal information
We may share personal information, where necessary, with service providers that support our business, such as IT, cloud storage, website hosting, email, customer relationship management, payment, accounting and professional advisory providers. We may also share information with event or delivery partners, your organisation or authorised representatives, regulators, public authorities, courts, law-enforcement bodies, prospective purchasers of our business, or others where required or permitted by law.
Service providers acting on our behalf may use personal information only for agreed purposes and must protect it appropriately. We do not sell personal information.
7. International transfers
Some suppliers may store or access personal information outside the United Kingdom. Before making a restricted transfer, we use a lawful transfer mechanism and other safeguards as required. These may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another lawful exception. Where required, we also carry out a transfer risk assessment. You may contact us for further information about safeguards relevant to your information.
8. How long we keep personal information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, tax, contractual and reporting requirements. In deciding retention periods, we consider the amount, nature and sensitivity of the information, the risk of harm, the purpose of processing, whether the purpose can be achieved in another way and applicable legal requirements.
· Client, contract, transaction and accounting records are generally retained for up to six years after the end of the relevant relationship or financial period, unless a longer period is required.
· Unsuccessful enquiries and proposals are retained only for a reasonable follow-up period.
· Marketing records are retained while you remain subscribed and as necessary to maintain a suppression record if you opt out.
· Cookie and analytics information is retained for the periods stated in our cookie information or consent tool.
Information may be retained for longer where needed for a dispute, legal claim, investigation or legal obligation.
9. Marketing and cookies
You can ask us to stop direct marketing at any time by using an unsubscribe option or contacting us. An objection to direct marketing will not affect service or other non-marketing communications. We may keep minimal information on a suppression list so that we can respect your choice.
Our website may use necessary cookies and, where selected, analytics or other optional technologies. We provide clear information about the technologies used, their purposes, providers and duration through our cookie notice or consent tool. We ask for prior consent where required, and you can change or withdraw your choices at any time. Withdrawing consent does not affect processing carried out before withdrawal.
10. Security
We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure. Access is limited to people and suppliers who need it for legitimate business purposes and who are subject to confidentiality and security obligations. We hold Cyber Essentials certification and monitor our security controls.
11. Your data protection rights
Depending on the circumstances, you may have the right to:
· ask for access to your personal information;
· ask us to correct inaccurate or incomplete information;
· ask us to erase information;
· ask us to restrict how information is used;
· object to processing based on legitimate interests and object at any time to direct marketing;
· receive information you provided in a structured, commonly used and machine-readable format, and ask us to transfer it where technically feasible;
· withdraw consent at any time where processing is based on consent; and
· not be subject to a decision based solely on automated processing that produces legal or similarly significant effects, subject to legal exceptions.
These rights are not absolute and exemptions may apply. We may need to verify your identity before responding. We do not charge a fee in most cases and normally respond within one month, although the law allows more time in certain circumstances.
We do not currently use personal information to make solely automated decisions that have legal or similarly significant effects.
12. Contact and complaints
To ask a question, exercise a right or raise a concern, contact Maxine Fox at maxine@5circles.co.uk or telephone 07852 955800. We would welcome the opportunity to resolve your concern.
You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection. Visit https://ico.org.uk for current contact details. 5 Circles Limited is registered with the ICO.
13. Changes to this notice
We review this notice regularly and may update it to reflect changes in our activities or the law. The current version will be made available on our website. If we plan to use personal information for a materially different purpose, we will provide appropriate information before doing so.