Privacy Policy

We are committed to safeguarding the privacy of our website visitors and service users.  Therefore, we set out in this privacy policy our position regarding certain privacy matters and the use of cookies on this Website.

Please read this privacy policy carefully.

1. Definitions

1.1  “Data” refers to collectively all information that you submit to Congeniality whether directly via the website, via email or in person.

1.2  “Data Protection Laws” means any and all applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46 EC (Data Protection Directive) or the GDPR, and any implementing laws, regulations and secondary legislation for as long as the GDPR is effective in the UK.

1.3  “GDPR” refers to the General Data Protection Regulation (EU) 2016/679

1.4   Congeniality, we or us” refers to Congeniality, a company incorporated in England and Wales (Registration Number 10032591).

1.5  “Website” refers to the website that you are currently using,, and any related or sub-domains unless expressly excluded by their own terms and conditions.

2. Scope of this Privacy Policy

2.1  This privacy policy applies only to the actions of Congeniality and Users with respect of this Website. It does not extend to any third-party websites that can be accessed from this Website including, but not limited to any links to affiliates and service providers and social media websites.

2.2  For the purposes of the applicable Data Protection Laws, Congeniality is the “data controller.”  This means that Congeniality determines the purposes and means for which, and the manner in which, your Data is processed.

3. How we collect data

3.1  Data is given to us by you whey you contact us through the Website, by telephone, post, e-email or through any other means; 

3.2  Data is collected automatically to the extent that you access the Website.  

4. How we use the Data

4.1  We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.

4.2  We may process your account data (“account data”). The account data may include your name, address, telephone number and email address.

4.3  We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include event attendance record, purchase patterns and preferences.

4.4  We may process information that you post for publication on our website or through our services (“publication data”).

4.5  We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”).

4.5  We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, referral contact, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer.

4.7  We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details.

4.8  We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.

4.9  We may process information contained in or relating to any communication that you send to us] (“correspondence data”). The correspondence data may include [the communication content and metadata associated with the communication.

4.10  In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary[ for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4.11  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4.12  The Data collected may be processed for the purposes of analysing the use of the website and services.  The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

5 How we secure the Data

5.1  We will use technical and organisational measures to safeguard your Data, for example:

  • Access to your account is controlled by a password and a username that is unique to you
  • We store your Data on secure servers.

5.2  Technical and organisational measures include measures to deal with any suspected data breach.  If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address:

6 Data retention

6.1  Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfill the purposes outlined in this privacy policy or until you request that the Data be deleted.

6.2  Even if we delete your Data, it may persist on backup archival media for legal, tax and regulatory purposes.

7 Your rights

7.1  You have the following rights in relation to your Data:

  • Right to access – the right to request (1) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information.  If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.”  Where we are legally permitted to do so, we may refuse your request.  If we refuse your request, we will tell you the reasons why.
  • Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
  • Right to erase –the right to request that we delete or remove your data from our systems.
  • Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
  • Right to data portability – the right to request that we move copy or transfer your Data.
  • Right to object – the right to object to our use of your Data including were we use it for our legitimate interests.

7.2 You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

7.3  To make inquiries, exercise any of your rights set out above, or withdraw your consent to the processing or your Data (where consent is our legal basis for processing your data), please contact us via this e-mail address:

7.4  If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner (ICO).  The ICO’s contact details can be found in the website at

7.5  It is important that the Data we hold about you is accurate and current.  Please keep us informed if your Data changes during the period for which we hold it.​

8 Links to other websites

8.1  This Website may, from time to time, provide links to other websites.  We have no control over such websites and are not responsible for the content of these websites.  This privacy policy does not extend to your use of such websites.  You are advised to read the privacy policy or statement of other websites prior to using them.

9 Change of business ownership and control

9.1  Congeniality may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Congeniality. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

9.2  We may also disclose Data to a prospective purchaser of our business or part of it.

9.3  In the above instances, we will take steps with the aim of ensuring your privacy is protected.

10 Modifications

10.1  We may update this policy from time to time by publishing a new version on our website.

10.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

10.3  We may notify you of changes to this policy by email or through the private messaging system on our website.

11 Jurisdiction and Waiver

11.1  If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of the privacy policy will not be affecred.

11.2  Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

11.3  This Agreement will be governed by and interpreted according to the law of England and Wales.  All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts

12 Our details

12.1  This website is owned and operated by Congeniality Limited.

12.2  We are registered in England and Wales under registration number 10032591.

12.3  Our registered address is at 71-75 Shelton Street, London WC2H 9JQ , United Kingdom.

12.4  You can contact us: