Privacy Policy

1. About this privacy policy

This privacy policy explains how Argo Natural Resources Limited, trading as DEScycle ("DEScycle", "we", "us" or "our"), collects and uses personal information when you visit www.descycle.com, contact us, engage with us in a business or professional capacity, or otherwise interact with our website and related communications.

We are the controller of the personal information described in this policy. This means that we decide why and how that information is used. This policy is intended to provide the privacy information required under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Data (Use and Access) Act 2025 and the Privacy and Electronic Communications Regulations 2003 (PECR), in each case as amended.

Our website is primarily an informational and business-to-business website. Separate privacy terms may apply where we enter into a contract, run a project, conduct recruitment or operate a service that has its own privacy notice.

2. Who we are and how to contact us

The controller is:

• Legal name: Argo Natural Resources Limited, trading as DEScycleCompany number: 11151531
• Registered in: England and Wales
• Registered office: Lynton House, 7-12 Tavistock Square, London, WC1H 9BQ, United Kingdom
• Email: info@descycle.com

Please use the subject line “Data protection” for privacy enquiries or “Data protection complaint” if you wish to make a complaint about our use of personal information.

3. The personal information we collect

Depending on how you interact with us, we may collect and use the following categories of personal information:

• Identity and professional information, such as your name, job title, employer or organisation, professional role and professional profile information.
• Contact information, such as your business or personal email address, telephone number, postal address and communication preferences.
• Enquiry and correspondence information, including information you submit through our contact form, emails, messages, meeting requests, feedback and records of our communications with you.
• Business relationship information, such as your organisation’s interests, potential projects, partnership or supplier discussions, meetings, event attendance and relevant relationship history.
• Technical and usage information, such as your internet protocol (IP) address, device identifiers, browser type and version, operating system, time zone, referring website, pages viewed, interactions, access times, diagnostic information and security logs.
• Cookie and preference information, including cookie choices, consent records and information generated by cookies or similar storage and access technologies.
• Marketing information, including whether you have asked to receive or stop receiving news, event invitations or other business communications from us.
• Compliance and legal information, where necessary to meet legal obligations, investigate security issues, prevent fraud, establish or defend legal claims or respond to lawful requests.

We do not intend to collect special category information (such as health, biometric, religious or political information) or criminal offence information through the website. Please do not include this type of information in a general website enquiry. If it is necessary for us to use such information in a specific context, we will identify an additional lawful condition and provide any further privacy information required.

4. How we collect personal information

We collect personal information:

• Directly from you, when you complete the website contact form, email or call us, meet us, attend an event, subscribe to communications, provide a business card or otherwise communicate with us.
• Automatically, when you use the website, through server logs, cookies and similar technologies, subject to your choices and applicable law.
• From your organisation or professional contacts, where they introduce you or provide your details for a legitimate business purpose.
• From publicly available and professional sources, such as company websites, professional networking platforms, trade publications, conference materials and public registers, where appropriate for business development, due diligence or relationship management.
• From service providers and partners, where they support our website, communications, events, security, business operations or projects and are permitted to provide the information to us.

5. How and why we use personal information

UK data protection law requires us to have a lawful basis for each purpose for which we use personal information. The bases most relevant to our website and business communications are legitimate interests, steps taken at your request before entering into a contract, performance of a contract, consent and compliance with a legal obligation.

Purpose: Operate and secure the website

How we use information: Provide website functionality; monitor availability and performance; diagnose faults; protect systems, information and users; prevent misuse and investigate incidents.

Lawful basis: Our legitimate interests in operating a secure and effective website; compliance with legal obligations where applicable.

Purpose: Respond to enquiries

How we use information: Receive, route, assess and respond to contact form submissions, emails, meeting requests and other communications.

Lawful basis: Steps taken at your request before a contract; performance of a contract; or our legitimate interests in managing enquiries and business relationships.

Purpose: Develop and manage business relationships

How we use information: Discuss potential projects, partnerships, investment, supply arrangements, trials, collaborations and other professional opportunities; maintain relationship records and follow up appropriately.

Lawful basis: Our legitimate interests in developing and managing DEScycle’s business; steps before a contract; or performance of a contract.

Purpose: Business communications and events

How we use information: Send relevant company news, event invitations and professional communications; measure engagement where permitted; maintain opt-out records.

Lawful basis: Consent where required; otherwise our legitimate interests in relevant business-to-business communications, subject to PECR and your right to object.

Purpose: Understand and improve the website

How we use information: Analyse aggregated or individual usage, test content and functionality, understand audiences and improve communications.

Lawful basis: Consent for non-essential storage or access technologies where required; otherwise our legitimate interests where the activity is lawful and proportionate.

Purpose: Compliance, claims and corporate administration

How we use information: Keep records; meet legal, tax, audit, regulatory and governance requirements; conduct due diligence; prevent fraud; manage disputes; establish, exercise or defend legal claims; support a financing, reorganisation, investment, sale or other corporate transaction.

Lawful basis: Compliance with legal obligations and our legitimate interests in protecting and administering our business.

Where we rely on legitimate interests, we consider the purpose, necessity and impact on the individual, including whether the use is reasonably expected in the context of a professional or business relationship. You may ask us for further information about a relevant assessment.

We will not use personal information for a materially incompatible purpose without providing further information and identifying an appropriate lawful basis.

6. Business communications and direct marketing

We may send you relevant DEScycle news, event invitations or business communications where you have requested them, consented where consent is required, or where applicable law permits us to contact you on another basis.

For business-to-business communications, the PECR rules differ depending on whether the recipient is a corporate subscriber or an individual subscriber, which can include sole traders and some partnerships. We will apply the rule relevant to the recipient and the communication channel. In all cases, you can ask us to stop marketing at any time by using an unsubscribe mechanism or contacting info@descycle.com.

If you opt out, we may retain limited contact information on a suppression list so that we can respect your choice. Opting out of marketing does not prevent us from sending necessary service, project, contractual, regulatory or other non-marketing communications.

7. Cookies and similar technologies

Our website may use cookies, pixels, scripts, local storage and similar technologies that store information on, or access information from, your device. Some are necessary for the website to operate, maintain security or remember a service you request. Others may support analytics, embedded content, functionality or communications measurement.

We use non-essential technologies only where you have given valid consent, unless another statutory exception applies. You can accept, reject or manage non-essential technologies through the website’s consent tool and can change your choices later. Refusing non-essential technologies should not prevent access to the core website.

Our Cookie Policy and consent tool should identify the technologies in use, their providers, purposes and durations. The Cookie Policy must be kept aligned with the website’s actual configuration.

8. When we share personal information

We may share personal information where reasonably necessary with:

• Website hosting, content management, cloud, communications, analytics, security, customer relationship management and other technology providers that process information for us.
• Professional advisers, including lawyers, accountants, auditors, insurers, consultants and corporate finance advisers.
• Project partners, research organisations, funders, suppliers, prospective customers or counterparties where sharing is necessary for a relevant discussion, project, application, due diligence process or contract and is lawful.
• Companies within any DEScycle group structure, where required for administration, security, finance, governance or the relevant business purpose.
• Regulators, courts, law enforcement, government bodies and other authorities where required by law or reasonably necessary to protect rights, safety or security.
• Actual or prospective investors, buyers, sellers, lenders, funders or transaction advisers in connection with a financing, investment, reorganisation, merger, acquisition, asset sale or similar corporate transaction, subject to appropriate confidentiality and data protection measures.

We do not sell personal information. We require service providers acting as processors to protect personal information and use it only on documented instructions, subject to applicable law.

9. International transfers

Some service providers, partners or recipients may be located outside the United Kingdom, or may access personal information from another country. Where this results in a restricted international transfer, we will use a lawful transfer mechanism and take any additional measures required by UK data protection law.

Depending on the destination and recipient, this may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, another approved safeguard, or a permitted exception. Where required, we will assess whether the transfer provides the legally required standard of protection.

You may contact us for further information about the safeguard relevant to your personal information, subject to confidentiality and legal restrictions.

10. 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 to meet legal, accounting, reporting, security and claims requirements. Retention can vary according to the nature of the information and relationship.

As a general guide:

• General website enquiries are normally retained for up to 24 months after the enquiry is resolved or the last substantive contact, unless a longer period is justified by an ongoing relationship, legal requirement or dispute.
• Business relationship and project records may be retained for the duration of the relationship and, where necessary, for up to six years afterwards to manage obligations and legal claims.
• Marketing contact records are retained while communications remain relevant and permitted. We periodically review inactive records. Suppression records may be retained for longer so that we can respect opt-outs.
• Technical and security logs are retained for periods appropriate to operational and security needs, normally no longer than 12 months unless needed to investigate an incident or meet a legal requirement.
• Data protection rights requests and complaints may be retained for up to six years after closure to demonstrate compliance and manage claims.
• Cookie and similar technology durations are described in the Cookie Policy and consent tool.

We may retain anonymised or aggregated information that no longer identifies an individual for research, statistics, reporting or business analysis.

11. Security

We use appropriate technical and organisational measures designed to protect personal information against unauthorised or unlawful use, accidental loss, destruction or damage. Measures may include access controls, authentication, secure configuration, encryption where appropriate, backups, supplier controls, staff confidentiality and incident management.

No internet transmission or information system is completely secure. You should avoid sending sensitive or confidential information through a general website form unless we have agreed an appropriate secure method.

12. Your data protection rights

Depending on the circumstances, you may have the right to:

• Be informed about how your personal information is used.
• Request access to your personal information and receive a copy of it.
• Ask us to correct inaccurate or incomplete personal information.
• Ask us to erase personal information in certain circumstances.
• Ask us to restrict the use of personal information in certain circumstances.
• Object to processing based on legitimate interests, including an absolute right to object to direct marketing.
• Receive certain information in a structured, commonly used and machine-readable format, or ask us to transfer it, where the right to data portability applies.
• Withdraw consent at any time where we rely on consent. Withdrawal does not affect processing that was lawful before withdrawal.
• Complain to us and to the Information Commissioner’s Office.

These rights are not absolute and exemptions may apply. We may need to verify your identity and clarify your request. We will not normally charge a fee, but the law permits a reasonable fee or refusal in limited circumstances.

13. Automated decision-making

We do not currently use information collected through the website to make decisions about individuals based solely on automated processing that produce legal or similarly significant effects. We will provide additional information if this changes.

14. Children

The website is intended for professional and general informational audiences and is not directed at children. We do not knowingly collect personal information from children through the website. If you believe a child has provided personal information to us, please contact us so that we can assess and, where appropriate, delete it.

15. Data protection complaints

You can make a data protection complaint directly to us by emailing info@descycle.com with the subject line “Data protection complaint”, or by writing to our registered office. Please describe the issue, relevant dates, the information involved and the outcome you are seeking. We may ask for proportionate information to verify identity or authority where necessary.

We will acknowledge a data protection complaint within 30 days of receiving it, investigate without undue delay, keep you appropriately informed and tell you the outcome. You may also complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. The ICO can be contacted through www.ico.org.uk or by telephone on 0303 123 1113.

We encourage you to contact us first so that we have an opportunity to address the issue, but this does not affect your right to contact the ICO.

16. Third-party websites and services

The website may contain links to third-party websites, platforms, embedded content or services. Those parties may collect and use personal information under their own terms and privacy notices. We do not control their privacy practices and encourage you to review the relevant information before providing personal data or enabling third-party content.

17. Changes to this policy

We may update this policy to reflect changes in law, regulatory guidance, our business or the website. We will publish the updated version on the website and change the “Last updated” date. Where a change materially affects how we use personal information, we will take additional steps to bring it to the attention of affected individuals where required.

18. Contact

For privacy questions, rights requests or complaints, contact:

• Email: info@descycle.com
• Post: Data Protection, DEScycle, Lynton House, 7-12 Tavistock Square, London, WC1H 9BQ, United Kingdom