Privacy Policy

1. Who We Are

CompanyPulse is operated by Interlink Digital Group Limited ("we", "us", "our"). We are the data controller for personal information processed through this website.

2. What Data We Process

We process two distinct categories of personal data:

2.1 Your Account Data

If you register for an account, we collect:

• Account data: name, email address, hashed password
• Usage data: pages visited, searches performed, IP address, browser type
• Cookie data: essential session cookies for authentication

2.2 Public Register Data (Third-Party Personal Data)

CompanyPulse displays information about company officers, directors, and persons with significant control (PSCs) sourced from the Companies House public register - a statutory register maintained under the Companies Act 2006.

This data is obtained via the Companies House API and Bulk Data Products, and is used under the Open Government Licence v3.0. The categories of personal data we display include:

• Name and role (e.g. director, secretary, PSC)
• Appointment and resignation dates
• Partial date of birth (month and year only - we do not hold or display full dates of birth)
• Nationality and country of residence
• Occupation
• Company associations (which companies a person is or was an officer of)
• Service address (the correspondence address filed at Companies House - we do not hold or display residential addresses)

We do not collect this data directly from the individuals concerned. It is filed with Companies House by the companies themselves, as required by law.

3. How We Use Your Data

3.1 Account Data

• To provide and maintain our service
• To manage your account and authentication
• To improve our platform and user experience
• To communicate service updates (with your consent)

3.2 Public Register Data

• To promote transparency in UK corporate governance
• To enable businesses and individuals to conduct due diligence
• To support anti-fraud and anti-money laundering efforts
• To provide company risk analysis and financial intelligence

4. Legal Basis (UK GDPR)

4.1 Account Data

• Contract - Article 6(1)(b): necessary to provide you with our service
• Legitimate interest - Article 6(1)(f): to improve our platform and prevent fraud
• Consent - Article 6(1)(a): for marketing communications

4.2 Public Register Data

• Public interest - Article 6(1)(e): republishing data from a statutory public register that is required by law to be openly accessible (Companies Act 2006, ss.1085-1087)
• Legitimate interest - Article 6(1)(f): enabling business transparency, due diligence, and informed commercial decisions. We have conducted a legitimate interest assessment and concluded that the public benefit of accessible company data outweighs any privacy impact, given that this data is already publicly available on the statutory register.

5. Public Register Data and Erasure Requests

We understand that individuals may wish to have their personal data removed from our website. However, the right to erasure under Article 17 UK GDPR is subject to important exemptions.

Article 17(3)(b) provides that the right to erasure does not apply where processing is necessary "for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest."

The data we display about company officers and PSCs is required by the Companies Act 2006 to be publicly available on the Companies House register. We mirror this statutory public register data to promote corporate transparency. We are therefore unable to erase this data in response to Article 17 requests.

5.1 What We Do Not Hold

• Residential addresses: The Companies House API provides only the service (correspondence) address filed by the company. We do not hold or display home addresses.
• Full date of birth: We display month and year only, consistent with what Companies House makes publicly available via its API.

5.2 Address Suppression for Personal Safety

If you believe that the display of your service address puts you or someone you live with at risk of violence or intimidation, you may apply directly to Companies House for address suppression under section 1088 of the Companies Act 2006. If Companies House suppresses your address, the change will be reflected on CompanyPulse when we next update our records.

Applications can be made at: gov.uk - Apply to remove your home address (form SR01)

5.3 Correcting Inaccurate Data

If any data displayed about you is inaccurate, the correction should be filed with Companies House, as they are the authoritative source. Once corrected on the register, our records will be updated accordingly. You can file corrections at gov.uk - File changes to a company.

6. Data Retention

• Account data: retained for as long as your account is active, plus 30 days after deletion request
• Usage logs: retained for 90 days
• Audit logs: retained for 24 months
• Public register data: retained for as long as the data remains on the Companies House register. Records of dissolved companies and resigned officers are retained for historical transparency, consistent with Companies House's own retention practices.

7. Your Rights

Under UK GDPR, you have the following rights in relation to your account data:

• Access (Article 15): request a copy of all personal data we hold about you
• Rectification (Article 16): correct any inaccuracies in your account data
• Erasure (Article 17): request deletion of your account and associated data
• Restriction (Article 18): request we limit how we process your data
• Portability (Article 20): receive your data in a structured, machine-readable format
• Object (Article 21): object to processing based on legitimate interest

Registered users can exercise these rights via the Privacy Dashboard in their account settings.

In relation to public register data, the right to erasure is subject to the exemption in Article 17(3)(b) as described in Section 5 above. You retain the right to object under Article 21, however we may demonstrate compelling legitimate grounds for continued processing that override your interests, given the statutory nature of the source data.

8. Cookies and Advertising

We use essential cookies for authentication and session management. We also use Google AdSense to display advertisements, which sets cookies to serve relevant ads based on your browsing activity. For full details of the cookies we use and how to opt out of personalised advertising, see our Cookie Policy.

Google's use of advertising cookies is governed by its own Privacy Policy. You can opt out of personalised ads via Google Ads Settings.

9. Contact

For privacy enquiries: privacy@companypulse.co.uk

If you are unsatisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk/make-a-complaint
• Telephone: 0303 123 1113