Privacy and Cookies Policy

Last updated: June 2026

This privacy policy applies between you, the User of this Website and Phi Technology Solutions Limited (Iris 360), the owner and provider of this Website. Iris 360 takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This privacy policy should be read alongside, and in addition to, our Terms of Use.

Please read this privacy policy carefully.

Definitions and interpretation

In this privacy policy, the following definitions are used:

In this privacy policy, unless the context requires a different interpretation: the singular includes the plural and vice versa; references to sub-clauses, clauses, schedules or appendices are to those of this privacy policy; a reference to a person includes firms, companies, government entities, trusts and partnerships; “including” is understood to mean “including without limitation”; reference to any statutory provision includes any modification or amendment of it; and the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of Iris 360 and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Iris 360 is the “data controller”. This means that Iris 360 determines the purposes for which, and the manner in which, your Data is processed.

Data collected

We may collect the following Data, which includes personal Data, from you:

• name;
• job title;
• profession;
• contact information such as email addresses and telephone numbers;
• IP address (automatically collected);
• web browser type and version (automatically collected);
• operating system (automatically collected);
• a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

in each case, in accordance with this privacy policy.

How we collect data

We collect Data in the following ways: data is given to us by you; and data is collected automatically.

Data that is given to us by you

Iris 360 will collect your Data in a number of ways, for example:

• when you contact us through the Website, by telephone, post, e-mail or through any other means;
• when you register your interest, request early access, or sign up to receive updates or our products/services;
• when you use our services;

in each case, in accordance with this privacy policy.

Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

• we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content;
• we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below headed “Cookies”.

Our use of data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

• internal record keeping;
• improvement of our products/services;
• transmission by email of marketing materials that may be of interest to you;
• contact for market research purposes, which may be done via email, telephone or mail; such information may be used to customise or update the Website;

in each case, in accordance with this privacy policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft opt-in: soft opt-in consent applies when you have previously engaged with us (for example, you contact us for more details about a particular product/service and we are marketing similar products/services); under soft opt-in consent, we will take your consent as given unless you opt out. For other types of e-marketing, we are required to obtain your explicit consent. If you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time (see “Your rights” below).

Who we share data with

We may share your Data with the following groups of people for the following reasons:

• any of our group companies or affiliates — to improve and ensure proper administration of our website and business;
• our employees, agents and/or professional advisors — to improve and ensure proper administration of our website and business;
• third-party service providers who process Data on our behalf under contract — for example our forms and CRM provider, HubSpot;

in each case, in accordance with this privacy policy.

Keeping data secure

We will use technical and organisational measures to safeguard your Data, for example: storing your Data on secure servers, and controlling access to any account through a password and user name unique to you. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss of, or unauthorised access to, your Data, please let us know immediately by contacting us at info@iris-360.co.uk.

For detailed information from Get Safe Online on how to protect your information and your devices against fraud, identity theft, viruses and other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

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 fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

You have the following rights in relation to your Data:

• Right to access — to request copies of the information we hold about you, or that we modify, update or delete such information. We will not charge you for this unless your request is “manifestly unfounded or excessive”. Where legally permitted, we may refuse your request, and if we do we will tell you the reasons why.
• Right to correct — to have your Data rectified if it is inaccurate or incomplete.
• Right to erase — to request that we delete or remove your Data from our systems.
• Right to restrict our use of your Data — to “block” us from using your Data or limit the way in which we can use it.
• Right to data portability — to request that we move, copy or transfer your Data.
• Right to object — to object to our use of your Data, including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights, or withdraw your consent to the processing of your Data (where consent is our legal basis), please contact us at info@iris-360.co.uk. If you are not satisfied with the way a complaint you make is handled, you may refer it to the Information Commissioner’s Office (ICO), whose contact details are at ico.org.uk. It is important that the Data we hold about you is accurate and current; please keep us informed if your Data changes.

Links to other websites

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

Changes of business ownership and control

Iris 360 may, from time to time, expand or reduce our business, and this may involve the sale and/or transfer of control of all or part of the business. Data provided by Users will, where relevant to any part of the 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. We may also disclose Data to a prospective purchaser of our business or any part of it. In each case, we will take steps with the aim of ensuring your privacy is protected.

Cookies

This Website may place and access certain Cookies on your computer. Iris 360 uses Cookies to improve your experience of using the Website and to improve our range of services. Iris 360 has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Iris 360 to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following Cookies:

You can choose to enable or disable Cookies in your internet browser. By default, most browsers accept Cookies, but this can be changed; please consult the help menu in your browser. You can delete Cookies at any time, but you may lose information that enables you to access the Website more quickly and efficiently. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org.

General

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. 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 deleted, and the validity and enforceability of the other provisions will not be affected. 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. This privacy policy will be governed by and interpreted according to the law of England and Wales, and all disputes arising under it will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

Iris 360 reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website, and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

Phi Technology Solutions details

• Phi Technology Solutions Limited is a company incorporated in England and Wales.
• Company registered number: 16191210
• Registered address: Chertsey House, 61 Chertsey Road, Woking, Surrey, GU21 5BN
• Operates the website iris-360.co.uk
• Email: info@iris-360.co.uk
• Phone: 01932 972100 (group line — confirm)
• ICO registration: [ICO registration reference — to confirm]

Cookies schedule

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think we have missed a cookie or there is any discrepancy, please let us know.