Neptune Infrastructure Associates - Privacy Policy
Last updated: 20th November 2025
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We are the data controller and are responsible for certain personal data about you that we collect and use to supply you (“user”) with our services (as described on our website) (“Services”), or where you use or browse our platform or website (“Platform” and, together with the Services, the “Services”)).
We keep our privacy policy under regular review. The latest version will be posted on our website.
If you have any questions about this policy or about how we handle your data, please contact our data privacy team using the contact details set out below in Section 1.
1. Corporate Details & Contact Information
We are Neptune Infrastructure Associates Ltd (registered company number 14994741), our registered office address is at Festival House, Jessop Avenue, Cheltenham, England, GL50 3SH.
Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at info@neptune-infra.com.
2. Data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity and Contact details including your name, job title, company name and address, billing address, company phone number, and business email address.
- Financial & transaction information including credit card, debit card, and financial account numbers, payment card information, financial account information, transaction details, form of payment, payment confirmation and other payment details, information about the items you purchase and your past transactions.
- Account information including your username, password, security questions, preferences and settings.
- Profile information including your feedback, your preferences about your interest in our Services and Platform, chat history.
- Marketing information: includes your preferences in receiving marketing communications from us or third parties.
- Communications with us including the information you include in communications with us, for example, when sending a support inquiry.
- Technical and usage information including information about how you use our Services, IT, communication and other systems, your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
If any of the content that you upload into our Platform or share when using our Services contains personal data relating to third parties, we assume that you will either take steps to remove the personal data or that you have sought appropriate permission to use this information in this context.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have with you or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a Service you have purchased from us but we will notify you if this is the case at the time.
3. How We Collect Your Personal Data
We may collect personal information from the following sources:
- Directly from you including when you create an account, visit or use the Services, communicate with us, or otherwise provide us with your personal information;
- Automatically through the Services including from your device when you use our Services or visit our Platforms, and through the use of cookies and similar technologies;
- From our service providers including when we engage them to enable certain technology and when they collect or process your personal information on our behalf;
- From our partners or other third parties.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• In limited circumstances where you have given your consent.
Depending on how you interact with us, we may use personal information for the following purposes:
- To Provide, Deliver, and Improve the Services. This includes, using it to perform our contract with you, to administer and protect our business and Services, processing and fulfilling your orders and any payments, collecting and recovering money owed to us, supplying you with the Services, account creation and management, to communicate with you, to make recommendations to you, and to tailor and improve the Services.
- For Marketing and Advertising. This might include sending you marketing, advertising and promotional communications by email, text message or postal mail.
- Services. This might include adding your Contact data to our client database in order to facilitate the delivery of Services.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly.
When you first visit our website, you will see a cookie pop-up banner that allows you to accept, manage or decline cookies. Through this banner you can:
- Accept All Cookies. By clicking “Accept All” you consent to the use of all cookies, including those used for analytics, personalisation and advertising.
- Manage Preferences. By selecting “Manage Preferences” or a similar option, you can customise your cookie settings and choose which types of cookies you wish to enable or disable.
- Decline Non-Essential Cookies By declining or turning off certain categories (other than strictly necessary cookies), you can prevent our website from setting non-essential cookies on your device.
You may change your cookie preferences at any time by clicking the cookie settings link and adjusting your choices accordingly.
6. How We Disclose Personal Data
We may disclose your personal data to third parties for legitimate purposes, subject to this Privacy Policy including for the purposes set out in Section 4 (“How We Use Your Personal Data”).
Such circumstances may include:
- With third parties who perform services on our behalf (e.g. IT management, payment processing, data analytics, customer support, cloud storage, fulfilment and shipping).
- Marketing companies and online advertising – helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in, including management of email marketing operations and services that deploy advertising on the internet as well as analysis of the effectiveness of our advertising and communications campaigns.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
7. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage, and Profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products/services and offers may be relevant for you (we call this marketing).
If you are a user, you may receive marketing communications from us if you have consented for us to send you this information or if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by unsubscribing.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/ purchase, product experience or other transactions.
8. Third Party Websites and Links
The Platform and Services may include links to third-party websites (for example, a link to our members’ only Linkedin group), plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.
If you use any third party apps, websites or services to access our Services, your usage is subject to the relevant third party's terms and conditions, cookies policy, and privacy policy. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy policies of the relevant social media platform (Linkedin, etc.).
9. The Platform and Services are aimed at businesses, we do not knowingly collect children's data
The Services are not intended to be used by children, and we do not knowingly collect any personal information about children under the age of 16.
10. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available from us by contacting us.
12. International Transfers
We may transfer and process your personal data outside of the United Kingdom/European Union (EU) to countries where data protection laws are less stringent than those in the UK/EUIf we do transfer your personal data outside the UK/EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• Where we use certain service providers, we may use specific contracts approved for use in the UK/EU which give personal data the same protection it has in the UK/EU.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EU.
13. Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, these are summarised below.
- Right to Access. You may have a right to request access to personal information that we hold about you. This is commonly known as a “data subject access request”.
- Right to Correct. You may have a right to request that we correct inaccurate or incomplete personal information we maintain about you.
- Right to Delete. You may have a right to request that we delete personal information we maintain about you.
- Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
- Managing Communication Preferences. We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.
- Objection to Processing and Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information for certain purposes.
- Withdrawal of Consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent. If you withdraw your consent, this will not affect the lawfulness of any processing based on your consent before its withdrawal.
If you wish to exercise any of these rights, please contact us. Please also note:
- You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
14. Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.