Privacy Policy

1. Who we are

Origentry provides business research and managed outreach services to specialist UK commercial lenders.

Origentry is the trading name of Mahdi Hussein, operating as a sole trader.

Email: support@origentry.com

This policy explains how we handle personal information about website visitors, people who contact us, client and supplier representatives, campaign senders and business contacts included in our research or outreach.

We are the data controller when we decide why and how personal information is used, including for our business administration, enquiries, our own marketing and independently determined research. Where we process information solely on a client’s documented instructions, we act as their processor. The client’s privacy information also applies to that processing.

2. Information we handle

Depending on your interaction with us, this may include:

• Identity and business details: name, role, employer, business contact details and professional profile information.
• Enquiries and bookings: messages, meeting details, preferences and information you provide about your business or requirements.
• Business research: publicly available information about a person’s business role, ownership or directorships, relevant business activity, research sources and assessments of possible business relevance.
• Campaign information: sender details, account-connection information needed for agreed services, messages, replies, communication history, campaign activity and contact preferences.
• Business administration: contract, invoice and payment records, supplier details and correspondence.
• Website information: IP address, browser and device details, access logs and usage information, depending on the technologies in use.

We do not ask for sensitive personal information for ordinary enquiries or prospect research. Please avoid sending information we do not need.

3. Where information comes from

We obtain information directly when you contact us, book a meeting, communicate with us or take part in a campaign.

We may also obtain relevant business information from:

• Clients, their participating team members and business referrals.
• Companies House, business websites, LinkedIn professional profiles, published business news and announcements.
• Business-information and contact-research providers.
• Our website and the services used to operate it.

Where we obtain your information indirectly, we identify the specific source or sources in the privacy information provided to you where known. This may be in our communication with you or accompanying information. Public availability does not remove your data-protection rights.

4. Why we use information and our lawful bases

Where we act as controller, our purposes and lawful bases are:

When relying on legitimate interests, we consider the necessity of the processing and its impact on your rights and reasonable expectations.

Where we act as a processor, the client determines the purposes and lawful basis, and we process information under its documented instructions and the applicable data-processing agreement.

You do not have to make an enquiry or book a meeting. If you withhold information needed to answer a request or provide an agreed service, we may be unable to do so. Any contractual requirement to provide information is explained when relevant.

5. Marketing and your right to object

We may contact relevant business representatives about Origentry’s services or communicate with business contacts on behalf of a campaign client, subject to applicable marketing rules. We obtain consent where the law requires it.

You can object to direct marketing at any time. Reply to the relevant message or email support@origentry.com. We will stop the direct marketing covered by your objection, including related profiling.

We may retain the minimum information needed on a suppression list to prevent unwanted future contact. Opting out of marketing does not prevent necessary administrative or contractual communications.

6. Research tools and AI

We use research, software and AI-assisted tools to gather and organise business information, assess possible relevance, help prepare communications and administer campaign work.

Prospect selection, messages and campaign decisions are subject to human review. We do not make solely automated decisions that have legal or similarly significant effects on individuals, and we do not make lending or credit decisions. Relevant lenders make those decisions.

7. Who receives information

We share relevant information where needed for the purposes in this policy with:

• Campaign clients and their authorised teams, for agreed research, campaign management and the progression of relevant business conversations.
• Service providers, including website hosting and security, email and document storage, appointment booking, customer relationship management, business-information research, AI-assisted processing and LinkedIn outreach and campaign communications providers.
• Contractors and professional advisers, where needed for delivery, accounting, legal advice, insurance or dispute resolution.
• Authorities and other parties, where disclosure is legally required or necessary to protect rights or investigate misuse.
• Parties involved in a proposed business transfer, where necessary and subject to appropriate confidentiality arrangements.

Providers processing information on our behalf are subject to appropriate contractual requirements. Some recipients, such as lenders and professional advisers, may act as independent controllers for their own purposes.

We do not sell personal information as a standalone contact-list product or use confidential client campaign information for our own advertising.

For clarity, we do not use client or campaign data for advertising, we do not use it to train general-purpose AI models, and we share it with third parties only as needed to provide our services, to take professional advice, to protect our legal rights or where required by law.

8. International processing

We use service providers with operations in the UK and overseas. Personal information may be stored or accessed outside the UK, including in the European Economic Area and the United States, for website infrastructure, appointment booking, communications, document storage and related support services. Storage and support locations can differ.

Service-provider support and subprocessing may also involve other countries, depending on the service and its applicable arrangements. You can contact us for further information about the destinations and safeguards relevant to your information.

Where a restricted transfer takes place, the applicable protection is provided through:

• UK adequacy regulations, where the destination or receiving organisation is covered. This includes transfers to the European Economic Area and eligible US organisations covered by the UK Extension to the EU–US Data Privacy Framework.
• Appropriate contractual safeguards, where applicable, including the EU Standard Contractual Clauses together with the UK International Data Transfer Addendum, or the UK International Data Transfer Agreement.

The mechanism used depends on the recipient and the applicable provider agreement. You can request further information and a copy of relevant contractual safeguards by emailing support@origentry.com, with confidential material redacted where appropriate.

9. How long we keep information

We retain personal information only for as long as needed for its purpose, taking account of:

• Enquiries and business relationships: whether the enquiry remains active, the relationship continues or relevant follow-up is reasonably expected.
• Research and prospect records: whether the information remains accurate, relevant and necessary for an identified research or outreach purpose.
• Campaign records: the campaign lifecycle, reporting and handover needs, and the client’s documented retention or deletion instructions where we act as processor.
• Contracts, invoices and payments: applicable tax and accounting requirements and the periods relevant to establishing or defending legal claims.
• Suppression records: the need to continue honouring an objection and prevent recontact.
• Security logs: the time needed to detect, investigate and resolve technical or security issues.

Information may be kept longer where needed for an existing dispute or legal obligation. We review retention and delete or anonymise information when it is no longer needed. Residual backup copies are removed through the applicable backup cycle and are not used for routine business activity.

10. Security

We use technical and organisational measures appropriate to the information and risks involved, including access controls and limiting access to people who need it. No online system can guarantee absolute security.

11. Cookies and similar technologies

We do not set cookies or use local storage, session storage, tracking pixels or device fingerprinting on this website.

Our hosting services may still process technical information, such as IP addresses and access logs, to deliver and secure the website, as described elsewhere in this policy.

When you follow a booking link, you leave our website and use an external booking service. That service may use its own cookies and similar technologies. Its privacy and cookie information is available on its booking pages.

12. Your rights

Depending on the circumstances, you may have rights to:

• Access your personal information and obtain a copy.
• Correct inaccurate or incomplete information.
• Request erasure or restriction of processing.
• Object to processing based on legitimate interests, including direct marketing.
• Receive and transfer certain information in a portable format where the legal conditions apply.
• Withdraw consent where processing relies on it, without affecting earlier lawful processing.

To exercise a right, contact support@origentry.com. We may request reasonable information to verify your identity or clarify your request. Requests are normally handled without charge and without undue delay, within one month, subject to legally permitted extensions, pauses or exceptions. We explain any applicable limitation.

Where we hold information solely on a client’s behalf, we assist the relevant controller with your request. You can contact us if you need help identifying them.

13. Questions and complaints

For a privacy question or complaint, email support@origentry.com, explaining your concern and how we can contact you.

We acknowledge data-protection complaints within 30 days, investigate without undue delay, keep you appropriately informed and communicate the outcome.

You also have the right to complain to the Information Commissioner’s Office (ICO):

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

You do not have to obtain our permission to contact the ICO.

14. Changes to this policy

We may update this policy as our services or legal obligations change. The latest version and update date appear on this page. Where required, we provide additional information or obtain consent before using information for a new purpose.