Privacy Policy

About This Policy

This Privacy Policy describes the policies of Intentive Ltd, 4 Blacksmiths Lane, St. Albans, AL3 4SQ, United Kingdom ("Intentive", "we", "us", or "our"), on the collection, use, and disclosure of your information when you use our website (https://intentive.digital) or engage with our marketing services (the "Service").

By accessing or using the Service, you consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy. If you do not consent, please do not access or use the Service.

We may modify this Privacy Policy at any time. The revised Policy will be effective 180 days from when it is posted, and your continued use of the Service after that time constitutes your acceptance of the revised Policy. We recommend you periodically review this page.

Intentive is registered with the Information Commissioner's Office (ICO) as a data controller and data processor under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Information We Collect

We collect and process the following personal information about you:

• Name
• Email address
• Mobile phone number (where you provide this to receive SMS or RCS communications)
• Communication preferences and consent records
• Website usage data and behavioural analytics

We collect this information when you contact us, sign up to our newsletter, engage with our marketing services, or explicitly provide your mobile number to receive SMS or RCS messages from us.

How We Use Your Information

We use the information we collect about you for the following purposes:

• Marketing and promotional communications (email, SMS, and RCS — with your consent)
• Creating and managing user accounts
• Enforcing our Terms of Service
• Providing customer support
• Improving our website and services through analytics
• Complying with legal obligations

If we want to use your information for any other purpose, we will ask for your consent and will use your information only upon receiving it, and only for the purpose(s) for which consent was granted — unless we are required to do otherwise by law.

How We Share Your Information

We will not transfer your personal information to any third party without seeking your consent, except in limited circumstances described below:

• Analytics providers — to help us understand how our website is used
• Data processing platforms — including email and messaging platforms used to deliver communications on our behalf

We require such third parties to use personal information transferred to them only for the purpose for which it was transferred and not to retain it longer than necessary for that purpose.

We may also disclose your personal information: (1) to comply with applicable law, regulation, court order, or other legal process; (2) to enforce your agreements with us, including this Privacy Policy; or (3) to respond to claims that your use of the Service violates any third-party rights. If Intentive is merged with or acquired by another company, your information may be transferred to the new owner.

SMS & RCS Data Collection Updated

When you provide your mobile phone number to Intentive — whether through our website, a sign-up form, or another opt-in mechanism — we may use that number to send you SMS (Short Message Service) or RCS (Rich Communication Services) messages related to our services, updates, or marketing communications.

We collect and store the following in connection with mobile messaging:

• Your mobile phone number
• The date, time, and method by which you opted in to receive messages
• The specific consent given (including the channel and message type consented to)
• Message delivery and read receipts (for RCS)
• Any replies or interactions you send in response to our messages
• Opt-out date and method, where applicable

This information is held securely and used solely for the purpose of delivering the messaging service and maintaining compliance records.

SMS & RCS Consent & Opt-in New

We will only send you SMS or RCS marketing messages if you have given us your prior express consent to do so. Consent is collected through a clear, affirmative opt-in action — such as ticking an opt-in checkbox or submitting a sign-up form that includes specific SMS or RCS consent language.

Consent for SMS or RCS messages is:

• Freely given and not bundled with general terms and conditions
• Specific to the channel (SMS and/or RCS) and the type of messages you will receive
• Recorded with a timestamp and the consent language presented at the time
• Not a condition of purchasing or using our services
• Separate from any email marketing consent

We retain records of all consents and can provide evidence of your opt-in upon request.

How to Opt Out of SMS & RCS New

You can opt out of receiving SMS or RCS marketing messages from us at any time. To do so:

• Reply STOP to any SMS or RCS message you receive from us. You will receive a single confirmation message and no further marketing messages will be sent.
• Reply HELP to any message to receive information about how to contact us or how to opt out.
• Email us at [email protected] and request to be removed from our mobile messaging list.

You have an absolute right under UK GDPR to object to direct marketing at any time. This right applies to all marketing channels, including SMS and RCS.

Mobile Data Sharing Policy New

Your mobile number may be shared only with the following categories of sub-processors, solely for the purpose of delivering messages on our behalf:

• Klaviyo — our marketing platform, used to send and manage SMS communications
• Google (RCS for Business) — used to deliver RCS messages through verified sender profiles
• Mobile network operators and RCS aggregators — for message routing and delivery

All such sub-processors are bound by data processing agreements and are required to process your mobile number only on our documented instructions, and only for the purpose of message delivery. They are prohibited from using your mobile number for any other purpose.

All other categories of data sharing listed in this Privacy Policy (including for legal compliance) apply equally to mobile data. However, mobile opt-in consent data will never be used for purposes beyond what was disclosed at the point of consent.

Message Rates & Frequency New

Message and data rates may apply. SMS and RCS messages are delivered over your mobile network or a Wi-Fi connection. Standard message and data rates charged by your mobile network provider may apply, depending on your plan. Intentive does not charge separately for receiving our messages.

Message frequency will vary depending on the nature of your engagement with us and any campaigns or updates relevant to you. We will not send an unreasonable volume of messages and will always aim to send only messages that are relevant and useful.

For support or further information about our SMS and RCS messaging programme, please contact us at [email protected].

Retention of Your Information

We will retain your personal information for 90 days to 2 years after user accounts remain idle, or for as long as we need it to fulfil the purposes for which it was collected as detailed in this Privacy Policy.

We may need to retain certain information for longer periods, such as for record-keeping and reporting in accordance with applicable law, or for other legitimate reasons such as enforcement of legal rights or fraud prevention.

Mobile consent records (including your opt-in date, method, and the consent language presented) will be retained for a minimum of 5 years following the date of consent or the date of last communication — whichever is later — to enable us to demonstrate compliance with PECR and UK GDPR in the event of a regulatory enquiry.

Residual anonymous and aggregate information that does not identify you directly or indirectly may be stored indefinitely.

Your Rights

Depending on the law that applies, you may have the right to:

• Access and receive a copy of your personal data
• Rectify inaccurate personal data
• Erase your personal data (the "right to be forgotten")
• Restrict or object to the active processing of your data
• Object to direct marketing at any time — including SMS and RCS marketing
• Port your personal information to another entity
• Withdraw any consent you have provided to us at any time
• Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk

To exercise any of these rights, please write to us at [email protected]. We will respond to your request in accordance with applicable law, and in any event within 30 days.

Please note that if you do not allow us to collect or process the required personal information, or withdraw consent for required processing, you may not be able to access or use the services for which your information was sought.

Cookies

To learn more about how we use cookies and your choices in relation to tracking technologies, please refer to our Cookie Policy.

Security

The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse, or unauthorised alteration of your information under our control.

However, given the inherent risks of transmitting data over the internet or mobile networks, we cannot guarantee absolute security. You transmit information to us at your own risk.

In the event of a personal data breach affecting your mobile number or other personal data, we will notify the ICO within 72 hours of becoming aware of the breach, in accordance with our obligations under UK GDPR and PECR. Where required, we will also notify affected individuals directly.

Contact & Data Protection

If you have any queries or concerns about the processing of your information, wish to exercise your data subject rights, or want to opt out of mobile messaging, please contact our Data Protection Officer: