Legal · Working draft for solicitor review
Privacy Policy
Draft updated 20 October 2026 · Not solicitor-approved · Do not publish as final until reviewed and confirmed.
Important solicitor review points
This working draft needs review by a qualified UK data protection solicitor. Confirm the lawful bases for each purpose, retention periods, processor and controller roles, international transfers, the operational introduction permission process, and the contact and supervisory authority details before final publication.
This draft explains how Carter Connects, the trading name of Trevor Carter, handles personal information when people visit our website, apply to a programme, join the network, or ask us to consider a professional introduction.
1. Who we are and how to contact us
Carter Connects is the trading name of Trevor Carter. Our business address is Bartle House, Oxford Street, Manchester M2 3WQ, United Kingdom.
For privacy questions or to exercise a data protection right, contact info@carterconnects.com. Please identify the request and the email address you used with Carter Connects. The business must confirm that this inbox is monitored for privacy requests and notices before relying on it as the sole contact channel.
Solicitor confirmation is needed for the controller identity wording, whether any other entity jointly determines processing purposes, and the appropriate supervisory authority contact.
2. Information we may collect
The information collected depends on the enquiry, application, membership or introduction request. It may include:
- Identity and contact details, such as name, email address, telephone number, job title and professional profile links.
- Business and professional details, such as company name, website, industry, role, expertise, business stage, services and relevant experience.
- Application and suitability information, including what the applicant is seeking, goals, connection priorities, relevant background, answers to form questions and information supplied during a review or conversation.
- Introduction information, such as the type of connection requested, business objective, context needed to assess suitability, possible relationship routes, decisions and permission records.
- Membership and service administration details, including application outcome, membership status, service dates, payment and cancellation administration where relevant, and communications about a service.
- Preference and consent records, including marketing choices, cookie preferences, any separate request to start a consumer service early, the date and method of each choice, and the policy version shown.
- Technical and usage information generated by a visit, which may include device, browser, log, cookie, analytics and embedded service information according to the visitor's settings and applicable cookie notice.
Please do not submit special category information, criminal offence information, confidential third party information or sensitive commercial material unless we specifically request it and explain why it is needed.
The business must verify that this description matches every live application form and payment or membership system before final approval.
3. Why we use information
Depending on the relationship and facts, we may use information to:
- Respond to enquiries and administer applications.
- Review an applicant's stated objectives, experience, suitability and fit for a particular programme.
- Understand a member's connection priorities and assess whether a relevant introduction may be appropriate.
- Prepare context for a possible introduction, request permissions, and facilitate it only where a suitable route exists and the relevant people agree.
- Deliver and administer an agreed service, including membership, payment, account, cancellation, support and complaint handling.
- Maintain records of choices and permissions, prevent misuse, keep the site secure and comply with legal obligations.
- Send marketing only where an appropriate lawful basis or consent applies and the recipient can object or unsubscribe as required. Expressing interest in joining or in an introduction is not, by itself, consent to unrelated marketing.
The lawful basis for each purpose must be determined by the actual facts, the person's role, and applicable data protection law. The controller should document those bases in the final notice. This draft does not make that legal determination.
4. How we assess suitability and possible introductions
We use application and professional information to understand the applicant's objectives, the type of relationship that could be useful, the context and timing, and whether a relevant route may exist. Carter Connects applies human review and relationship judgement. A possible match is not an endorsement, and a member is not given automatic access to the network or its records.
We may use limited professional information to assess whether two people could be relevant to one another. Before sharing an individual's direct contact details with a prospective introduction, Carter Connects will explain the proposed introduction and obtain that individual's permission through the agreed process. No member's contact details should be sent to the other party for a specific introduction before the required permission is recorded. If permission is not given, the introduction will not proceed and the contact details will not be shared for that introduction.
The exact introduction workflow, what non identifying or professional context may be shared before permission, and how each party's permission is recorded must be confirmed operationally and by the solicitor. Information necessary to make an introduction should be limited to what each participant has agreed to share.
Introductions, referrals, funding, clients, investment and business results are not guaranteed.
5. Who may receive information
Personal information may be available to people who need it for the purposes described in this policy, including Carter Connects personnel and authorised service providers. Depending on the service and page, providers may include:
- HubSpot for application, contact and relationship management where that form or workflow is connected to HubSpot.
- Payment, membership and account service providers such as Stripe and Outseta where configured for the relevant offer.
- Marblism hosted form email delivery for forms that are configured to send information to Carter Connects by email.
- Website hosting, security, analytics, embedded video and live chat providers as described in the Cookie Policy and according to the visitor's consent settings.
- A potential introduction, but only the limited information needed for that specific introduction and only after the necessary permission has been obtained from the relevant person.
- Professional advisers, regulators, law enforcement or other recipients where disclosure is required by law or is necessary to establish, exercise or defend legal claims.
We do not sell personal information. Before final publication, confirm each active provider, its role, data location, transfer safeguards, instructions, retention and current contract. A named provider in this draft does not mean that every provider receives data on every page.
6. How long information is kept
Information should be kept only for as long as it is reasonably needed for the purpose for which it was collected, to administer an application or service, to maintain required business records, to respond to a complaint, or to establish or defend a legal claim. When it is no longer needed, it should be securely deleted or anonymised, subject to legal retention requirements and provider backup cycles.
No verified, approved retention schedule has been supplied for applications, unsuccessful applicants, member records, introduction permissions, payment records, marketing choices, email submissions, or backup copies. Specific periods, deletion triggers, responsibility for deleting information from HubSpot, email, Stripe and Outseta, and backup expiry need to be agreed and inserted before this policy is finalised. We do not invent a retention period in this draft.
7. Your data protection rights
Depending on the applicable law and circumstances, you may have the right to request access to personal information, correction, erasure, restriction, objection, portability, or withdrawal of consent where processing relies on consent. You may also have the right to complain to the relevant supervisory authority.
To exercise a right, contact info@carterconnects.com and tell us what you are requesting. We may need to verify your identity and will respond within the time required by law. We will explain if a request cannot be fully met because a legal obligation or another lawful ground applies. Confirm the monitored status of this inbox and final request-handling procedure before publication.
8. Security, transfers and automated decisions
We use reasonable organisational and technical safeguards appropriate to the information and services involved. No method of transmission or storage is entirely risk free. The specific security controls and each provider's access to information should be reviewed regularly.
Some providers may process information outside the United Kingdom. The locations, relevant transfer safeguards and means of obtaining information about them require confirmation for each provider and should be stated in the final version.
Applications are reviewed by people. Technology may help organise information or identify potentially relevant possibilities, but a final introduction decision is subject to human context and judgement. Confirm whether any automated decision making or profiling with legal or similarly significant effects occurs. This draft does not state that such activity occurs.
9. Cookies and related technologies
Essential site functions and optional analytics and embedded media are described in the Cookie Policy. Some forms may load HubSpot and reCAPTCHA services when displayed or submitted. Their exact cookies, storage, purposes and consent classification require a technical audit and solicitor review.
Cookie Settings can be used to review optional preferences. The final notice should explain how consent can be withdrawn and what happens to existing cookies and storage when a preference changes.
10. Changes to this policy
We may revise this policy when our services, systems or legal obligations change. The date of the latest update should be shown and material changes should be communicated where appropriate. The version presented to an applicant or member should be available when the information is collected.
This is a working draft for qualified UK solicitor review. It is not legal approval or advice. Do not publish it as final until the listed facts and arrangements are verified.