Privacy Policy

Data Controller	Saltire Finance Ltd
Product	Praxis
Registered in	Scotland, United Kingdom
Contact	[email protected]
UK GDPR basis	Contract, Legitimate Interests, Legal Obligation
Last updated	15 June 2026

1. Who We Are

Saltire Finance Ltd ("we", "us", "our") is the data controller for personal data processed in connection with Praxis, our FCA rectification delivery support application. Praxis may be made available under white-label or custom-branded arrangements by authorised partners; in those cases, Saltire Finance Ltd remains the underlying data controller for data collected through the platform infrastructure.

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights in relation to it. It applies to all users of Praxis and visitors to our website.

2. What Personal Data We Collect

2.1 Account and Contact Data
When you register an interest in or sign up for Praxis, we may collect:

• your name and job title
• your business email address
• your organisation name
• your telephone number (if provided voluntarily)

2.2 Usage and Technical Data
When you access our website or the Praxis platform, we may automatically collect:

• IP address and browser type
• pages visited and time spent
• referring URLs
• device and operating system information

This data is collected via standard server logs and, where applicable, analytics tools. It is used in aggregate and is not used to identify you individually unless required for security purposes.

2.3 Communications Data
If you contact us by email, web form, or other means, we will retain a record of that correspondence including any personal data you include.

2.4 What We Do NOT Collect
Praxis operates on a client-side architecture. All project data, rectification programme content, risk logs, issue registers, action trackers, and related delivery materials entered into the Praxis application are stored locally within your own browser or device environment. We do not transmit, access, store, or process any project or programme data you enter into Praxis on our servers. We have no visibility of the content of your rectification programmes or related work.

3. How We Use Your Personal Data

Purpose	Lawful Basis	Retention
Responding to enquiries and managing waitlist / early access	Legitimate interests / Pre-contractual steps	12 months from last contact
Providing and administering access to Praxis	Performance of contract	Duration of contract + 6 years
Sending product updates and relevant communications (where opted in)	Consent	Until consent withdrawn
Improving the platform and website (aggregated analytics)	Legitimate interests	26 months (standard analytics cycle)
Complying with legal and regulatory obligations	Legal obligation	As required by law

4. White-Label and Partner Arrangements

Praxis may be deployed under a white-label or custom-branded arrangement by an authorised partner organisation (for example, a consultancy or financial services firm). In such cases:

• Saltire Finance Ltd remains the data controller for personal data collected through the underlying platform infrastructure (such as account registration data).
• The partner organisation may be a separate data controller or data processor in respect of any personal data they collect or manage in connection with their deployment of Praxis.
• Partners are required to maintain their own compliant privacy notices where applicable.
• Project and programme data entered into the Praxis application remains stored client-side on the end user's device, regardless of the white-label configuration.

5. Sharing Your Personal Data

We do not sell your personal data. We may share personal data with:

• Service providers who assist us in operating our website and platform (for example, hosting providers, email delivery services, analytics providers) — these parties act as data processors under our instruction and are bound by appropriate data processing agreements.
• Professional advisers including solicitors, accountants, and insurers where necessary.
• Regulatory authorities or law enforcement where we are required to do so by law.

We do not transfer personal data outside the UK or European Economic Area except where adequate safeguards are in place in accordance with UK GDPR.

6. Cookies and Tracking

Our website may use cookies and similar technologies for functional and analytical purposes. We use:

• Essential cookies — necessary for the website to function correctly
• Analytics cookies — to understand aggregate usage patterns (where applicable, subject to your consent)

You can control cookie settings through your browser. Disabling certain cookies may affect the functionality of our website. Where we rely on consent for non-essential cookies, we will request this via a cookie consent mechanism on first visit.

7. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction. These include access controls, encrypted communications, and regular security reviews.

As project data in Praxis is stored client-side, you are responsible for the security of the device and environment in which you use the application, including appropriate access controls and backups.

8. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

• Right of access — to obtain a copy of the personal data we hold about you
• Right to rectification — to have inaccurate data corrected
• Right to erasure — to request deletion of your data in certain circumstances
• Right to restriction — to limit how we use your data in certain circumstances
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests
• Right to withdraw consent — where processing is based on consent, to withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at [email protected]. We will respond within one calendar month.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you by email or by prominent notice on our website. The effective date at the top of this document will always reflect the most recent version.

10. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:

Saltire Finance Ltd
12 Harrier Court, Dunfermline, Fife, KY11 8JS
[email protected]
saltirefinance.com