Privacy Notice
This Privacy Notice explains how Ullr Intelligence Ltd (“we”, “us”, “our”) collects, uses and protects your personal data. It applies when you engage our desk-based private investigation services, or when we process personal data about you during an investigation instructed by one of our clients.
1. Who we are
- Data controller: Ullr Intelligence Ltd (registered in England & Wales, company no. 17117362)
- Registered office: Prime Apartments, 483 Green Lanes, London N13 4FG
- Email: info@ullrintelligence.co.uk
- Director: David Nelson
- ICO registration: registered with the Information Commissioner’s Office as a data controller, registration number ZB655932.
We are a UK-registered company providing professional desk-based private investigation and intelligence services.
2. What personal data we collect
- Client data: name, contact details, billing information and case instructions.
- Data-subject data: name, address history, date of birth, employment, financial information, public records and open-source intelligence (OSINT) lawfully obtained during investigations.
- Special category or criminal-convictions data: only where strictly necessary and with appropriate safeguards, including an Appropriate Policy Document (DPA 2018 Schedule 1) where required.
3. How we use your data and our lawful bases
- Providing investigation services to clients: contract and/or legitimate interests (supported by legitimate-interests assessments).
- Legal obligations: for example tax, accounting and responding to data-subject requests.
- Improving our services: legitimate interests, with appropriate balancing.
We do not sell personal data, and we do not use solely automated decision-making with legal or similarly significant effects.
4. Use of AI tools and technology
We use advanced AI tools to assist with the analysis and structuring of open-source intelligence, as part of our legitimate interests in delivering efficient, high-quality investigative services. We apply strict data minimisation, carry out legitimate-interests and transfer-risk assessments where required, and maintain appropriate contractual safeguards (including Standard Contractual Clauses) for any international transfers.
5. Investigations and transparency
Due to the nature of private investigation work, there may be circumstances where providing full information to a data subject at the time of collection would prejudice the investigation. In such cases we rely on applicable exemptions under UK GDPR and the Data Protection Act 2018.
6. Data sharing
We may share personal data with trusted sub-contractors under strict confidentiality agreements, with professional advisers, with secure service providers, or with law enforcement and regulators where legally required.
7. How long we keep your data
We retain case files and reports for 6 years in line with our Data Retention and Deletion Policy, or longer where required by law or to defend legal claims.
8. Your rights
You have rights under UK GDPR, including access, rectification, erasure, restriction, portability and objection. You can also complain to the ICO at ico.org.uk. To exercise your rights, contact us using the details above.
9. Changes to this notice
We may update this Privacy Notice from time to time. The current version is always available on our website.