Privacy Policy

1.1 Important information and who we are

Welcome to Thelonious Limited, a subsidiary of The Birdella Group Ltd. This Privacy Policy describes how Thelonious Limited (“we”, “us”, or “our”) handle data across the Thelonious platform (the “Platform”).

We are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of England and Wales (the “Legislation”). Capitalised terms used below have the same meaning as provided for in the Legislation unless expressly stated otherwise below.

This Privacy Policy explains how we collect, process and keep your data safe and will tell you about your privacy rights.

The individuals from whom we may gather and use data can include:

• Customers
• Suppliers
• Business contacts
• and any other people that the organisation has a relationship with or may need to contact.

1.2 Your Data Controller & Contact Point; Complaints

Thelonious Limited is the primary Data Controller for the Personal Data processed through our Platform or otherwise collected from you. Any inquiries, requests to exercise your legal rights, or complaints regarding your data should be sent to our central compliance inbox at info@birdella.com.

Complaints:

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. You can find our complaints form here complaints form.

1.3 Processing On Behalf Of Our Clients

When you use our services or Platform through your employer or an organization, we act as a Data Processor. We process your data according to the instructions provided by your employer or organization who will be the Data Controller in those circumstances.

2.1 Types of data / Privacy policy scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: includes data relating to your first name, last name, date of birth, username and passwords.
• Contact Data: includes data relating to your phone number, addresses, email addresses.
• Marketing and Communications Data: includes data relating to your preferences in receiving marketing information and other information from us.
• Billing Data: includes data relating to your debit and credit card information such as the card details, name attached to your payment details and your billing address.
• Transactional Data: includes data relating to details and records of all payments you have made for our services or products and the services and/or products you have selected.
• Customer Support Data: includes data relating to feedback and survey responses and any queries or requests for support you may raise.
• Usage Data: includes data about how you use our website, products and services.
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our website.

We also collect, use and share Aggregated Data which is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting and Using Your Data

There are a number of permitted reasons under the Legislation that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Contractual Obligations”: We may require and use certain information from you in order to fulfil our contractual obligations and provide you with the promised service in relation to a contract we have entered into or are about to enter into with you.
• “Legitimate Interest”: We might need to collect and use certain information from you to be able to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience, using your email to provide security alerts, using metadata to optimize the platform interface, or verifying your identity to prevent fraudulent bot activity. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• “Legal Compliance”: We may use your Personal Data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis. For example, we may be required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Consent”: We rely on consent only where we have obtained your active agreement to use your Personal Data for a specified purpose, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.

2.3 How We Collect Your Data

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your Personal Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see our cookie policy https://birdella.com/thelonious-cookie/ for further details.
• Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:
  • Technical Data is collected from the following parties:
    • analytics providers such as Google Analytics based outside the UK;
    • advertising networks advertising networks such as LinkedIn and Google based outside the UK; and
    • search information providers such as Google based outside the UK.
  • Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe based outside the UK.
  • Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us – info@birdella.com.

3.2 Marketing and content updates

You will receive marketing and new content communications from us if you have chosen to opt into receiving those communications. From time to time we may also analyse your Profile/Identity, Contact, Technical and Usage Data to form a view as to which products, services and offers may be of interest to you so that we can then send you relevant marketing communications and recommendations about products or services that may be of interest to you.

Opting Out

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us info@birdella.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us – info@birdella.com.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.1 Your legal rights

Under certain circumstances, you have the following rights under the Legislation in relation to your Personal Data:

• Right to be informed. You have a right to be informed about our purposes for processing your Personal Data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
• Right of access. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it (also known as a “data subject access request”). See section 4.3 below for more details on how you can make a data subject access request.
• Right to rectification. You have a right to request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right to erasure. You have the right to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to object. You can object to the processing of Personal Data we hold about you. This effectively allows you to stop or prevent us from processing your Personal Data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
  • (i) Where we are processing your Personal Data for direct marketing purposes.
  • (ii) Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Right to restrict processing. You have the right to request the restriction or suppression of your Personal Data. Note that this is not an absolute right and it only applies in certain circumstances:
  • (i) If you want us to establish the data’s accuracy.
  • (ii) Where our use of the data is unlawful but you do not want us to erase it.
  • (iii) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right to data portability. You have the right to request the transfer of your Personal Data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

4.2 How We Protect Your Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We use appropriate security measures designed to ensure Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will enter into appropriate contractual obligations with them to seek to ensure that we do not relinquish control of your Personal Data nor is it exposed to security risks that would not have arisen had the data remained in our possession.

However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us immediately – info@birdella.com.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

4.3 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

5.1 Data Residency

The residency of your data depends on which part of our ecosystem you are interacting with:

• Thelonious Platform: Our intelligence platform and its associated databases are hosted in the United Kingdom. This ensures that all primary research data and user-inputted queries remain within the UK’s data protection jurisdiction.
• The Birdella Group Website: Our corporate website and general marketing infrastructure are hosted in the United States.

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy. Please see section 8 below for further information.

5.2 Global Security Standards

Regardless of where data is processed, we apply a unified security framework. Currently this includes:

• Encryption: All Personal Data is encrypted at rest using AES-256 and in transit via TLS 1.2 or higher.
• Access Control: We apply security protocols to seek to ensure access to our production environment is restricted to a limited number of authorized personnel and is subject to multi-factor authentication (MFA).
• Expert Oversight: As part of our Human-Verified commitment, we conduct regular internal vulnerability assessments led by our senior policy and technical teams.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Profile/Identity, Billing and Transaction Data) for six years after they cease being customers for tax purposes.

You must not use our website, products, services or Platform unless you are aged 18 or older. If you are under 18 and you somehow access any of the foregoing, you must immediately stop doing so.

This website is not intended for children and we do not knowingly collect data relating to children.

While the Platform is hosted in the United Kingdom, our corporate infrastructure is hosted in both the United Kingdom and the United States. Using our services therefore involves the international transfer of data.

8.1 Transfers from the UK/EEA

When we transfer data from the UK to jurisdictions (such as the United States) which have laws that do not provide the same level of data protection as English law, we always ensure that a similar degree of protection is afforded to it by utilizing Standard Contractual Clauses (SCCs) or the UK International Data Transfer Addendum. These legal frameworks ensure that any data moving between our UK platform and our US corporate environment is protected by the same rigorous standards required under the UK GDPR.

8.2 US State-Specific Disclosures (CCPA/CPRA)

For our users based in the United States, we comply with applicable state laws:

• No Sale of Data: We do not “sell” your personal information to third parties, nor do we “share” it for cross-context behavioral advertising as defined by the CCPA.
• Purpose Limitation: We only process your data for the specific business purposes outlined in this policy—primarily to provide the Thelonious intelligence services.
• Sensitive Data: We do not use or disclose “Sensitive Personal Information” for purposes other than those permitted by law.

We keep our Privacy Policy under review and will place any updates here. This version is dated 13 April 2026.

By using our Platform, products, services and/or website, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of the same will constitute your express acceptance of any modifications to this Privacy Policy. PLEASE CHECK BACK HERE REGULARLY TO ENSURE YOU ARE AWARE OF ANY CHANGES.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us, for example if you change to a new address or email address.

All uses of the word “including” mean “including but not limited to” and the enumerated examples in this policy are not intended to in any way limit the term which they serve to illustrate.

Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided and any unrelated correspondence will be ignored.

Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on our behalf, waive rights or make representations (whether contractual or otherwise) to you. Our terms, policies and any official public announcement on our website shall take precedence over any and all communications or messaging you may receive from our staff. If anything contained in an email from any address linked to us contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any of our rights, you should disregard the same entirely and the latter will take precedence over the former. The only exception to this is genuine correspondence issued to you from a duly authorised representative of our legal department.

Our website and Platform may include links to third-party websites, plug-ins, and applications (such as legal databases or news sources). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.