L42 LTD. PRIVACY POLICY

1. Introduction

This Privacy Policy explains how L42 Ltd, also trading as Intelligent Internet ("we", "us", or "our"), collects, uses, and protects personal data relating to our suppliers, vendors, contractors, and other counterparties in the course of our business operations including individuals who apply for employment or engagement with L42 Ltd.

We are committed to safeguarding the privacy and confidentiality of personal data in compliance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act, 2018.

2. Who We Are

L42 Ltd is a Private liability Company incorporated under English and Welsh law and engaged in the business of artificial intelligence and crypto-related technologies. For the purposes of applicable data protection laws, L42 Ltd is the data controller, meaning we determine how and why personal data is processed. If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us at [email protected]

3. What Personal Data We Collect

We collect personal data directly from you in the following ways including during the application process, onboarding or contract negotiations and through communications, including emails, marketing materials, and telephone calls and when you submit invoices, proposals, or other documents. We may collect personal data indirectly from publicly available sources, such as company websites or government registries.

We may collect and process the following categories of personal data from suppliers, applicants applying for a role with L42 Ltd and our counterparties, including indirectly from publicly available sources, such as company websites or government registries:

  • Contact information: name, address, email address, telephone number, and job title
  • Financial information: bank account details, tax identification numbers, and payment-related information
  • Professional information: company name, registration details, and business licences
  • Communications: emails, call records, and other correspondence
  • Identification data: copies of identification documents (for example, passports), where required for due diligence purposes
  • Recruitment Information: including CVs, cover letters, application forms, employment history, education, qualifications, skills, references, recommendations an applicant provides, interview and assessment data, right-to-work information (where legally required), communications exchanged with us during the recruitment process and publicly available professional information (e.g. LinkedIn profiles), where relevant and permitted by law.

We do not intentionally collect special category data unless permitted by law and strictly necessary for recruitment purposes (e.g. diversity monitoring or reasonable adjustments).

4. How We Use Your Personal Data

We use personal data for the following purposes:

  • Contract management: to evaluate, enter into, and manage contractual relationships
  • Compliance: to conduct due diligence and meet legal and regulatory obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements
  • Payment processing: to process payments and manage financial transactions
  • Communications: to facilitate business communications and maintain working relationships
  • Internal operations: for record-keeping, audits, hiring, to assess your suitability for employment or engagement, manage recruitment processes, communicate with you about your application, conduct interviews, and make hiring decisions and other legitimate business purposes

5. Event Attendees and Marketing Communications

This section applies to individuals who register for or attend events organised or sponsored by L42 Ltd (including community events), and individuals who subscribe to receive marketing or promotional communications from us. We may collect and process the following personal data in connection with events and marketing activities:

  • Name
  • Email address
  • Event registration details and attendance information
  • Communication preferences

We process this personal data for the following purposes:

  • To administer and manage event registrations, including ticket confirmations and event-related communications (e.g., changes to time or venue);
  • To respond to enquiries relating to events;
  • To send marketing communications about future events, initiatives, or updates, where you have opted in to receive such communications.

We rely on the following lawful bases under applicable data protection law:

  • Contractual necessity or legitimate interests – where processing is necessary to administer an event you have registered for;
  • Consent – where you have chosen to receive marketing communications from us.

Where we rely on consent for marketing communications, you may withdraw your consent at any time by using the unsubscribe link included in our emails or by contacting us at [email protected].

Where you register for an event but do not opt in to receive marketing communications, your personal data will be retained only for as long as necessary to administer the event and for a limited period thereafter for record-keeping purposes. Where you opt in to receive marketing communications, we will retain your contact details until you withdraw your consent or unsubscribe.

We process personal data on the following legal bases, as applicable:

  • Contractual necessity: where processing is required to perform a contract or take steps prior to entering into a contract
  • Legal obligations: where processing is required to comply with applicable laws and regulations
  • Legitimate interests: for our legitimate business purposes, such as maintaining supplier relationships and improving operational efficiency

Consent: where we rely on explicit consent for specific processing activities

7. Sharing Your Personal Data

We do not sell or rent personal data to third parties. We may share personal data with the following categories of recipients:

  • Service providers: third-party providers who support our operations, such as IT support providers, payment processors, applicant tracking systems or auditors. Such providers process personal data under contractual obligations requiring confidentiality and appropriate security measures.
  • Regulatory authorities: where required by law or in response to lawful requests
  • Affiliated companies: within our corporate group, for business administration and compliance purposes

8. International Transfers

Where personal data is transferred outside the United Kingdom or the European Economic Area (EEA), we ensure that appropriate safeguards are in place, including:

  • Contracts incorporating standard contractual clauses approved by the European Commission or the UK authorities
  • Transfers to countries recognised as providing an adequate level of data protection

9. Data Retention  

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or to comply with legal and regulatory requirements. This generally includes the duration of the contractual relationship and a defined period thereafter, as required by law.

10. Your Data Protection Rights

Under applicable data protection laws, you have the following rights:

  • The right to access your personal data
  • The right to request correction of inaccurate or incomplete data
  • The right to request erasure of your personal data (subject to legal or contractual obligations)
  • The right to request restriction of processing
  • The right to object to processing based on legitimate interests
  • The right to data portability

To exercise any of these rights, please contact us at [email protected]. We will respond within the timeframes required by law.

11. Security Of Your Personal Data  

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

12. Updates To This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal, regulatory, or business requirements. The most recent version will be published on our website, and material changes will be communicated where required by law.

13. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our handling of personal data, please contact us at  [email protected]

If you are not satisfied with our response, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):

  • Website: https://ico.org.uk
  • Telephone: 0303 123 1113

Owner: Legal Department

Last updated: 13 February 2026

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