Privacy Terms

Effective Date: 04 August, 2025

1. Introduction

HGP IS Limited ("we," "us," "our," or "HGP IS") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our words.business website and services.

Company Details:

  • Name: HGP IS Limited

  • Registered Office: 167-169 Great Portland Street, Fifth Floor, London, W1W 5PF, United Kingdom

  • Contact: support@words.business

2. Information We Collect

2.1 Personal Information

We may collect the following personal information:

  • Name and contact details (email address, phone number, postal address)

  • Company or organization information

  • Payment and billing information

  • Communication preferences

2.2 Content Information

  • High-stakes business documents and communications submitted for review

  • Content provided for Traffic Light Review (TLR) assessment

  • Materials submitted for Mind the Gap Report (MTG) analysis

  • Communications related to our risk assessments and improvement recommendations

  • Feedback and project-related information

2.3 Technical Information

  • IP address and browser information

  • Website usage data and analytics

  • Cookies and similar tracking technologies

  • Device and connection information

2.4 Communication Records

  • Email correspondence

  • Project briefs and instructions

  • Service-related communications

3. How We Collect Information

We collect information:

  • Directly from you when you contact us or engage our services

  • Automatically through website usage and cookies

  • From third parties where you have given consent (e.g., referral partners)

  • Through service delivery platforms and communication tools

4. Legal Basis for Processing (UK GDPR)

We process your personal data based on:

  • Contract performance: To provide our editing and review services

  • Legitimate interests: For business operations, service improvement, and communication

  • Consent: Where you have specifically agreed (e.g., marketing communications)

  • Legal obligations: For compliance with applicable laws

5. How We Use Your Information

5.1 Service Delivery

  • Providing Traffic Light Review (TLR) assessments and risk scoring

  • Delivering Mind the Gap Report (MTG) comprehensive analysis

  • Analyzing content for risks, opportunities, and improvement recommendations

  • Managing express overnight delivery services

  • Processing payments for MTG reports and improvement services

  • Communicating assessment results and improvement pricing

5.2 Business Operations

  • Improving our services and website functionality

  • Analyzing usage patterns and service effectiveness

  • Maintaining security and preventing fraud

  • Complying with legal and regulatory requirements

5.3 Marketing (with consent)

  • Sending newsletters and service updates

  • Providing information about new services

  • Industry insights and content tips

6. Information Sharing and Disclosure

6.1 We DO NOT sell your personal information to third parties.

6.2 We may share information with:

  • Service providers: IT support, payment processors, cloud storage providers

  • Professional advisors: Lawyers, accountants, business consultants

  • Legal authorities: When required by law or to protect our rights

  • Business transfers: In the event of merger, acquisition, or asset sale

6.3 International Transfers

  • We are based in the UK but work globally and may transfer data internationally

  • We ensure appropriate safeguards are in place

  • Some service providers may be located outside the UK/EU

7. Content Security and Confidentiality

7.1 Important Limitations

  • We specialize in high-stakes content review but cannot guarantee the confidentiality or security of content you provide

  • We do not know in advance the sensitivity, confidentiality level, or business-critical nature of your content

  • Given the high-stakes nature of our clients' content, we strongly recommend that for highly sensitive or confidential materials, you provide secure access rather than direct transmission

  • You acknowledge that submitting content for TLR or MTG services involves inherent risks

7.2 Security Measures

We implement reasonable security measures including:

  • Encrypted data transmission where possible

  • Access controls and user authentication

  • Regular security assessments

  • Secure disposal of data when no longer needed

7.3 Data Breach Response

In the event of a data breach, we will:

  • Assess the risk and impact

  • Notify relevant authorities within 72 hours where required

  • Inform affected individuals without undue delay where high risk exists

  • Take steps to mitigate the breach

8. Cookies and Website Analytics

8.1 Types of Cookies We Use

  • Essential cookies: Required for website functionality

  • Analytics cookies: To understand website usage (e.g., Google Analytics)

  • Functional cookies: To remember your preferences

  • Marketing cookies: For advertising (with consent)

8.2 Managing Cookies

You can control cookies through your browser settings. However, disabling essential cookies may affect website functionality.

8.3 Third-Party Analytics

We use Google Analytics and similar services to understand website usage. These services have their own privacy policies.

8. Data Retention

We retain personal information for:

  • Client data: Duration of service relationship plus 7 years for business records

  • TLR and MTG content: As long as necessary for service delivery, typically 30 days after delivery, then securely deleted unless longer retention is requested

  • Assessment records: Summary risk scores and recommendations retained for service improvement purposes (personal identifiers removed)

  • Website data: As specified in our cookie policy

  • Marketing data: Until you withdraw consent or we no longer have legitimate interest

10. Your Rights (UK GDPR)

You have the right to:

  • Access: Request copies of your personal data

  • Rectification: Correct inaccurate personal data

  • Erasure: Request deletion of your personal data

  • Restriction: Limit how we use your personal data

  • Portability: Receive your data in a machine-readable format

  • Object: Object to processing based on legitimate interests

  • Withdraw consent: For processing based on consent

10.1 Exercising Your Rights

To exercise these rights, contact us at support@words.business. We will respond within one month.

10.2 Complaints

You have the right to complain to the Information Commissioner's Office (ICO) if you believe we have not handled your personal data properly.

11. US-Specific Considerations

11.1 California Consumer Privacy Act (CCPA)

If you are a California resident, you may have additional rights including:

  • Right to know what personal information is collected

  • Right to delete personal information

  • Right to opt-out of sale (note: we do not sell personal information)

  • Right to non-discrimination

11.2 Other US State Laws

We comply with applicable state privacy laws. Contact us for specific information about your state's requirements.

12. Children's Privacy

Our services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will:

  • Post the updated policy on our website

  • Notify you of material changes via email where appropriate

  • Update the "Effective Date" at the top of the policy

14. International Data Transfers

When we transfer personal data outside the UK, we ensure:

  • Adequate level of protection as determined by the UK authorities

  • Appropriate safeguards such as Standard Contractual Clauses

  • Your rights remain protected

15. Contact Information

For questions about this Privacy Policy or our privacy practices:

Email: support@words.business Address: HGP IS Limited, 167-169 Great Portland Street, Fifth Floor, London, W1W 5PF, United Kingdom

For data protection matters specifically, you can also contact our designated privacy contact at the same email address.


Last Updated: 04 August 2025