1. Introduction 

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AJN Solutions Group (“we”, “us”, “our”) is committed to protecting your privacy and respecting the confidentiality of your personal information. We collect and use data only as necessary to provide our services and operate this website, in line with the UK GDPR, the Data Protection Act 2018, and the Data (Use and Access) Act 2025.

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This policy applies only to the AJN Solutions Group website and not to external sites you may access through it.

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2. Information About Us 

AJN Solutions Group is a privately owned consultancy business. 

For any data‑protection queries, contact: tony@antonyjnewman.com

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3. What Data We Collect 

We keep personal data collection to a minimum. 

We may collect:

- Client name 

- Company name 

- Job role 

- Employee names 

- Business email address 

- Business address 

- Business telephone number 

- Number of employees (approximate bands) 

- Business sector 

- Individuals’ names (open source research) 

- Publicly available information on individuals (open source research) 

- Payment or billing information 

- Copies of passport or driving licence (where legally required) 

- Non‑personal website usage data 

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4. Lawful Basis for Processing

We process personal data under the following UK GDPR lawful bases:

4.1 Contract

To provide and manage our services, including onboarding, identity checks, and delivery of consultancy or open source reports.

4.2 Legitimate Interests

For activities necessary to operate and protect the business, including: 

- Conducting open source research using publicly available sources 

- Maintaining business records 

- Preventing fraud or misuse 

- Ensuring website security and performance 

We balance these interests against your rights and freedoms.

4.3 Legal Obligation

Where we must retain or provide information to comply with UK law (e.g., accounting, anti‑fraud, identity verification).

4.4 Consent

Used only where required (e.g., optional communications). 

You may withdraw consent at any time.

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5. How We Use Your Data

We use your personal data to:

- Provide and manage services, including onboarding and identity checks 

- Supply documents, forms, and essential service communications 

- Conduct open source research using publicly available sources 

- Operate and improve our website and services 

We never send spam and only process data where it is necessary and proportionate. 

We do not use your data for any purpose not stated in this policy.

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6. Use of AI Tools (DUAA 2025 Requirement)

AJN Solutions Group may use AI‑assisted tools to support research, drafting, or analysis. 

Where AI is used:

- It does not make automated decisions about you 

- It is used only to assist the human consultant 

- Personal data is minimised or anonymised wherever possible 

- No AI system is permitted to train on your data 

- You may request that your data is not processed using AI tools 

This meets the transparency requirements effective 19 June 2026.

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7. Cookies Used on This Website 

AJN Solutions Group does not use any specialist cookies. 

However, our hosting provider Wix.com operates essential and functional cookies required for security, performance, and site operation, including:

• XSRF‑TOKEN

• hs

• svSession

• SSR‑caching

• wixCIDX

• wix_browser_sess

• consent‑policy

• smSession

• TS

• bSession

• fedops.logger.X

• wixLanguag

Further details: [www.wix.com/about/privacy](http://www.wix.com/about/privacy)

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8. How Long We Keep Your Data

We retain personal data until you ask us to delete it. 

We also keep:

- Transaction and subscription records (for accounting) 

- Emails and service‑related communications where reasonably required 

- Certain records needed to support potential legal claims 

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9. How and Where Your Data Is Stored 

All personal data related to risk consulting and open source research is stored securely within the UK and protected under UK GDPR. 

All personal data related to clients of our online academy is stored securely in Australia by our service provider, and is still protected under UK GDPR.

We do not transfer your data outside the UK unless legally required and with appropriate safeguards.

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10. Do We Share Your Data? 

We do not share your personal data with third parties except:

10.1 Where legally required 

(e.g., law enforcement, regulatory bodies).

10.2 For open source‑related services

We may share publicly available information contained within open source reports with the commissioning client only, where this is necessary to fulfil the contracted service.

We never sell data, never share it for marketing, and never disclose non‑public personal data unless required by law.

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11. Your Rights Under UK GDPR 

You have the right to:

- Be informed 

- Access your personal data 

- Correct inaccurate data 

- Request deletion 

- Restrict or object to processing 

- Request data portability 

- Be free from automated decision‑making and profiling (we do not use these) 

You may also complain to the Information Commissioner’s Office (ICO).

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12. Data‑Protection Complaints Procedure (Required from 19 June 2026) 

If you have a concern about how your data has been handled:

1. Email your concern to tony@antonyjnewman.com 

   Include your name, contact details, and a brief description of the issue.

2. Alternatively you may post your complaint to the postal address shown on the website. 

3. We will acknowledge your complaint within 5 working days. 

4. We will investigate and respond within 30 days. 

5. If the matter is complex, we may extend the timeframe by up to 60 days and will notify you. 

6. If you remain dissatisfied, you may escalate your complaint to the ICO.

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13. Accessing Your Personal Data 

To request access to your personal data, email us and clearly mark your message as a Subject Access Request. 

We normally respond within one month, with extensions for complex cases.

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14. Contact Us 

For any data‑protection queries or to exercise your rights: 

Email: tony@antonyjnewman.com

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15. Changes to This Policy 

We may update this policy if the law changes or our practices change.