Privacy Policy

1 - Introduction

1. Alpha Colony (a trading name of "Fantom Factory Limited") is a processor within the meaning of the Data Protection Act 2018 and the UK General Data Protection Regulation. Further details about us and how to contact us appear below. We collect and process data from the No Ordinary Ant website on behalf of Spiral Horizons CIC (the data controller).
2. This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.
3. This Privacy Statement applies to personal data from you when you contact us and provide us with your personal data when you:
   1. create an account to use the website; "No-Ordinary-Ant.uk" including websites published at its subdomains;
   2. make enquiries via email to any of our support channels, such as: “support@alphacolony.io”;
4. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected.
5. We have legal obligations to you to inform you of:
   1. the personal data which we collect from you;
   2. how we use it;
   3. the purposes for which we process your personal data;
   4. the legal basis for processing your personal data;
   5. who we share your personal data with;
   6. where we store and send your personal data, and protections;
   7. the periods for which we retain your personal data;
   8. your rights under the General Data Protection Regulation; and
   9. the right to lodge a complaint with a supervisory authority.

2 - How We Process Your Personal Data

1. Personal data is information that identifies you, either directly or indirectly. This includes your contact details and any information about you that you provide us.
2. When we process your personal data, we:
1. do so lawfully, fairly and in a transparent manner;
2. collect it for specified, explicit and legitimate purposes and do not further process it in a manner that is incompatible with those purposes;
3. limit our collection to what is adequate and relevant to what is necessary in relation to the purposes for which they are processed;
4. take reasonable steps to keep it accurate and up to date having regard to the purposes for which they are processed;
5. keep it in a form where we can identify you for no longer than is necessary, for the purposes for which it is processed;
6. process it in a manner that ensures appropriate security of the personal data, which includes protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. We use appropriate technical or organisational measures to do so.

3 - Personal Data Collected

1. The types of personal data we collect from you when you visit our website or contact us is limited to the information you provide us.
2. When you communicate with us or use our services the following data may be collected:
1. Primary account details

4 - Special Categories of Personal Data

1. The special categories of personal data are for personal data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
2. We do not deliberately collect any special categories of personal data from you.
3. We would prefer that you do not send it to us or make it known to us.
4. Should we choose to do so, we may delete the entire communication and ask you to send it again with the special categories of personal data absent. If for some reason we are not able to do so, we do not store it in any structured way and process it only:
   1. where we have your explicit consent;
   2. for employment purposes, such as for job applications;
   3. where the processing relates to personal data which you have made public; and
   4. where processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

5 - Keeping Personal Data up to Date

1. Please help us keep your personal data up to date and let us know when it changes by editing or deleting your website account.
2. At any time, you may contact us in writing to request that we provide you with the personal data we hold about you.

6 - Children

1. We do not sell products or provide services for purchase by children.
2. If you are under 18, you may use our website only with consent and supervision of a parent or guardian.
3. We do not directly communicate with any children through website services and we do not collect personal contact information for any other form of messaging.

7 - Sources of Personal Data

1. We primarily obtain personal data about you from you.
2. We may also obtain information about you from publicly available sources, such as websites where you have made the information public, and any other third parties.
3. We may also confirm information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us and sometimes in order to be able to assess the quality of the services we supply you or you offer. The additional information we collect may be categorised as follows:
1. information that confirms your identity;
2. organisation information,
3. information which confirms your contact information;

8 - How We Use Your Personal Data

1. We process your personal data for the following purposes, where we have a legal basis to do so:
1. to provide our services to you, on behalf of Spiral Horizons CIC,
2. to meet our service contract with Spiral Horizons CIC.
3. assist others to deliver their services to you.

9 - Marketing

1. You may receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
2. You are able to opt out of marketing communications at any time.
3. We do not share your personal data with any external company for marketing purposes.

10 - Legal Basis Further Uses

1. We believe we have legitimate interests to process your personal data to:
1. respond to unsolicited communications from you to which we believe you would expect a response;
2. meet our legal and statutory obligations to you and others;
3. conduct marketing activities, including sending email correspondence and video presentations; and
4. ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
2. We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
3. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11 - Data Sharing

1. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
2. We limit access to your personal information to those employees, agents, contractors and other third parties who need to know. They will only process your personal information on our instructions. They are subject to a duty of confidentiality.
3. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
4. We may have cause to share your personal information with our service providers, such as:
1. Data Sub-processors
5. We only permit them to process your personal data for specified purposes and in accordance with our instructions, where we have a legitimate interest in doing so.

12 - Automated Decision Making

1. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
2. We do not automate decision making in a way that affects your legal rights or any other basis.

13 - Data Storage

1. We store personal data in the UK and France. Where we transfer personal data out of the UK, we do so on the basis that the sub-processor in the country to which we transfer your data is deemed to provide an adequate level of protection for your personal information.

14 - Cookies

1. Cookies contain information that is transferred to your computer's hard drive by our Website. We only use essential cookies to deliver our services, which do not require your consent. They enable us to:
1. Support the use of accounts on our website,
2. Set and hold website display and language options.

15 - Data Security

1. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. As stated above at paragraph 11 above, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
2. We store all information that you provide to us on secure servers.
3. We train employees regarding our data privacy policies and procedures, and permit authorised employees and staff to access information on a need-to-know basis, as required for their role. We use firewalls designed to protect against intruders, test for network vulnerabilities and use encryption for data at rest and data in transmission. However, no method of transmission over the internet or method of electronic storage is completely secure.
4. Where you have a password which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential.

16 - Retention Of Your Data

1. We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
2. 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 requirements.
3. We keep your personal data only for as long as required by us:
1. to provide the services requested by Spiral Horizons CIC;
4. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with applicable laws and regulations. Upon direction from Spiral Horizons CIC we will retain and securely destroy your personal information in accordance with our data retention policy.

17 - Rights of Access, Correction, Erasure, and Restriction

1. You have a series of rights under the UK General Data Protection Regulation.
2. Under certain circumstances, you have the right to:
1. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
4. Object to processing of your personal information 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.
5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; and
6. Request the transfer of your personal information to another party.
3. If you would like to exercise any of these rights, please contact us using the details below. We will need to verify your identity before we are able to release any personal data to you. This is important to safeguard your information.
4. Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us in some circumstances. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
5. If you wish us to remove personal data about you from our website, you should contact us to make your request.
6. We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

18 - Complaints

1. If you are dissatisfied with the way we process your personal data, you have the right to complain to the Information Commissioner's Office.
2. The Information Commissioner may be contacted at:
1. https://ico.org.uk/
3. We would prefer to try and resolve any difficulties between us and make them right before you approach the ICO. Please consider contacting us in the first instance.

19 - Withdrawal of Consent

1. Where you may have provided your consent for us to process your personal data and/or transfer your personal data for a specific purpose, you can withdraw it at any time.
2. To withdraw your consent, please contact us using the details below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. Please see above.

20 - Changes to this Privacy Statement

1. We may need to change this Privacy Statement from time to time. You are able to identify when this Privacy Statement was changed by the date which appears at the bottom of it.
2. Amendments are updated on this page, to the email address stated in your account and/or through a notice on our home page. Your continued use of our website and the resources enabled by our services signifies your consent to such processing and of the conditions set out in this Privacy Policy.

21 - About Us

1. Alpha Colony is a trading name of Fantom Factory Limited, a company formed in accordance with the laws of England and Wales with registered company number 1118 3348 with registered offices situated at 53 Empire Avenue, Cwmgwrach, Neath, SA11 5SU, Wales in the United Kingdom.
2. Fantom Factory Ltd, via Alpha Colony, is responsible for the personal data we hold and process on behalf of Spiral Horizons CIC.
3. We have appointed a data protection officer who is responsible for ensuring that our Privacy Statement is followed. If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our data protection officer at support@alphacolony.io

Version 1.0 Published 30 April 2025