Privacy Notice

This website at morningcrestprotocol.com (the “Site”) is operated by MorningCrest Solutions, a company organised in the United States and trading as Morningcrest Protocol (“we”, “us”, “our”). You can contact us at james@morningcrestprotocol.com.

1. Scope

This notice explains what personal information we collect through the Site and in the course of our work, why we collect it, who we share it with, and the rights you have. It applies to visitors, enquirers and counterparties. It does not apply to third-party sites we link to.

2. Information we collect

• Information you give us. Your name, company, work email, sector, market side and the requirement you describe in the enquiry form, plus anything you send by email or share when booking a call.
• Business contact information. In the ordinary course of our work we hold professional contact details for companies and their representatives, obtained from the individuals themselves, from their employers, or from publicly available business sources.
• Technical information. Our hosting provider processes your IP address and request metadata to deliver the Site and protect it from abuse. Where analytics are enabled they are aggregate and cookieless.
• Your preferences. Your chosen display language is stored in your own browser and is never transmitted to us.

We do not knowingly collect information from children, and the Site is not directed at them.

3. Why we process it, and on what basis

We process personal information to respond to enquiries, to assess whether an introduction is commercially sound, to perform any engagement you enter into with us, and to meet our legal, tax and accounting obligations. Where the UK or EU General Data Protection Regulation applies, our lawful bases are the performance of a contract or steps taken at your request, our legitimate interests in operating and promoting a business-to-business service, and compliance with legal obligations. Where we rely on legitimate interests you may object, as set out below.

4. Sharing

We disclose your details to a counterparty only with your permission. We use service providers who process data on our behalf under contract, including hosting, form handling, scheduling and email providers. We may disclose information where required by law, to establish or defend legal claims, or in connection with a sale or reorganisation of our business. We do not sell personal information, and we do not share it for cross-context behavioural advertising.

5. International transfers

We are based in the United States and our service providers may process data in the United States and elsewhere. Where personal information is transferred out of the UK or the European Economic Area, we rely on appropriate safeguards such as the UK International Data Transfer Agreement or the European Commission’s Standard Contractual Clauses.

6. Retention

We keep enquiry correspondence for up to 24 months from our last contact with you unless it becomes part of an engagement, in which case we keep engagement records for seven years to meet our legal, tax and accounting obligations. After that we delete or anonymise it.

7. Your rights

Depending on where you live, you may have the right to access, correct, delete, restrict or object to our processing of your personal information, to receive it in a portable form, and to withdraw consent where we rely on it. Residents of California and other US states with comparable laws may have rights to know, delete, correct and opt out, and we will not discriminate against you for exercising them. To exercise any right, write to james@morningcrestprotocol.com. We respond within the period the applicable law requires, and we may need to verify your identity first.

If you are in the UK or the EEA and you believe we have not handled your information properly, you may complain to your national supervisory authority.

8. Security

We apply technical and organisational measures appropriate to the sensitivity of the information we hold. No method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

9. Changes

We may update this notice. The date at the top shows when it last changed, and material changes will be identified here.