Privacy Policy

Last updated: 29 September 2026

XP/ND (“XP/ND”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store and share personal information when you visit our website, contact us, make an enquiry, do business with us or interact with us in a professional capacity.

Who we are

XP/ND, company number HE470167, is the controller responsible for the personal information described in this Privacy Policy.

Our registered office is Spartis 1, Pahos, 8020, Cyprus.

For privacy enquiries, contact privacy@xpnd.work.

Information we collect

Depending on how you interact with XP/ND, we may collect:

  • your name;
  • job title and employer or organisation;
  • business email address and telephone number;
  • postal or business address;
  • information contained in enquiries, correspondence and communications with us;
  • information about your business, commercial requirements, services of interest or potential engagement with XP/ND;
  • records of our business relationship and previous communications;
  • information made publicly available in a professional or business context, including information available through company websites, LinkedIn and similar professional sources; and
  • technical information about use of our website, such as IP address, browser, device and website usage information where this is collected through analytics or similar technologies.

We do not intentionally collect special category personal information through this website and ask that you do not include unnecessary sensitive personal information in enquiries.

How we obtain personal information

We may obtain personal information directly from you when you:

  • submit a form or enquiry through our website;
  • contact us by email, telephone, LinkedIn or another communication channel;
  • enquire about our services;
  • engage with us regarding a proposal or business relationship; or
  • otherwise communicate with XP/ND.

We may also obtain professional contact information from publicly available sources, including company websites, professional directories and LinkedIn, or through introductions and existing business relationships.

How we use personal information

We may use personal information to:

  • respond to enquiries and requests;
  • discuss your business and commercial requirements;
  • prepare proposals and discuss potential engagements;
  • provide and administer our services;
  • manage customer, supplier and other business relationships;
  • maintain records of enquiries, engagements and correspondence;
  • identify organisations and professional contacts who may have a relevant interest in XP/ND’s services or content;
  • communicate with existing and prospective business contacts;
  • send relevant business-to-business marketing and commercial communications where permitted by law;
  • manage and improve our website;
  • understand website usage and performance;
  • maintain the security and integrity of our website and business systems;
  • comply with legal and regulatory requirements; and
  • establish, exercise or defend legal claims.

Our lawful bases for using personal information

We process personal information only where we have an appropriate lawful basis.

Depending on the circumstances, we may process personal information because:

It is necessary for a contract or steps requested before entering into a contract. This may apply where you ask us to provide a proposal, discuss an engagement or provide services.

We have a legitimate interest. This may include operating and developing our business, responding to business enquiries, managing customer and supplier relationships, maintaining business records, identifying prospective customers, communicating with relevant professional contacts, conducting appropriate business-to-business marketing, improving our website and protecting our business and systems.

Where we rely on legitimate interests, we consider whether our use of the information is necessary and proportionate and balance our interests against the rights and interests of the individual concerned.

We need to comply with a legal obligation. This may apply to information we are required to retain or disclose by law.

You have given consent. Where consent is required for a particular activity, you may withdraw it at any time.

Business development and direct marketing

XP/ND may identify organisations and professional contacts that we reasonably believe could have an interest in our services, content or the commercial subjects we work on.

For this purpose, we may use business contact information that has been provided directly to us or is available from professional and publicly accessible sources, including LinkedIn and company websites.

We may contact relevant individuals through professional networks, LinkedIn, business email or other appropriate business channels, subject to applicable data protection and electronic marketing laws.

Where we rely on legitimate interests for processing personal information connected with business development, our interests include developing our business, establishing and maintaining relevant professional relationships and communicating information about services or commercial subjects that may be relevant to those relationships.

You have the right to object at any time to the use of your personal information for direct marketing. If you ask us to stop, we will stop using your information for that purpose.

We may retain limited information on a suppression record so that we can respect your request in future.

Website forms

Information submitted through our website is sent by email to XPND and held in its Zoho-hosted mailbox.

We use this information to respond to enquiries, manage potential and existing business relationships and maintain appropriate records of our communications.

Website analytics and cookies

We use analytics technologies, including Google Analytics, to understand how visitors use our website and to measure and improve website performance.

Where cookies or similar technologies require consent, they will not be used until the appropriate consent has been obtained.

More information is available in our Cookie Policy.

Sharing personal information

We may share personal information where necessary with organisations that support our business, such as:

  • email providers, including Zoho;
  • website analytics providers, including Google;
  • IT, email, hosting and website service providers;
  • other business software and service providers;
  • professional advisers; and
  • regulators, public authorities, courts or other parties where disclosure is required by law or necessary to establish, exercise or defend legal rights.

We do not sell personal information.

Where another organisation processes personal information on our behalf, we take appropriate steps to protect that information.

International transfers

Some of the service providers or business systems we use may process personal information in countries other than the country in which it was originally collected.

Where personal information is transferred internationally, we use appropriate safeguards where required by applicable data protection law.

How long we keep personal information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including legitimate business, contractual, legal and regulatory purposes.

The appropriate retention period depends on the nature of the information and our relationship with you.

Customer, supplier and business records may be retained for longer periods where they remain relevant to an ongoing business relationship, contractual obligations, legal requirements or potential claims.

For prospective customers and enquiries that do not develop into an ongoing business relationship, we periodically review the information we hold and delete or anonymise personal information when it is no longer reasonably required.

We may retain limited information where necessary to record a marketing objection or other request.

Keeping information secure

We take appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

Your rights

Depending on the circumstances and the law that applies, you may have rights concerning your personal information, including the right to:

  • request access to personal information we hold about you;
  • ask us to correct inaccurate or incomplete information;
  • request deletion of your information in certain circumstances;
  • request restriction of processing in certain circumstances;
  • object to certain processing based on legitimate interests;
  • object at any time to processing for direct marketing;
  • request transfer of certain information where the right to data portability applies; and
  • withdraw consent where processing is based on consent.

These rights are not absolute in every circumstance.

To exercise a right, contact privacy@xpnd.work.

Complaints

If you have concerns about how we use your personal information, please contact us first so that we can investigate.

You may also have the right to complain to the data protection supervisory authority responsible for dealing with your complaint.

Third-party websites

Our website may contain links to websites operated by third parties.

Those organisations are responsible for their own websites and privacy practices. We recommend reviewing their privacy information when visiting their websites.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our business, website, systems, marketing activities or legal requirements.

The current version will be published on this website with the date of the latest update.

Contact

For questions about this Privacy Policy or the way XP/ND uses personal information, contact:

privacy@xpnd.work

XP/ND
Company number HE470167
Spartis 1
Pahos
8020
Cyprus