Privacy policy
Effective date: 29 September 2026
This Privacy Policy explains how Foundational Limited (“Foundational”, “we”, “us”, “our”) collects, uses, shares, and protects your personal data when you use our website and the Origin platform. We are the data controller and process personal data in accordance with the UK GDPR and the Data Protection Act 2018.
1. Data Collection
We collect personal data you provide and data collected automatically. When you request access via our website form, we collect your name, company name, email address, your orbits of interest, your data-object interests, and whether you opt in to updates. If you are granted access to Origin, we hold account data managed through our identity provider (name, email, authentication credentials, and your organisation). We also collect usage and technical data (how you interact with our site and platform, device and browser information, and IP address), records of your communications with us, and information via cookies and similar technologies (see “Cookies and Other Data Collection Tools”).
2. Using Your Personal Data
We use your personal data to: assess and action access requests and provision accounts (legitimate interests; steps prior to a contract); provide and operate Origin (performance of a contract); send service and security communications (legitimate interests / contract); send product updates and marketing where you have opted in (consent); analyse and improve our services (legitimate interests, or consent where cookie-based); maintain security and prevent fraud (legitimate interests); and meet legal and regulatory obligations, including compliance and export-control requirements (legal obligation / legitimate interests). Where we rely on legitimate interests, we have balanced these against your rights and freedoms.
3. Sharing Your Personal Data
We share personal data only with: service providers acting on our instructions (including our identity provider, hosting and cloud infrastructure, and analytics and email providers); professional advisers where necessary; and authorities or regulators where required by law. We do not sell your personal data.
4. International Transfers
Some of our providers process personal data outside the United Kingdom. Where they do, we put appropriate safeguards in place — such as UK adequacy regulations, the UK International Data Transfer Agreement or Addendum, or equivalent measures. Details are available on request.
5. Updating Your Information
You can ask us to update or correct your personal data at any time by emailing info@foundational.space.
6. Protecting Your Personal Data
We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
7. Third-Party Websites
Our website may link to third-party websites we do not control. This policy does not apply to those sites, and we are not responsible for their privacy practices. Please review their own policies before providing them with personal data.
8. Children’s Privacy
Our website and services are not directed at children, and we do not knowingly collect personal data from anyone under the age of 13. If you believe a child has provided us with personal data, please contact us and we will delete it.
9. Cookies and Other Data Collection Tools
We use strictly necessary cookies required for the website to function. Our website analytics are cookieless, so no consent is required for them.
10. Data Retention
We keep personal data only as long as necessary for the purposes described in this policy or as required by law. Access-request data is retained for 12 months, and account data for the duration of the relationship and six years afterwards.
11. Your Rights
Under the UK GDPR you have the right to access your data; to rectify inaccuracies; to erase it; to restrict or object to processing; to data portability; and to withdraw consent at any time (without affecting processing carried out beforehand). To exercise any of these rights, email info@foundational.space; we will respond within one month. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk, though we would welcome the chance to resolve any concerns first.
12. Modifications to this Privacy Policy
We may update this Privacy Policy from time to time. Changes take effect when we post the updated policy, and the effective date above reflects the latest version.
13. Contact
Foundational Limited is the data controller. We are registered in England and Wales, company number 16515763, with registered office at 167–169 Great Portland Street, London, W1W 5PF. For any privacy questions or to exercise your rights, contact info@foundational.space.