Privacy Policy

Last updated: 24 May 2025

1. Introduction

At Capodan Research Ltd ("Capodan", "we", "us", or "our"), we are committed to protecting the privacy of everyone we engage with, whether you are a research participant, a client, a website visitor, or a professional contact.

This Privacy Policy explains how we collect, use, store, and share personal data, and outlines your rights under data protection law, including the UK General Data Protection Regulation (UK GDPR). It applies to personal data we process in the course of delivering research projects, providing consultancy services, operating our website, and communicating with our network.

We believe in transparency and clarity. That means being clear about what we collect, why we collect it, and how we keep it safe. We only use personal data for legitimate purposes, and we always strive to handle it with care and respect.

If you have any questions about this policy or how we handle your data, you can contact us at:

Email: contact@capodan.com

2. Who We Are

Capodan Research Ltd is an independent research and consultancy company based in the UK. We specialize in uncovering the deeper meaning behind language, helping organizations align their communications, strategies, and value propositions with the people they serve.

We conduct qualitative and quantitative research, including interviews, surveys, workshops, discourse analysis, and linguistic modeling. Our clients span multiple sectors, from marketing and media to technology, finance, and the public sector.

In the course of our work, Capodan may act as a data controller (when we collect data directly) or a data processor (when data is shared with us by a client). We always ensure that our data handling practices comply with applicable data protection laws.

Company details:
Capodan Research Ltd
Company number: 16292639
Registered office: First Floor, Swan Buildings, 20 Swan Street, Manchester, M4 5JW
Email: contact@capodan.com

3. What Data We Collect

The personal data we collect depends on your relationship with Capodan, whether you're a research participant, a client contact, a website visitor, or someone whose data appears in publicly available sources. We only collect what is necessary and appropriate for the project or interaction.

We may collect the following types of personal data:

• Contact details: name, email address, phone number, job title, organization
• Demographic information: age, gender, region, profession, or sector (where relevant and provided)
• Research responses: interview or survey answers, audio/video recordings, transcripts, feedback or comments
• Technical data: IP address, browser type, location data (when visiting our site)
• Usage and interaction data: how you use our website, open our emails, or engage with our tools

Publicly available and scraped data:

We may collect publicly available information from online sources, such as websites, forums, product reviews, and social media platforms, where permitted by law and platform terms. This is used to conduct language analysis, sentiment research, or keyword studies. We do not attempt to identify individuals from this data unless the content is already published in an attributable, public-facing context (e.g. professional reviews or statements).

When we use such data, we process it in aggregated or anonymized form wherever possible. Identifiable elements are only retained when necessary, legally permitted, and aligned with the research purpose.

We do not knowingly collect data from children under 13. If we need to do so, we always obtain verifiable parental or guardian consent in advance.

4. How We Collect Personal Data

Capodan collects personal data in a number of ways, depending on how you engage with us. We only collect data that is relevant, proportionate, and necessary for the specific purpose we are pursuing.

We collect data through the following channels:

• Directly from you: when you complete a survey, take part in an interview or discussion, respond to a form, sign up for updates, or contact us
• Through our clients: when we are commissioned to conduct research and the client shares relevant personal data with us under a data processing agreement
• Through your use of our website: via cookies and analytics tools that capture usage behavior, browser type, IP address, and site interactions
• From publicly available sources: where we collect open data such as online reviews, forum content, social media posts, or public registers to support linguistic and sentiment analysis

In all cases, we ensure that data is collected lawfully and transparently, and that individuals are informed where required. For web-sourced data, we avoid intrusive collection methods and aim to anonymize or aggregate the information unless it is clearly published in a professional or public capacity.

5. Why We Use Your Data (Purposes & Legal Bases)

Capodan processes personal data to support our research, consultancy, and communication activities. We only collect and use data where we have a clear and lawful basis for doing so, in line with the UK General Data Protection Regulation (UK GDPR).

Our main purposes for using personal data include:

• Delivering qualitative and quantitative research services, including surveys, interviews, and discourse analysis
• Providing insight consultancy to help clients understand customer perceptions, language use, and value alignment
• Administering our website and digital platforms, improving user experience, and tracking engagement with our content
• Managing client relationships, project communication, and commercial contracts
• Recruiting and managing participation in research studies
• Conducting analysis of publicly available data (e.g. reviews, forums) to identify patterns, sentiment, and trends

The lawful bases we rely on include:

• Consent: where individuals voluntarily take part in research or submit information through our site or tools
• Legitimate interest: where we use data to deliver our services, respond to enquiries, maintain business relationships, or analyze publicly available language data, provided it does not override your rights or freedoms
• Contract: where data is needed to fulfill a contract or agreement with you or your organization
• Legal obligation: where we are required to retain or share information by law (for example, for accounting or safeguarding purposes)

When processing special category data such as information relating to ethnicity, beliefs, or health, we only do so with explicit consent and a clear research purpose. These data types are always optional, and participation is never conditional on providing them.

6. How We Share Your Data

Capodan takes data confidentiality seriously. We do not sell your personal data and we only share it where necessary to deliver our services, comply with the law, or fulfill a legitimate interest that does not override your rights.

We may share your data with:

• Clients: We may share anonymized research findings, summaries, or aggregated data with the organization that commissioned the project. Personal identifiers are never included unless you have given clear, explicit permission.
• Third-party service providers: We use trusted platforms to support our work, such as survey tools, transcription services, video conferencing platforms, and secure cloud storage. All providers are bound by data processing agreements and comply with UK GDPR.
• Internal team and contractors: Our researchers and analysts may access your data for the purposes of analysis or delivery. All personnel are trained in data protection and bound by confidentiality agreements.
• Safeguarding or legal authorities: If you disclose something that suggests you or someone else may be at risk of harm, we may need to share relevant information with an appropriate authority to protect wellbeing and safety.

Examples of third-party tools we use include: Microsoft 365, SharePoint, Teams, Zoom, Google Workspace, Typeform, and Qualtrics. Where we use software with data storage outside the UK, we ensure safeguards are in place such as Standard Contractual Clauses.

We will never use your data for unrelated purposes or share it for direct marketing unless you have explicitly opted in.

7. Cookies and Tracking Technologies

Capodan uses cookies and similar technologies on our website to improve performance, understand how visitors use the site, and support delivery of our online tools. Cookies are small text files stored on your device that help websites remember your preferences and actions.

We use the following categories of cookies:

• Strictly necessary cookies: Enable essential site functionality such as navigation, page load performance, and security. These cannot be switched off in our systems.
• Performance and analytics cookies: Help us understand how visitors interact with the site, such as which pages are visited most. We may use tools like Google Analytics, only with your consent.
• Functionality cookies: Remember choices you make (e.g. region or language settings) to personalise your experience.

We do not use cookies for advertising or tracking for marketing purposes. If this changes, this policy will be updated and your consent will be requested.

Your choices: You can manage your cookie preferences through our cookie banner or by adjusting your browser settings. Declining non-essential cookies may affect certain features or functionality.

For full details, please see our Cookie Policy.

8. International Data Transfers

Capodan operates primarily within the United Kingdom. However, some of the third-party tools and platforms we use may store or process data outside the UK or European Economic Area (EEA).

When personal data is transferred internationally, we ensure that appropriate safeguards are in place to protect it. This may include:

• Standard Contractual Clauses approved by the UK Information Commissioner’s Office (ICO) or European Commission
• UK International Data Transfer Agreements (IDTAs)
• Vendors certified under recognized frameworks, where applicable

We regularly review the data protection policies of our suppliers and only work with service providers who meet GDPR-equivalent standards of privacy and security.

We also aim to respect international privacy standards, including the EU GDPR, where applicable to individuals located outside the UK. If you are based outside the UK and have concerns about how your data is handled, please contact us to discuss further.

If you would like more information about how and where your data may be transferred, or the specific safeguards in place, please contact us at contact@capodan.com.

9. How Long We Keep Your Data

Capodan retains personal data only for as long as it is needed for the purposes outlined in this policy, or as required by law. We aim to keep data no longer than necessary, and we review retention regularly to ensure data is either deleted or anonymized when appropriate.

Typical retention periods include:

• Research participant data: Personal identifiers are deleted within 12 months of collection unless we have received your explicit consent to retain them for follow-up research. Anonymized research responses may be kept for longer for comparison, trend analysis, or reporting purposes.
• Client and project data: Contact and contract-related data may be kept for up to 6 years for legal, financial, and accountability purposes.
• Website analytics and cookie data: Retained for a maximum of 26 months unless otherwise specified in our Cookie Policy.

We securely delete or anonymize data once the retention period has ended or the original purpose has been fulfilled.

10. How We Protect Your Data

Capodan takes data security seriously and implements a combination of technical, organizational, and contractual measures to protect the personal data we hold from unauthorized access, loss, misuse, alteration, or disclosure.

Our security measures include:

• Secure cloud storage using platforms with built-in encryption and access controls (e.g. Microsoft 365, SharePoint)
• Restricted access to personal data, limited only to those who need it for their role
• Use of secure file transfer tools and password protection for sensitive materials
• Regular review of third-party processors and software providers to ensure GDPR compliance
• Internal staff training on data protection and responsible handling of client and participant information

We continually assess risks and update our processes to align with industry best practice. While no method of transmission or storage is entirely risk-free, we take appropriate steps to minimize exposure and respond promptly to any concerns.

11. Your Rights Under UK GDPR

As someone whose personal data may be processed by Capodan, you have rights under the UK General Data Protection Regulation (UK GDPR). We are committed to upholding these rights and making it easy for you to exercise them.

You have the right to:

• Be informed: Know what data we collect, how we use it, and why, which this policy provides
• Access your data: Request a copy of the personal data we hold about you
• Rectification: Ask us to correct inaccurate or incomplete personal data
• Erasure: Request that we delete your personal data in certain circumstances (also known as the “right to be forgotten”)
• Restrict processing: Ask us to limit how we use your data under certain conditions
• Object to processing: Challenge how we use your data, including for profiling or where we rely on legitimate interest
• Withdraw consent: Withdraw your consent at any time if that is the legal basis we are relying on
• Data portability: Request that we transfer your personal data to another organization or to you, where applicable

To exercise any of these rights, please contact us at contact@capodan.com. We may need to verify your identity before we respond. We aim to respond within one month of receiving your request.

12. How to Contact Us

If you have any questions about this Privacy Policy, the data we hold about you, or if you would like to exercise your rights, please get in touch. We are happy to help and committed to responding promptly and transparently.

Contact details:

Capodan Research Ltd
First Floor, Swan Buildings
20 Swan Street
Manchester, M4 5JW
Email: contact@capodan.com

13. How to Complain

We take data protection seriously and aim to resolve any concerns quickly and fairly. If you have a complaint about how we have handled your personal data, please contact us first using the details above. We will investigate and respond to your concerns as soon as possible.

If you are not satisfied with our response, or believe that we are not processing your personal data in accordance with data protection law, you have the right to lodge a complaint with the UK’s data protection authority:

Information Commissioner’s Office (ICO)
Website: https://ico.org.uk
Helpline: 0303 123 1113

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal obligations, or data protection practices. Any updates will be published on this page with a revised “last updated” date at the top of the policy.

We encourage you to review this policy periodically so that you stay informed about how we protect your personal data. If we make any significant changes that affect your rights or the way we process your data, we will notify you where appropriate.

15. Use of AI and Automated Processing

Capodan does not use artificial intelligence (AI) or automated decision-making to evaluate individuals or to make decisions that would produce legal or significant effects on them.

In some projects, we may use software to assist with tasks such as keyword detection, clustering, or language pattern identification. These tools are used solely to support human-led analysis and insight generation, and any findings are always reviewed and interpreted by our research team.

We do not use your personal data to train AI models or systems. If this ever changes, we will update this policy and seek your explicit consent where required.