B2B PRIVACY POLICY | THE PRIMAL AXIS

VERSION 1.1 | EFFECTIVE DATE: 08 APRIL 2026

1. INFORMATION WE COLLECT 1.1 Contact Details: We collect and process names, business email addresses, telephone numbers, and physical business addresses. 1.2 Protocol Diagnostics: We process data relating to organisational audits, identified internal operational friction points, and strategic assessments. 1.3 Financial Data: We maintain records of issued invoices and digital payment confirmation receipts; we do not store full credit or debit card information. 1.4 Voluntary Disclosures: We process strategic insights regarding organisational health or psychological friction provided voluntarily during the Diagnostic phase.

2. LAWFUL BASIS FOR PROCESSING 2.1 Contractual Necessity: Data is processed to facilitate the delivery of the Axis Protocol and associated strategic services. 2.2 Legal Obligation: Records are maintained to ensure full compliance with UK tax and accounting regulations. 2.3 Explicit Consent: Where sensitive insights are shared for the purpose of high-level advisory, processing is based on your direct and informed consent.

3. UTILISATION OF INFORMATION 3.1 Service Delivery: Data is used exclusively to provide tailored strategic advisory and to execute the Axis Protocol. 3.2 Administrative Management: Information is used to manage settlement verification, project scheduling, and operative licensing. 3.3 Statutory Compliance: Records are held to meet all necessary HMRC requirements and professional insurance standards.

4. DATA INFRASTRUCTURE & SECURITY 4.1 Digital Security: All digital records are held within an encrypted, password-protected infrastructure utilising enterprise-grade two-factor authentication (2FA). 4.2 Physical Integrity: Any physical documentation is stored in secured facilities and either digitised into a secure format or destroyed via high-security shredding. 4.3 Third-Party Disclosure: We do not sell personal or business data. Data is shared with third-party processors (such as banking institutions) only as required to facilitate settlement or as mandated by UK law.

5. DATA RETENTION 5.1 Diagnostic Records: Retained for 7 years after the final phase of the Protocol, in accordance with UK professional insurance and legal recommendations. 5.2 Financial Records: Retained for a minimum of 6 years as required by HMRC statutory guidelines.

6. INDIVIDUAL RIGHTS (GDPR) 6.1 Access & Correction: You retain the right to request a copy of the data held by The Primal Axis and to request corrections to any inaccuracies. 6.2 Erasure: You may request the deletion of data where it does not conflict with our legal retention duties (e.g., tax records). 6.3 Regulatory Oversight: You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) regarding data handling practices.

7. CONTACT & OVERSIGHT 7.1 Data Controller: For all queries regarding data protection, contact Gary West at: gary@primalaxis.co.uk