Last updated: 5 October 2026
1. Who we are
1.1 Actio Limited, a company incorporated in Gibraltar under company number 126925, with its registered office at 13 Irish Town, Gibraltar GX11 1AA ("ACTIO", "we", "us"), is the controller of personal data collected through actioclaim.com (the "Website").
1.2 Contact for privacy matters: info@actioclaim.com. [Insert Data Protection Officer details if appointed.]
1.3 We process personal data in accordance with the Gibraltar General Data Protection Regulation and the Data Protection Act 2004 (Gibraltar), and, where applicable, the EU General Data Protection Regulation (EU) 2016/679 and the UK GDPR.
1.4 This policy covers the Website. Personal data processed within the ACTIO platform on behalf of clients (including data contained in case files) is governed by the client's subscription agreement and data processing terms.
2. Personal data we collect
| Category | Examples | Source |
|---|---|---|
| Contact and identity | Name, firm or organisation, role, work email, country | Demo, pricing and investor forms |
| Enquiry details | Approximate claim volume, plan interest, message content | Forms |
| Investor eligibility | Eligibility self-declaration, country of residence | Investor area |
| Account data | Log-in email, authentication records | Platform log-in (clients only) |
| Technical and usage | IP address, browser and device type, pages viewed, referring site, approximate location | Cookies and server logs |
2.1 We do not seek to collect special category data through the Website. Do not submit case documents, health information or other sensitive data through Website forms.
3. How and why we use personal data
| Purpose | Lawful basis |
|---|---|
| Responding to demo, pricing and general enquiries | Steps at your request prior to entering a contract; legitimate interests in responding to business enquiries |
| Managing investor registrations and eligibility checks | Legitimate interests; compliance with legal obligations |
| Providing platform access to clients | Performance of a contract |
| Sending follow-up information about ACTIO to business contacts | Legitimate interests; consent where required by law. You can opt out at any time |
| Operating, securing and improving the Website | Legitimate interests |
| Analytics cookies | Consent |
| Complying with legal and regulatory obligations, and establishing or defending legal claims | Legal obligation; legitimate interests |
4. Automated decision-making
4.1 The Website does not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.
4.2 The ACTIO platform uses automated analysis to assess claims. Where such analysis relates to an identifiable individual, it is used to support decisions made by qualified people. Individuals have the right to request human review of any decision based solely on automated processing, to express their point of view and to contest the decision, under Article 22 of the GDPR.
5. Sharing personal data
5.1 We share personal data only with:
- (a) service providers acting on our instructions, including website hosting, form-handling, email, analytics and IT providers;
- (b) professional advisers, including lawyers, accountants and auditors;
- (c) partner law firms, funders or insurers, only where you have asked to be introduced to them or have instructed us to share;
- (d) regulators, courts, law enforcement or other authorities where required by law;
- (e) a purchaser or successor in connection with a sale, merger or reorganisation of our business.
5.2 We do not sell personal data.
6. International transfers
6.1 Some service providers are located outside Gibraltar, the UK and the EEA. Where we transfer personal data to a country without an adequacy decision, we use appropriate safeguards, such as standard contractual clauses approved by the relevant authority.
7. Retention
7.1 Enquiry and contact data: up to [24] months from last contact, unless a business relationship follows.
7.2 Investor registration data: for the duration of the relationship and up to [6] years after, or longer where required by law.
7.3 Client account data: as set out in the subscription agreement.
7.4 Technical and analytics data: up to [13] months.
8. Security
8.1 We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls and restricted staff access. [Describe hosting region and encryption at rest once confirmed.]
9. Your rights
9.1 Subject to applicable law, you have the right to: access your personal data; correct inaccurate data; erase data; restrict or object to processing (including direct marketing); data portability; withdraw consent at any time where processing is based on consent; and not be subject to decisions based solely on automated processing (see section 4).
9.2 To exercise any right, email info@actioclaim.com. We will respond within one month.
9.3 You may lodge a complaint with the Gibraltar Regulatory Authority (www.gra.gi), or with the supervisory authority in your country of residence or work.
10. Cookies
10.1 The Website uses strictly necessary cookies to function and, with your consent, analytics cookies to understand how the Website is used. You can accept or reject non-essential cookies through the cookie banner and change your choice at any time through [Cookie settings link]. [List cookies, providers and durations once analytics tools are chosen.]
11. Changes
11.1 We may update this Privacy Policy. The current version is always on the Website with its "Last updated" date.