Privacy Policy

Puleston Jones Limited – Privacy Notice

Last updated: 17 January 2026

Puleston Jones Limited (“we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy. This notice explains how we collect, use, store and share personal data in the course of providing our services and operating our business.

1. Who We Are

Puleston Jones Limited is the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR).

Registered office: Ducks Farm, Dux Lane, Plaxtol, Kent TN15 0RB

Company number: 15359471

Email: simon@emralcarbon.com

2. What Personal Data We Collect

We may collect and process the following categories of personal data:

• Identity data: name, employer, role/title
• Contact data: email address, telephone number, postal address, messaging handles
• Professional data: background, qualifications, transaction role, deal information
• Correspondence data: emails, messages, letters, documents, call notes
• Call and meeting data: audio/video recordings, transcripts and summaries where relevant
• Financial/transaction data: invoices, payment history (if applicable)
• Technical data: IP addresses, browser type, device information (for website use)

We do not intentionally collect special category data unless you voluntarily provide it during communications.

3. How We Collect Personal Data

We collect personal data in the following ways:

• When you contact us by email, phone or messaging platforms
• When you engage us to provide services
• During calls or meetings (including via AI note-taking tools)
• When you visit our website or use online tools we provide
• From publicly available sources (e.g., LinkedIn, company websites)
• From third parties who introduce or refer you to us

4. How We Use Personal Data

We process personal data for the following purposes:

• To provide professional, advisory, consulting or legal services
• To manage client relationships and communications
• To arrange and participate in calls and meetings
• To take accurate notes of calls and meetings (including via AI transcription tools)
• To maintain internal records, files and compliance documentation
• To manage billing, payments and financial administration
• To operate, secure and improve our website and systems
• To comply with legal and regulatory obligations

5. Lawful Bases for Processing

We rely on the following lawful bases under the UK GDPR:

• Contract: where processing is necessary to perform a contract with you or take steps at your request before entering a contract
• Legitimate interests: for business administration, record-keeping, accurate note-taking, and service delivery, balanced against your privacy rights
• Legal obligations: for compliance with applicable laws and regulations
• Consent: where required (for example, for certain marketing communications)

Where we rely on legitimate interests, we have conducted a balancing assessment and you have the right to object (see Section 10).

6. AI Note Takers, Recording and Transcription

We may use AI-assisted tools to:

• Record calls and meetings
• Transcribe spoken audio to text
• Summarise or analyse discussions
• Store transcripts securely

We do this for the legitimate interests of accurate note-taking, professional record-keeping and improving service delivery.

If you wish to object to recording or AI transcription, or you require an alternative arrangement, please inform us before or at the start of the call or meeting.

7. Sharing Personal Data

We may share personal data with:

• Professional service providers (e.g., technical, notetaking, email, cloud, CRM)
• Legal, accounting, or compliance advisors
• Insurers or brokers where relevant to a transaction or service
• Counterparties where required in the context of a transaction or engagement
• Law enforcement or regulators where required by law

We do not sell personal data to third parties.

8. International Transfers

Some of our service providers may be located outside the UK. Where personal data is transferred internationally, we ensure appropriate safeguards are in place, such as:

• UK GDPR adequacy regulations, or
• Standard Contractual Clauses (SCCs) or equivalent mechanisms

Details can be provided on request.

9. Data Retention

We retain personal data only for as long as necessary for the purposes described above, including:

• To provide ongoing services
• To maintain business and legal records
• To comply with statutory or regulatory requirements

Retention periods may vary depending on the type of data and legal context.

10. Your Data Protection Rights

Under the UK GDPR you have the following rights (subject to certain conditions):

• Access: to request a copy of your personal data
• Rectification: to correct incomplete or inaccurate data
• Erasure: to request deletion of your data in certain circumstances
• Restriction: to limit how we use your data
• Objection: to object to processing based on legitimate interests
• Portability: to receive your data in a structured, machine-readable format
• Withdraw consent: where processing is based on consent

To exercise any of these rights, contact us using the details in Section 1.

11. Security

We implement technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure or alteration. Access to personal data is restricted to authorised individuals on a need-to-know basis.

12. Complaints

If you have concerns about how we process your personal data, please contact us first. You also have the right to complain to the UK Information Commissioner’s Office (ICO):

Website: https://ico.org.uk/

Telephone: +44 (0)303 123 1113

13. Changes to This Notice

We may update this Privacy Notice from time to time. The latest version will always be available on request or published on our website.