Privacy Policy
Last updated: 25 October 2025
Key Diligence Ltd conducts research on businesses and organisations, the broad focus of this being (but not limited to) the commodities trading and trade finance sectors. This privacy notice outlines what to expect us to do with any personal information we collect as part of our core business activities and client outreach.
Content:
Our contact details
What information we collect, use, and why
Lawful bases and data protection rights
Where we get personal information from
How long we keep information
Who we share information with [when required]
Sharing information outside the UK
How to complain
Our Contact Details
Email: contact@keydiligence.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
Names and business contact details
Business addresses
Payment details (including card or bank information for transfers and direct debits)
Transaction data (including details about payments to and from you and details of products and services you have purchased)
Usage data (including information about how you interact with and use our website, products and services)
Criminal offence data (collected/processed on the lawful basis described as “legitimate interests” as set out by UK GDPR)
We collect or use the following personal information for the operation of client or customer accounts:
Names and business contact details
Business addresses
Purchase or service history
Account information, including registration details
Marketing preferences
We collect or use the following personal information for information updates or marketing purposes:
Names and business contact details
Business addresses
Marketing preferences
Purchase or account history
IP addresses
We collect or use the following personal information for research or archiving purposes:
Names and business contact details
Business addresses
Purchase or client account history
We may need to collect or use the following personal information to comply with legal requirements:
Name
Contact information
Identification documents
Client account information
Any other personal information required to comply with legal obligations
Safeguarding information
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and business contact details
Business addresses
Payment details
Account information
Purchase or service history
Customer or client accounts and records
Financial transaction information
Correspondence
Information we collect about you automatically each time you visit our website
Information we may collect through the use of cookies (see our cookie policy).
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s (Information Commissioner’s Office) website (https://ico.org.uk/).
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
To make a data protection rights request, please contact us using the contact details at the top of this privacy policy summary.
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for research or archiving purposes:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information to comply with legal requirements:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Where we get personal information from
Directly from you
Publicly available sources
Market research organisations
Credit reference agencies
Suppliers and service providers
How long we keep information
We will hold information relating to tax for as long as we are required to retain this information by applicable tax law
We will keep information relating to our research reports for as long as required in the context of our research and related future research activities
Account information is kept as long as the customer/client/supplier is active and thereafter at the latest for the relevant legal limitation period under UK or other applicable law
Other information is kept for as long as we have a legitimate need to retain and use this
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided at the top of this privacy policy summary.
Who we share information with [when required]
Clients
Professional or legal advisors
Regulatory authorities
External auditors
Organisations we are legally obliged to share personal information with
Suppliers and service providers
Professional consultants
Sharing information outside the UK
Where necessary, we may transfer personal information outside of the UK, including to:
Clients located outside the UK
Third-party agents subcontracted by us
We aim to comply with the UK GDPR when transferring information outside the UK, although it is highlighted that other countries may not have the same data protection laws as the UK.
For further information, please contact us using the contact information provided at the top of this privacy policy summary.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
