Privacy | Numeritas

Introduction

Numeritas Limited (part of the Factotum group of companies) (“We”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use http://www.numeritas.co.uk/Terms and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the UK General Data Protection Regulation and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025. Where we process personal data about individuals in the European Union, the EU General Data Protection Regulation may also apply. In this notice, “GDPR” means whichever of these applies.

1. Definitions

Data controller – A controller determines the purposes and means of processing personal data.

Data processor – A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 4(1) of the GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

Numeritas Limited is the data controller, or in the case of our anti-money laundering checks is a joint data controller with SmartCredit Limited (t/a SmartSearch, Mayfield House, Lower Railway Road, Ilkley, Leeds LS29 8FL). This means we decide how your personal data is processed and for what purposes. Our registered office is c/o Factotum Group LLP, The Kinetic Centre, Theobald Street, Borehamwood, Hertfordshire WD6 4PJ and our correspondence address is 180 Strand, London, WC2R 1EA. We are registered with the Information Commission under registration number ZB559228. For all data matters contact Stephen Aldridge, on ku.oc.satiremun@ofni.

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

If you are an employee of a client company or a company involved in any project in which Numeritas is providing services, we will process your data in connection with services we provide to our client. We may also process your data in order to provide marketing material to promote our services and to inform you of news, events or activities.

We use business-grade AI tools to help us carry out some of these purposes efficiently. See ‘Use of artificial intelligence (AI) tools’ below.

If you download and use nXt, our free Excel add-in, see ‘Our nXt Excel add-in’ below for the data it collects.

You may give us information about you by filling in forms on our website www.numeritas.co.uk, or landing pages (where you are accessing our online resources), or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site or to receive information from us, or if you email us or are copied on emails to us, enter a competition, promotion or survey or participate in discussion groups on our site or on social media.

Our website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. If you fill in any form on our website, the cookies on that machine will be associated with your contact details.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

Identity data includes contact details (email address, company, role, phone number IP Address, information about the hardware and software used to access our website and any other information you give us or is given to us by a related party). We process information about your device hardware and software used to access our website and microsites. We may also process your photograph, career history and publicly available information about you.
Communications data includes our communications with you by email, text, social media, telephone and any other means.
Usage Data includes pages you have visited on our website, resources you have accessed and files you have downloaded, events you have registered for or attended and other use of content we offer. This information will be associated with your IP address and if you submit your contact details in a form will be associated with your email address and other Contact Data.
Content data includes personal data contained in documents, spreadsheets, financial models, emails and meeting notes shared with us in connection with a project (for example names, job titles and, occasionally, salary or payroll information within a financial model).
nXt data includes your registration email address, technical details about your computer and Excel installation, a pseudonymous computer ID and your IP address, sent by our nXt Excel add-in (see ‘Our nXt Excel add-in’ below).

We have obtained your personal data from you, or from one of our clients, prospective clients or someone related to a project that we are involved in, or an enquiry made to us. We may also process data about you that is publicly available on social media, websites or correspondence we receive.

5. What is our legal basis for processing your personal data?

a) Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data depends on your relationship with us. The following lawful basis applies in each situation described below:

Consent of the data subject;	If you have told us that the email you use to communicate with us is a personal (non-commercial) email address, we ask for your consent to send marketing information. You have the right to withdraw consent to marketing information at any time using preference links on every marketing email we send. Where you opt out of receiving marketing information, this will not apply to personal data provided as a result of an enquiry or involvement in a client project or other transaction.
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract	If you are an employee of Numeritas Ltd or a prospective employee of Numeritas Ltd.
Processing necessary for compliance with a legal obligation	If we are required to identify you as part of our anti-money laundering due diligence or other regulatory obligation we are subject to.
Processing necessary to protect the vital interests of a data subject or another person	N/A
Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller	N/A
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject	If you are an employee or contractor working for a client or are involved on a project that we are working on we have a legitimate interest in processing your data in connection with the delivery of our services and for the purpose of business development. If you use your personal email address in relation to a client project or enquiry as described above, we will treat this as a commercial email address and the legitimate interest purpose will apply. This includes using business-grade AI tools to help our staff prepare, review and check our work efficiently (see ‘Use of artificial intelligence (AI) tools’ below). We have balanced this interest against your rights and freedoms and apply the safeguards described in that section.

More information on lawful processing can be found on the Information Commission website.

6. Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with:

Our advisors, which include legal, technical, IT, financial, HR and other business advisors.
Our cloud software providers, for example Hubspot.com
Our IT and productivity service providers, including Microsoft (Microsoft 365, including Microsoft Copilot Chat), acting as our data processors.
Anthropic, the provider of Claude, an AI assistant we use under a business (Team) plan, acting as our data processor.
SmartSearch, for anti-money laundering identity checks.
Our web hosting provider, which stores nXt registration and update-check data as our processor.
Other companies in the Factotum group, where needed for group administration, reporting and shared services.

How long do we keep your personal data?

We keep your personal data only for as long as we need it for the purposes set out in this notice. In particular:

client and project records, including personal data in models and correspondence: seven years after the end of the engagement, so that we can meet legal, regulatory and insurance requirements and defend any legal claims;
marketing contacts: until you opt out, or three years after our last meaningful contact with you;
anti-money laundering records: five years after the end of our business relationship, in line with the Money Laundering Regulations 2017; and
AI tool conversations and project files: deleted within 90 days after the end of the project they relate to (or, for conversations not linked to a project, within 90 days of the last use). A record of how AI was used on a project is kept with the project file for the period above.Conversations deleted from Claude are removed from Anthropic’s systems within 30 days, except where flagged for a safety review.
nXt registration and update-check records: see ‘Our nXt Excel add-in’ below.

7. Use of artificial intelligence (AI) tools

We use a small number of business-grade generative AI tools to help our staff work efficiently. At the date of this notice these are:

Claude, provided by Anthropic, used under Anthropic’s business (Team) plan and Commercial Terms of Service; and
Microsoft Copilot Chat, included in our Microsoft 365 business licences and used only while signed in with our work accounts, so that Microsoft’s enterprise data protection applies.

We use these tools for tasks such as drafting and summarising documents and correspondence, research, preparing meeting notes, and reviewing and checking spreadsheet formulae, VBA code and model documentation. Where information we put into these tools includes personal data (for example your name, contact details or role in an email, document or financial model), the tools process that data on our behalf.

How we protect your personal data when using AI

We use only business versions of these tools, under contracts in which the provider acts as our data processor and has agreed to data protection terms (Anthropic’s Data Processing Addendum and Microsoft’s Products and Services Data Protection Addendum).
The providers do not use the prompts we enter, the files we upload or the responses generated to train their AI models. We do not permit consumer or free personal versions of AI tools to be used for our business.
We enter only the minimum personal data needed for the task, remove or anonymise personal data wherever practicable, and do not enter special category personal data (such as health information) into AI tools.
We only use client information, including any personal data within it, in an AI tool where this is consistent with our agreement with that client. A client can ask us not to use AI tools on its work.
A suitably qualified member of our team reviews every output before it is relied on or shared. AI tools support our people; they do not make decisions about you.
Access is limited to trained, approved staff using their work accounts, in line with our AI policy.

When Microsoft Copilot Chat searches the web to answer a question, it sends a search query (with user and organisation identifiers removed) to Microsoft’s Bing search service. For those queries Microsoft acts as an independent controller under the Microsoft Privacy Statement, rather than as our processor. Our staff are instructed not to include personal data in requests that may use web search.

Our lawful basis for this processing is our legitimate interest in delivering our services efficiently and to a high standard (see the table above). These tools may store or process data outside the UK. See ‘Transfer of Data Abroad’ below.

8. Our nXt Excel add-in

nXt is a free Excel add-in that we distribute from nxt.numeritas.co.uk. This section explains the personal data nXt collects when you install and use it. The rest of this notice, including your rights and how to complain, also applies.

What nXt sends us

When you install nXt, the installer sends us a one-off registration containing:

the email address you enter;
whether the installation succeeded;
your Excel version (and whether it is 32-bit or 64-bit), your operating system, and your processor type and number of cores;
your Excel country settings;
a computer ID (explained below); and
your IP address and the date and time.

About 15 seconds after each Excel start while nXt is loaded, and whenever you click “Check for updates”, nXt checks for a newer version. Each check sends:

the email address you registered with (or “UNREGISTERED” if you did not register);
your nXt version and build, and whether you started the check yourself;
the same computer ID and your Excel country settings; and
your IP address and the date and time.

The computer ID is an 8-letter code generated from your computer’s name. We never receive the computer name itself. The code lets us count installations and recognise repeat checks from the same computer.

What nXt never sends us

nXt never sends us the contents of your spreadsheets (formulas, values, workbook or file names, or file paths), your Windows username, passwords or payment details. It does not collect any special category data. nXt contains no analytics, advertising or tracking services.

Why we use this data

To tell you when an update is available and deliver it. nXt always asks you before installing an update.
To support you if you contact us about nXt.
To understand how widely nXt is used, by counting installations and active users.

We also use the email address you register with to send you news about nXt and our services. You can opt out at any time using the link in each email.

We do not sell or share this data.

Our lawful basis

We rely on our legitimate interests in providing updates and support for a free product, and in measuring how widely it is used. The data is limited to what we need, and is the kind of information you would expect software to send when it checks for updates. Where we use your registration email for marketing, we do so on the basis of our legitimate interests, and you can opt out at any time.

Where the data is held

nXt communicates only with nxt.numeritas.co.uk. The data is stored securely by our UK web hosting provider, which acts as our processor, and is not transferred outside the UK.

We recommend installing the latest version of nXt, which uses an encrypted (HTTPS) connection.

How long we keep it

We keep version-check records for six years. We keep registration records until six years after the last update check from that computer, and then delete them.

Information stored on your own computer

nXt also stores some information on your computer. This information is not sent to us:

settings in the Windows registry, under HKEY_CURRENT_USER\Software\VB and VBA Program Settings\nXt. These include the install date, your registered email address, your Windows username, the date of the last update check, usage counters and your preferences; and
the add-in file, in %APPDATA%\Numeritas\nXt_lite\, and temporary files in your %TEMP% folder.

Uninstalling nXt and deleting these registry settings removes this information.

Your choices

If you do not want nXt to check for updates, you can block nxt.numeritas.co.uk in your firewall or network settings. nXt will keep working, but you will not be told about updates.

You have the rights set out in ‘Your rights and your personal data’ above. To make a request about nXt data, email ku.oc.satiremun@ofni with the email address you registered with, so that we can find your records.

9. Providing us with your personal data

Unless you are a signing authority acting on behalf of a client, or an employee or prospective employee of Numeritas Ltd, you are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences: we may be unable to enter into a contract with the company you represent or to make you an offer of employment.

10. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
The right not to be subject to a decision based solely on automated processing that has a legal or similarly significant effect on you, without meaningful human involvement and appropriate safeguards (see ‘Automated Decision Making’ below).

11. Transfer of Data Abroad

Some of our service providers, including Microsoft and Anthropic, store or process personal data outside the UK, including in the European Economic Area (EEA) and the United States. Whenever we transfer your personal data outside the UK, we make sure it is protected by one of the following safeguards:

the UK Government has found that the country provides adequate protection for personal data (this includes the EEA countries);
for transfers to the United States, the recipient is certified under the UK Extension to the EU–US Data Privacy Framework (the “UK–US data bridge”); or
we have a contract with the recipient containing the International Data Transfer Addendum to the EU Standard Contractual Clauses, or the International Data Transfer Agreement, approved for use in the UK.

You can contact us for more information about the safeguards we use.

12. Automated Decision Making

We do not make decisions about you based solely on automated processing (including the use of AI) that have legal effects on you or similarly significantly affect you. Where we use AI tools, a member of our team reviews the output and remains responsible for any decision.

13. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

14. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. This notice was last updated on 10 November 2026.

15. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our data protection lead, Stephen Aldridge, on ku.oc.satiremun@ofni. We will acknowledge a complaint within 30 days of receiving it and respond without undue delay, telling you what we have done. You can make a complaint by email with “Data protection complaint” in the subject line.

If this does not resolve your complaint to your satisfaction, you have the right to complain to the UK data protection regulator, the Information Commission (which replaced the Information Commissioner’s Office on 30 September 2026), on 0303 123 1113, via its website at https://ico.org.uk, or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

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