Legal

Privacy Policy

Last updated: 6 August 2026

This policy applies to all personal data processed by BelloiteX (Belloite Ltd) in connection with this website, our recruitment portal, our AI assistant, and our ICT consulting services.

1. Who We Are and How to Contact Us

BelloiteX is the trading name of Belloite Ltd, an information, communication and technology (ICT) solutions firm registered in England and Wales. We are the data controller for personal data collected through this website and our associated services.

  • Registered name: Belloite Ltd
  • Company number: 16765305
  • Registered office: 190 Dantzic Street, Manchester, M4 4LF, United Kingdom
  • Data protection enquiries: hello@belloite.co.uk
  • Telephone: 0161 399 0492

We have not appointed a formal Data Protection Officer (DPO) as we do not meet the thresholds that make this mandatory. All data protection enquiries are handled directly by the company's senior management. You may contact us at the details above for any matter relating to this policy.

2. Scope of This Policy

This Privacy Policy describes how we collect, use, share, retain and protect personal data in connection with:

  • General website visitors to belloite.co.uk and www.belloite.co.uk
  • Individuals submitting a consultation or contact enquiry
  • Users of our AI chat assistant (Bella)
  • Individuals who apply for employment through our recruitment portal
  • Applicants asked to submit identity, address, or right-to-work documents
  • Individuals receiving recruitment status communications from us
  • Hired employees in the pre-onboarding stage, for whom we generate employment documentation

This policy does not cover personal data processed in the context of our business-to-business (B2B) client services or client employee data. Separate data processing agreements govern those relationships.

3. What Personal Data We Collect

3.1 Website Visitors

When you visit our website we automatically collect limited technical information to help us monitor site health and detect unusual activity. This data is used to send an internal notification to our team and is not stored in a persistent database.

  • IP address
  • Approximate geographic location (city, region and country — derived from your IP address; precise street-level location is not determined)
  • Device category (Desktop, Tablet, Mobile)
  • Browser type and version
  • Page URL visited
  • Referring URL (the page or link that brought you to our site, if applicable)
  • Timestamp of visit

3.2 Consultation Bookings and Contact Enquiries

When you book a free consultation or submit a contact form (including through our AI assistant), we collect the information you voluntarily provide:

  • Full name
  • Email address
  • Phone number
  • Service of interest or topic of enquiry
  • Preferred date and time (for consultation bookings)
  • Any additional notes, questions or context you choose to include
  • Your AI chat conversation transcript, if a booking is completed or the chat is submitted to our team

3.3 AI Chat Interactions (Bella)

Our website includes an AI-powered chat assistant named Bella. When you use this feature:

  • The messages you send are processed in real time by a third-party AI language model to generate a response. We do not store your full conversation on our own servers.
  • If you complete a consultation booking through the chat, your name, contact details and the full transcript of that conversation are included in the booking notification sent to our team by email.
  • If you close the chat without completing a booking, and a meaningful conversation occurred, the transcript may be emailed to our team for service quality and improvement purposes.
  • Your chat history is stored locally in your own browser (see Section 9 — Browser Storage). We have no access to this local copy.

3.4 Recruitment Applications

When you submit a job application through our careers portal, we collect the following personal data as part of the application form:

Contact and Identity

  • Full name
  • Email address
  • Phone number
  • Home address

Employment Background

  • Current employment status
  • Notice period
  • Years of experience in field
  • Highest educational qualification
  • Salary or rate expectations
  • Desired start date
  • Willingness to relocate
  • Remote working preference

Right to Work and Immigration Status

  • Work authorisation / visa status (e.g. British citizen, EU settled status, skilled worker visa, student visa)
  • This is collected to ensure compliance with our legal duty to verify the right to work in the United Kingdom under the Immigration, Asylum and Nationality Act 2006 and subsequent regulations.

Professional Profile

  • Portfolio URL (optional)
  • GitHub or equivalent code profile URL (optional)
  • LinkedIn profile URL (optional)

Application Materials

  • Cover letter (text)
  • Curriculum vitae (CV) — uploaded as a file (PDF, Word, or similar); stored in secure encrypted cloud storage

3.5 Identity, Address, and Right-to-Work Documents

For applicants who progress to the pre-employment verification stage, we may request that you upload one or more of the following document categories via a secure, time-limited upload link sent to your registered email address:

  • Photo identification: such as the biographical/photo page of a passport, a UK driving licence, or a national identity card
  • Proof of address: such as a utility bill, bank statement, or council tax letter dated within the last three months
  • Right to work / immigration status evidence: such as a passport biometric page, a UK visa or Biometric Residence Permit (BRP), or a GOV.UK Right to Work online share code

These documents are stored in encrypted private cloud storage accessible only to authorised BelloiteX recruitment staff. Documents are not shared with third parties except where required by law. The upload links are cryptographically signed and expire automatically after seven days.

3.6 Pre-Employment Contractual Documentation

For applicants offered a position, we generate employment documentation (such as a zero-hours worker agreement) using the personal data already collected during the application process — specifically your name, home address, agreed job title, hourly rate, and engagement start date. This document is made available to you and to our internal recruitment team. It is not shared with any third party except for storage within our secure infrastructure.

4. How We Use Your Personal Data

Purpose Personal data used Lawful basis (UK GDPR Art. 6)
Send an internal visitor alert to our team IP address, location, device, browser, page URL, referrer Legitimate interest (monitoring site health and traffic)
Respond to and arrange consultations Name, email, phone, service interest, preferred date/time, notes Legitimate interest / steps towards contract
Send you a booking confirmation email with calendar invite Name, email, service, date/time Steps towards contract (pre-contractual necessity)
Generate an AI response in the chat assistant (Bella) Your chat messages Legitimate interest (providing the requested service)
Review chat transcripts to improve service quality Chat transcript Legitimate interest (service improvement)
Assess and process job applications All application form data, CV, cover letter Legitimate interest (recruitment)
Communicate application status updates to applicants Name, email, job role, application status Legitimate interest (recruitment communication)
Verify identity and proof of address at pre-employment stage Photo ID, proof of address documents Legitimate interest (due diligence); Legal obligation (where required by financial or regulatory sector clients)
Verify the right to work in the UK Immigration status, right-to-work documents Legal obligation (Immigration, Asylum and Nationality Act 2006)
Generate pre-employment contractual documentation Name, address, job title, pay rate, start date Steps towards contract (pre-contractual necessity)
Maintain internal records of recruitment activity Application data, status history, notes, documents Legitimate interest (business record-keeping)
We do not use your personal data for: unsolicited marketing, targeted advertising, sale to third parties, credit referencing, or any automated profiling that produces legal or similarly significant effects. We do not engage in any secondary use of your data beyond what is described in this table.

5. Automated Processing and Decision-Making

Our AI chat assistant (Bella) uses an automated language model to generate responses to your messages in real time. This is a standard AI text generation process and does not constitute automated decision-making under Article 22 of UK GDPR — it produces conversational responses only and does not make decisions with legal or similarly significant effects on you.

Our recruitment portal assigns application status labels (e.g. "reviewing", "shortlisted", "offer made") that are set manually by authorised staff. No hiring or rejection decisions are made by automated means. All decisions about whether to progress, shortlist, interview, make an offer to, or reject a candidate are made by a human being.

Document upload links and authentication tokens used in our recruitment system are generated automatically using cryptographic processes. These are operational security measures and do not affect any decision about your application.

6. Third-Party Service Providers

We engage carefully selected third-party data processors to operate our website and services. Each processor acts under our instruction and under a data processing agreement where applicable. We do not sell data to third parties, and we do not permit processors to use your data for their own purposes.

For security reasons, we do not publish the specific names or commercial identities of our technology infrastructure providers, as doing so may facilitate targeted social engineering or phishing attempts against our users or staff. Instead, we describe each category of service and its data handling scope below.

Service category Purpose Data involved Transfer location
Cloud application hosting and serverless infrastructure Hosts the website, processes API requests, runs server-side application logic All data passing through the website and API United States (with appropriate safeguards)
Encrypted private file storage Securely stores uploaded CVs and verification documents CV files, photo ID, proof of address, right-to-work documents United States (with appropriate safeguards)
Transactional email delivery service Sends application confirmations, status update emails, document request emails, consultation confirmations, and internal team notifications by email Name, email address, application details, message content United States (with appropriate safeguards)
AI language model provider Processes chat messages in real time to generate AI responses for the Bella assistant The text of messages you send in the chat United States (with appropriate safeguards)
Business instant messaging platform Delivers real-time internal team notifications for new bookings, enquiries and visitor alerts Booking details, contact information, chat transcripts (for bookings), visitor data United States (with appropriate safeguards)
IP geolocation service Converts raw IP addresses into approximate geographic locations (city/country) for internal visitor alerts IP address (no other data transmitted) European Economic Area
Web font delivery network Loads typefaces used across the website Your IP address and browser user-agent (as part of a standard HTTP font request) United States

If you would like more information about any specific provider category or wish to object to a particular transfer, please contact us at hello@belloite.co.uk.

7. International Data Transfers

Several of our service providers are based in, or process data in, the United States. The UK has not granted an adequacy decision in respect of the United States as a whole. For transfers to US-based processors, we rely on one or more of the following safeguards:

  • The provider's participation in a recognised data protection certification or compliance framework
  • Standard Contractual Clauses (SCCs) as approved or adopted under UK law
  • The provider's own binding corporate rules, where applicable
  • Our legitimate interest assessment where the transfer is strictly necessary to deliver the service you have requested and the risks to your rights are proportionate

Our IP geolocation provider processes data within the European Economic Area (EEA), which benefits from UK adequacy regulations.

You may request a copy of the relevant transfer safeguards for any specific processor by contacting us at hello@belloite.co.uk.

8. Data Retention

We retain personal data only for as long as is necessary for the purpose for which it was collected, or as required by law. The following schedules apply:

Data category Retention period Basis for retention period
Visitor notification data (IP, location, device, page, referrer) Not retained — dispatched as a one-time internal notification and not written to any persistent database Minimal data principle; not required for any ongoing purpose
Consultation and contact enquiry details Up to 2 years from the date of the enquiry or last contact, whichever is later Legitimate interest in maintaining business records and responding to follow-up enquiries
AI chat transcripts (bookings / reviewed sessions) Up to 12 months from the date of the conversation Service quality review and business record
Job applications — unsuccessful outcome Up to 6 months from the date we notify you of the outcome, then securely deleted Enables us to respond to any dispute or query about the recruitment process; ICO guidance on recruitment records
Job applications — withdrawn by applicant before outcome Up to 30 days from withdrawal, then deleted Minimal retention in case of queries
CV and uploaded application files (unsuccessful applicants) Deleted within 6 months of the application outcome Proportionality; files are sensitive and not required once recruitment is concluded
Identity and proof-of-address documents (unsuccessful applicants) Deleted within 6 months of the application outcome Sensitive personal data; not required once verification stage is concluded without hire
Job applications — successful (hired) Retained as part of the employment record for the duration of employment and for 6 years post-employment termination Employment law obligations; Limitation Act 1980 (civil claims); HMRC record-keeping requirements
Right-to-work documents — hired employees Retained for the duration of employment and for 2 years after employment ends, then securely destroyed Home Office statutory right-to-work check requirements (Immigration, Asylum and Nationality Act 2006)
Pre-employment contractual documents (e.g. worker agreements) Retained for the duration of the working relationship and for 6 years thereafter Contractual record; Limitation Act 1980
Chat history stored in your browser (localStorage) Stored on your device only; persists until you clear your browser data or storage We have no control over or access to this copy — it exists solely on your device

At the end of any retention period, data is either permanently deleted from our systems or securely anonymised so that it can no longer be associated with any individual.

9. Cookies and Browser Storage

We do not use tracking cookies, advertising cookies, or any cookie-based analytics. The following browser storage mechanisms are used on this site:

localStorage

  • Key: bh_chat_v2 — stores your AI chat conversation history locally in your browser so that past conversations are visible when you return to the site. This data is stored entirely on your own device. We do not transmit, read, or have access to this local data. You can clear it at any time by clearing your browser's site data or local storage.

sessionStorage

  • Key: bh_visited — a temporary flag set during your first page view of each browser session. It prevents our team from receiving duplicate visitor notifications within a single visit. This value is automatically deleted when you close the browser tab and is never transmitted to our servers or third parties.

Web font requests

Our website loads typefaces from an external web font delivery network. When your browser requests a font file, your IP address and browser user-agent string are transmitted to that provider's servers as part of a standard HTTP request. This provider may log such requests in accordance with its own privacy policy. We have implemented the font loading in a way that minimises additional data sharing beyond what is inherent in a standard font file request. The provider does not set cookies via this mechanism.

Recruitment upload tokens

When an applicant uses a document upload link, the time-limited token embedded in that link is read by our server to authenticate the request. The token is a cryptographically signed string and contains only your application identifier and the list of document types requested. It does not contain any plain-text personal data.

10. Data Security

We implement a range of technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These include:

  • Encrypted transmission: All data exchanged between your browser and our servers is encrypted using HTTPS/TLS.
  • Private cloud storage: Uploaded files (CVs, verification documents) are held in encrypted private cloud storage. They are not accessible via public URLs; access requires server-side authentication using restricted credentials.
  • Time-limited signed upload tokens: Document upload links are cryptographically signed and expire automatically after seven days. They cannot be guessed, reused, or forged.
  • Access controls: Our internal recruitment portal and administrative functions are protected by authentication. Only authorised personnel can access applicant data, uploaded documents, or generate employment documentation.
  • Server-side proxy for file downloads: Uploaded documents are never served via direct public URLs. All file retrieval is proxied through our authenticated server layer, ensuring access cannot bypass our permission controls.
  • Minimal data collection: We do not collect data we do not need. Sensitive data (such as verification documents) is collected only when legally required or when you have progressed to the relevant stage of recruitment.
  • Segregation of environments: Our production infrastructure, internal administration tools, and external-facing public pages are logically separated and independently access-controlled.

No method of electronic transmission or storage is entirely free from risk. While we take all reasonable precautions, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours as required by UK GDPR, and we will inform affected individuals without undue delay where the breach is likely to result in a high risk to them.

11. Your Rights Under UK GDPR

As a data subject, you have the following rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. You may exercise any of these rights by contacting us at hello@belloite.co.uk. We will acknowledge your request promptly and respond within one calendar month. In complex cases we may extend this by a further two months, in which case we will notify you.

Right of Access (Subject Access Request)

You may request a copy of the personal data we hold about you, along with information about how we use it, who we share it with, and how long we retain it. We will provide this at no charge in a commonly used electronic format unless the request is manifestly unfounded or excessive.

Right to Rectification

If the personal data we hold about you is inaccurate or incomplete, you have the right to ask us to correct or complete it. We will act on your request without undue delay.

Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data where:

  • The data is no longer necessary for the purpose for which it was collected
  • You withdraw consent (where consent was the basis) and there is no other lawful basis
  • You object to processing and there are no overriding legitimate interests
  • The data has been unlawfully processed
  • Erasure is required to comply with a legal obligation

This right does not apply where we are required to retain the data by law (for example, right-to-work records or employment records for tax purposes).

Right to Restriction of Processing

You may ask us to suspend our use of your data (while retaining it) where:

  • You contest the accuracy of the data — processing is restricted while we verify it
  • The processing is unlawful but you prefer restriction to erasure
  • We no longer need the data but you need it for a legal claim
  • You have objected and we are considering whether our legitimate interests override yours

Right to Data Portability

Where processing is based on your consent or on the performance of a contract, and is carried out by automated means, you may request a copy of your personal data in a structured, commonly used, machine-readable format (such as JSON or CSV). This right applies to data you have actively provided to us.

Right to Object

You have the right to object to processing carried out on the basis of our legitimate interest. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for a legal claim.

Rights Related to Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects. As described in Section 5, we do not make hiring or rejection decisions by automated means. If you believe an automated process has produced a decision with significant effect on you, please contact us immediately.

12. Recruitment Applicants — Additional Rights and Information

Withdrawing Your Application

You may withdraw your application at any time by emailing hello@belloite.co.uk with your application reference number (included in your submission confirmation email) and a request to withdraw. Upon withdrawal, we will cease active consideration of your application. We will retain minimal records for up to 30 days to handle any queries, after which all associated data is deleted.

Requesting Deletion of Your Application

If your application is unsuccessful, we retain your data for up to 6 months (see Section 8). You may request early deletion of your application data at any time by contacting us. We will comply unless there is an active legal obligation or dispute that requires us to retain the data.

Accessing Your Application Data

You may make a Subject Access Request (SAR) to receive a copy of all personal data we hold in connection with your application, including any notes our team has recorded, your application status history, and any documents you have uploaded. Submit your request to hello@belloite.co.uk.

Right to Work Checks

We are required by UK law to verify that all persons we engage to work for us have the legal right to work in the United Kingdom before or on their first day of work. This verification involves checking and retaining copies of original identity and right-to-work documents. Failure to conduct these checks could result in a civil penalty under the Immigration, Asylum and Nationality Act 2006. We cannot waive this obligation.

Speculative Applications and Talent Pool

If you submit an application for a role that is no longer available, or if we believe your profile may suit future vacancies, we may retain your application for up to 6 months and contact you if a relevant position arises. We will always make clear if we are doing this. You may opt out of this at any time.

13. Children's Privacy

Our website, services and recruitment portal are intended solely for use by adults (18 years of age or over) and businesses. We do not knowingly collect or process personal data from anyone under the age of 16. If you are under 16, please do not use this website, submit an application, or provide any personal data to us.

If you believe that a person under the age of 16 has submitted personal data to us, please notify us immediately at hello@belloite.co.uk. We will take steps to delete such data promptly.

14. Changes to This Policy

We review and update this Privacy Policy periodically to reflect changes in our data processing activities, legal requirements, or guidance from the ICO. The "Last updated" date at the top of this page always reflects the most recent version.

Where a change is material — for example, if we introduce a new significant processing purpose or add a new category of third-party sharing — we will take reasonable steps to bring the change to your attention, which may include displaying a notice on our website or, where we hold your contact details, sending you an email.

Continued use of our website or services after a policy update constitutes acknowledgement of the revised policy. We encourage you to review this page periodically.

15. Complaints

If you have a concern about how we handle your personal data, we ask that you contact us first so that we have the opportunity to address it:

  • Email: hello@belloite.co.uk
  • Telephone: 0161 399 0492
  • Post: Belloite Ltd, 190 Dantzic Street, Manchester, M4 4LF, United Kingdom

We aim to respond to all privacy complaints within 14 days and to resolve them within 30 days. If you are not satisfied with our response, or if you believe we are processing your data unlawfully, you have the right to lodge a complaint directly with the Information Commissioner's Office (ICO), the UK's independent data protection authority:

  • Website: ico.org.uk/make-a-complaint
  • Telephone: 0303 123 1113
  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF