Privacy Policy.

This Privacy Policy explains how we collect, use and protect personal information when you visit our website, contact us, make an enquiry, or otherwise interact with Athena Integrity through this site.

This policy applies to website use and initial enquiries. Where Athena is engaged to provide integrity, investigation, intelligence, due diligence or related support, additional privacy terms may apply depending on the nature of the engagement.

1. Who we are

Athena Integrity is currently a pre-incorporation project name used by its co-founders for the development and promotion of an independent sports integrity capability.

Athena Integrity is not yet incorporated as a legal company. It does not currently have a company number or registered office.

Until a legal entity is formed, references in this Privacy Policy to "Athena Integrity", "Athena", "we", "us" or "our" mean the co-founders operating this website and handling enquiries made through it.

Once Athena Integrity is incorporated or otherwise formalised as a legal entity, this Privacy Policy will be updated to include the relevant legal entity name, company number, registered office and any other required details.

2. ICO registration

Athena Integrity is not currently registered with the UK Information Commissioner's Office.

We will keep this position under review as Athena develops, including by assessing whether we are required to pay the data protection fee or register with the ICO.

3. Personal information we collect

We may collect and process the following types of personal information.

Information you provide to us

This may include:

• your name;
• organisation;
• job title or role;
• email address;
• telephone number;
• the content of any enquiry or message you send to us;
• information about your organisation's integrity, governance or investigative needs;
• any other information you choose to provide.

Please avoid sending sensitive information through a general website form or email unless we have agreed that this is appropriate. If a matter is sensitive, confidential or involves allegations about individuals, we will agree an appropriate secure channel before detailed information is shared.

Technical information

We may receive limited technical information when you visit the website, such as:

• IP address;
• browser type;
• device type;
• date and time of visit;
• basic server logs.

At present, we do not use analytics cookies, advertising cookies, marketing pixels or website tracking tools.

If this changes, this Privacy Policy and any relevant cookie notice will be updated.

Information from third parties

We may receive information from third parties where you are introduced to us, referred to us, or where another organisation provides your contact details in connection with a potential engagement, enquiry or professional relationship.

4. How we use personal information

We use personal information for the following purposes:

• to respond to enquiries;
• to arrange confidential discussions;
• to assess whether Athena may be able to assist;
• to communicate with prospective clients, clients, partners, advisers and contacts;
• to provide information about Athena's capabilities;
• to manage professional and business relationships;
• to keep appropriate records of communications and decisions;
• to protect confidentiality and security;
• to comply with legal, regulatory and professional obligations;
• to protect Athena's legitimate business interests.

We do not sell personal information.

5. Lawful bases for processing

We process personal information only where we have a lawful basis to do so.

Depending on the context, we may rely on one or more of the following lawful bases.

Legitimate interests

We may process personal information where it is necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

This may include responding to enquiries, managing professional relationships, maintaining records, protecting our position, developing Athena's work in sports integrity and maintaining website security.

Contract or steps before entering into a contract

Where you or your organisation asks us to consider an engagement, we may process personal information to take steps before entering into a contract or to perform a contract.

Legal obligation

We may process personal information where necessary to comply with legal or regulatory obligations.

Consent

Where we rely on consent, for example for certain future marketing activity, you may withdraw that consent at any time.

6. Sensitive information

Some enquiries may relate to sensitive integrity matters, including allegations of misconduct, safeguarding concerns, disciplinary issues, corruption, match-fixing, doping, criminality or other serious matters.

You should not provide detailed sensitive information through a general website form unless we have agreed that this is appropriate.

If sensitive information is provided to us, we will handle it carefully and use it only for the purpose of assessing the enquiry, protecting confidentiality, agreeing appropriate next steps, or meeting legal or professional obligations.

Where Athena is formally engaged to handle sensitive integrity, investigation or intelligence work, the relevant engagement documentation may include additional privacy terms.

7. Cookies and analytics

At present, Athena Integrity does not use analytics cookies, advertising cookies, marketing pixels or similar tracking tools.

The website may still use strictly necessary technical processes required to make the website function securely and reliably.

If Athena introduces analytics, advertising, embedded media, booking tools, newsletter tools or similar technologies, this Privacy Policy and any relevant cookie notice will be updated before or at the time those tools are used.

8. Direct marketing and updates

Athena may in future send occasional updates, insights, event invitations or other communications about its work in sports integrity.

We will only do this where lawful.

Where consent is required, we will ask for consent. Where we contact business or professional contacts on another lawful basis, we will still provide a clear way to opt out.

9. Who we share personal information with

We may share personal information with:

• professional advisers;
• IT, hosting, email, website and cloud service providers;
• contractors or specialist practitioners supporting Athena's work;
• legal, regulatory or public authorities where required or appropriate;
• clients or prospective clients where relevant to an engagement or enquiry;
• other third parties where you have asked us to do so or where it is necessary for the purpose for which the information was provided.

Where we use suppliers or contractors, we take reasonable steps to ensure personal information is handled securely and in line with data protection requirements.

10. International work

Athena may work with contacts, clients, advisers or counterparties outside the United Kingdom.

Where personal information is transferred internationally, we will take steps designed to ensure that appropriate safeguards are in place, where required by data protection law.

11. How long we keep personal information

Athena's formal retention schedule has not yet been established.

Until that schedule is adopted, we will keep personal information only for as long as reasonably necessary for the purpose for which it was collected.

In practice, this means:

• enquiry information will be kept while the enquiry is active and for a reasonable period afterwards;
• prospective client and relationship records may be kept where needed for follow-up, conflict management, business records or legitimate interest purposes;
• engagement-related records may be kept for longer where needed for legal, contractual, regulatory, insurance, confidentiality or dispute purposes;
• marketing preferences may be kept so that we can respect opt-out requests.

Athena will adopt a more detailed retention schedule as the business develops.

12. How we protect personal information

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access controls, secure systems, confidentiality obligations and careful handling of sensitive matters.

No method of transmission over the internet is completely secure. For sensitive enquiries, we may agree a more secure communication channel before detailed information is shared.

13. Your rights

Depending on the circumstances, you may have the right to:

• access your personal information;
• correct inaccurate or incomplete information;
• request deletion of your information;
• restrict how we use your information;
• object to certain processing;
• request transfer of your information;
• withdraw consent where processing is based on consent;
• complain to the UK Information Commissioner's Office.

Some rights may not apply in every situation, particularly where we need to retain information for legal, regulatory, contractual, confidentiality, investigation or legitimate business reasons.

14. Complaints

If you have concerns about how we handle personal information, please contact us first so we can try to resolve the matter.

You also have the right to complain to the UK Information Commissioner's Office.

15. Links to other websites

Our website may contain links to third-party websites, including LinkedIn or other external resources.

We are not responsible for the privacy practices, content or security of third-party websites. You should read their privacy policies before providing personal information to them.

16. Changes to this policy

We may update this Privacy Policy from time to time.

The latest version will be published on this page with the date of the most recent update.