Millennium Global Intelligence

We respect your privacy and are committed to protecting your personal data. This policy will inform you as to how we collect, process and look after your personal data (including when you use our website at and when we provide you with our services). We will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

We do not knowingly collect data relating to children.

It is important that you read this policy together so that you are fully aware of how and why we are using your data. If you are using our website, your acceptance of this policy is deemed to occur upon your first use of the site.

This policy supplements (and its terms apply in addition to) any other terms of use or other terms and conditions agreed between you and us from time to time.

1. Who We Are

1.1    Our website and services are operated by Millennium Emerging Europe Limited, a company registered in England and Wales under number 12855990 whose registered office is at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ (“we/us/our”).

1.2    This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    Our data privacy manager is Andras Radnoti and he is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact Mr. Radnoti via email at

2. What This Policy Covers

2.1    Personal data, or personal information, means any information about a living individual from which that person can be identified (directly or indirectly). This definition shall, where applicable, incorporate the definitions provided in EU Regulation 2016/679 – the General Data Protection Regulation (“EU GDPR”), the retained EU law version of the GDPR (“UK GDPR”) and the Data Protection Act 2018. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymous data).

2.2    Our site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit before submitting any personal data to third parties.

2.3    If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can give consent on his/her behalf to the processing of their data and receive on their behalf any data protection notice.

3. What Personal Data Do We Collect?

3.1    Depending upon your use of our site and services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, date of birth, gender.
  • Contact Data includes address, billing address, email address and telephone number.
  • Business information includes company/organisation name, job title, profession and VAT number.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and details of purchases.
  • Enquiry and Correspondence Data includes information contained in any enquiry you submit to us or contained in or relating to any communication that you send to us regarding our services or your requirements.
  • Usage Data includes information about how you use our site and our services.
  • Communications Data includes your communication preferences.

3.2    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3.3    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a contract you have with us but we will notify you if this is the case at the time.

4. How Is Your Personal Data Collected?

4.1    We collect data from and about you generally through direct interactions. You may give us your identity, contact and financial data (and any other information which you choose to give us) by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you apply for our services, and give us feedback or communicate with us.

4.2    We do not place cookies on your computer or device.

5. How Do We Use Your Data?

5.1    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

5.1.1    Where we need to perform the contract we are about to enter into or have entered into with you;

5.1.2    Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

5.1.3    Where we need to comply with a legal obligation.

5.2    Generally, we do not rely on consent as a legal basis for processing your personal data although we would always get your consent before sending third party direct marketing communications to you (which we do not do).

5.3    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in this policy.

5.4    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (see section 9 below).

5.5    Specifically, we may use your data for the following purposes:

5.5.1    To register you as a new customer, contract with you and supply our services to you (on the basis of performance of a contract with you);

5.5.2    To process your orders, including managing payments and collecting money owed to us (on the basis of performance of a contract with you and it being necessary for our legitimate interests);

5.5.3    To communicate with you, respond to your enquiries and manage our relationship with you, including notifying you about changes to our terms or policies and asking you to leave a review (on the basis of performance of a contract with you, complying with our legal obligations, and it being necessary for our legitimate interests to keep our records updated and to study how customers use our services);

5.5.4    To administer and protect our business and site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), including enforcing our contracts and policies, investigating complaints and preventing illegal activity (being necessary to comply with a legal obligation and for our legitimate interests (for example for running our business, providing administration and IT services and network security));

5.5.5    Otherwise carrying out our business activities in circumstances where you ought reasonably to have an expectation that we will process your personal data for a particular purpose.

5.6    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (see section 9 below.). If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosure of Your Personal Data

6.1    We may share your personal data with the parties set out below for the purposes set out above: >

6.1.1    External Third Parties, namely:    Service providers, including Amazon Web Services (with data centres in the US) who provides IT, cloud hosting, system administration and back-up services;    Invoice and banking providers, namely Wave Financial Inc. and its affiliated companies who provide invoicing services via, and Wise Payments Limited who provide banking services on our behalf;    Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and    HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

6.1.2    Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.

6.2    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

6.3    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and the law.

7. How, Where and For How Long Do We Store Your Data?

7.1    Some of the external third parties to whom we transfer your personal data are based outside the UK. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and will be fully protected under the UK GDPR, EU GDPR, Data Protection Act 2018 and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

7.1.1    We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries; or

7.1.2    We will use specific approved contracts which ensure the same levels of personal data protection that apply under applicable data protection legislation. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. By giving us your personal data, you agree to these arrangements. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.2    Data security is very important to us, and to protect your data we have put in place suitable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. By way of example, these include encrypted CRM software accessible through multi-factor authentication, as well as limiting access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

7.3    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7.4    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Subject to the foregoing, we will generally retain your personal data for as long as necessary to support the services we are providing to you, and generally for a period of three consecutive years thereafter. If you do not access our services and no communication has been made for more than that three-year period, we will generally delete personal data we hold about you. If you terminate an engagement for the provision of our services, we generally delete personal data we hold about you within a period of five working days. However, in either scenario, we may retain certain of your personal data for longer if we think it is reasonably necessary to do so in the circumstances, taking into consideration factors such as our need to answer any queries or resolve any problems you may have and our need to comply with legal requirements (e.g. relating to record keeping).

7.5    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8. Your Legal Rights

8.1    Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

8.1.1    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

8.1.2    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

8.1.3    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

8.1.4    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object if we processed your personal data for direct marketing purposes (which we do not do). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

8.1.5    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:    If you want us to establish the data's accuracy;    Where our use of the data is unlawful but you do not want us to erase it;    Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;    You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

8.1.6    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

8.1.7    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

8.1.8    Rights with respect to automated decision making and profiling. We do not carry out these activities.

8.2    If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

8.3    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8.4    We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In the case of subject access requests, normally, we aim to provide a complete response, including a copy of your personal data within one month. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

8.5    If you require any information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in section 9. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 9 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the relevant supervisory authority for data protection issues, which in the UK is the Information Commissioner’s Office ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

9. Contacting Us

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact us at, or via the address set out in section 1.1 above. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 8 above).

10. Changes to Our Privacy Policy

We keep our privacy policy under regular review. It was last updated in February 2023. We may change this policy from time to time (for example, if the law changes or if we change our business in a way that affects personal data protection). You will be notified of any material changes (e.g. a change in the processing purpose, controller identity, or changes in how data subjects can exercise their rights) by email or on this site. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.