Privacy Policy

1. Who we are

We are a private limited company registered in England and Wales.

• Company name: Divergent Matrix Limited
• Trading as: Occentra
• Company number: 14707575
• Registered office: Unit 134932, 13 Freeland Park, Wareham Road, Poole, Dorset, England, BH16 6FH
• Privacy contact: privacy@occentra.co.uk

You can view our Companies House record online.

2. Scope of this notice

This notice covers personal data collected through the Occentra marketing website and enquiry channels—for example, when you submit a demo request form or email us at hello@occentra.co.uk. For these purposes, we act as the data controller.

Occentra product and customer data: The Occentra platform, when used by customers, typically processes employee and occupational health data on behalf of those customer organisations. In that context, the customer is the data controller and we act as their data processor. The customer's own privacy notice governs that processing. If you have questions about a data processing agreement or our role as processor, please contact privacy@occentra.co.uk.

The website does not collect occupational health records or special-category health data. Please do not include employee health information in the demo request free-text field. If we receive such information unintentionally, we will delete it.

3. Personal data we collect

Demo and consultation enquiry forms:

• Full name
• Work email address
• Organisation name
• Job title
• Telephone number (optional)
• Anything you would particularly like us to cover (optional free text)
• Marketing consent (whether you opted in to product updates)
• Source (which page you submitted the form from, e.g. book-demo or consult)

Emails to hello@occentra.co.uk:

• Your email address, name and any other information you include in your message

Technical data from website visits:

• IP address
• Browser type and version
• Device and operating system information
• Pages visited, referring URLs and timestamps
• Approximate location derived from IP address (city/region level, via Google Analytics)

This technical data is collected automatically through hosting logs and Google Analytics 4.

4. Purposes and legal bases

We process personal data for the following purposes and rely on the legal bases shown:

Responding to demo and consultation enquiries

• Purpose: to review your requirements, contact you to discuss Occentra, and arrange follow-up demonstrations or conversations.
• Legal basis: legitimate interests (pursuing business-to-business sales enquiries initiated by you) and, where relevant, taking steps prior to entering into a contract.

Sending product news and updates

• Purpose: to send occasional emails about Occentra product news and updates if you opted in.
• Legal basis: consent (you ticked the optional marketing consent checkbox).

Website security and operations

• Purpose: to operate, secure and maintain the website, including abuse prevention, rate limiting, troubleshooting and infrastructure monitoring.
• Legal basis: legitimate interests (keeping the website secure and available).

Website analytics

• Purpose: to understand how the website is used (pages viewed, traffic sources and call-to-action clicks) so we can improve content and performance.
• Legal basis: legitimate interests (measuring and improving a business website). Analytics cookies are used as described in section 9.

Legal compliance

• Purpose: to comply with legal or regulatory obligations, respond to lawful requests from authorities, or establish, exercise or defend legal claims.
• Legal basis: legal obligation and, where applicable, legitimate interests.

5. Who we share data with

We do not sell your personal data. We may share it with:

• Our internal team: employees and contractors who need access to respond to your enquiry or operate the website.
• Amazon Web Services (AWS): we use AWS for website hosting and AWS Simple Email Service (SES) to deliver enquiry notification emails. AWS processes data on our behalf under appropriate contractual terms.
• HubSpot, Inc.: we use HubSpot to store demo and consultation enquiries as CRM leads so we can follow up. HubSpot processes this data on our behalf under appropriate contractual terms. See HubSpot's Privacy Policy.
• Google LLC (Google Analytics): we use Google Analytics 4 to measure website usage. Google processes this data on our behalf. See Google's Privacy Policy and Analytics data practices.
• Professional advisers: such as lawyers or accountants, where reasonably required.
• Law enforcement and regulators: where we are legally required to disclose information or to protect our rights.

6. International transfers

Some processing by AWS, HubSpot and Google may occur outside the United Kingdom, including in the United States. Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place in accordance with UK data protection law, such as standard contractual clauses with the UK International Data Transfer Addendum.

7. How long we keep data

Enquiry data: we retain demo and consultation enquiry data while we are actively handling your enquiry and any related sales conversations. Once the enquiry is concluded and there is no ongoing relationship, we delete or anonymise the data unless we have a legal reason to keep it longer.

Marketing contacts: if you opted in to product updates, we keep your contact details until you withdraw consent or ask us to stop.

Server logs: technical logs are retained only as long as needed for security, operational monitoring and troubleshooting purposes.

Analytics data: Google Analytics retains event data according to the retention period configured in our Google Analytics property (by default up to 14 months).

8. Your rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Rectification of inaccurate or incomplete data.
• Erasure of your data in certain circumstances.
• Restriction of processing in certain circumstances.
• Object to processing based on legitimate interests, including objecting to direct marketing at any time.
• Data portability where processing is based on consent or contract and carried out by automated means.
• Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, contact us at privacy@occentra.co.uk. We will respond within one month, or let you know if we need more time.

Complaints to the ICO: if you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO). You can do so via the ICO complaints page. We encourage you to contact us first so we can try to resolve any concerns.

9. Cookies and similar technologies

The website uses cookies that are strictly necessary for the site to function—for example, session management or security features—and cookies set by Google Analytics 4 to measure how visitors use the site (pages viewed, approximate location, device/browser information and referral source). Google Analytics may also use similar technologies such as pixels or local storage.

We do not use marketing or advertising cookies. You can control cookies through your browser settings; blocking analytics cookies will not prevent you from using the website.

10. Security

We implement appropriate technical and organisational measures to protect personal data, including access controls, encryption in transit and secure hosting practices. No method of transmission or storage is completely secure, and we cannot guarantee absolute security, but we take reasonable steps to protect the data we hold.

11. Children

The Occentra website and enquiry channels are directed at businesses and professional users. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us and we will delete it.

12. Automated decision-making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on the website.

13. Changes to this notice

We may update this privacy notice from time to time. The effective date at the top of this page will be revised when changes are published. Where changes are significant, we may also highlight them on the website.

14. Contact us

For privacy questions or to exercise your rights, contact:

privacy@occentra.co.uk

Divergent Matrix Limited
Trading as Occentra
Company No. 14707575
Unit 134932, 13 Freeland Park, Wareham Road, Poole, Dorset, England, BH16 6FH

For general enquiries (not privacy-related), you can also reach us at hello@occentra.co.uk.