Discretion is part of the experience, not an afterthought.

Roger Morgan, trading as The Elite Circles, is the data controller. Service address: Crown Lodge, 12 Elystan Street, London SW3 3PP, United Kingdom. This notice covers enquiries, applications, member accounts, the directory, private spaces, connections, messages, events and payment administration.

Information may include your name, professional details, organisation, email and telephone number; application answers, profile information and preferences; messages, connection requests, event attendance and images you choose to share; payment and subscription records; and relevant security or service logs.

We receive information directly from you and, for existing member records, from records supplied by you or the membership team, including imported directory data. If you ask us to prepare an optional professional-biography draft and that feature is enabled, your name, organisation and city are sent to Google Gemini with Search grounding. The draft and cited public sources are returned for your review; we do not save a draft to your profile unless you choose to do so. This feature is not used unless enabled and requested.

The member sign-in uses necessary session cookies. The public website does not use advertising or analytics cookies.

We do not ask applicants to provide criminal-offence data or carry out background, identity, reference or credential checks. If such information is sent to us in a safety report, we will assess whether the law permits us to use it and limit handling to what is necessary.

We use information to respond to enquiries and applications, provide and administer membership, maintain member accounts and private spaces, arrange introductions and events, process payment administration, send service emails, address safety reports, secure the service and comply with legal obligations.

For enquiries and applications, our basis is taking steps at your request before a contract and, where appropriate, our legitimate interest in considering participation in and protecting a private professional community. For member services, our basis is performing the membership contract. For accounting and other legal duties, our basis is legal obligation. For security, complaints and legal claims, our basis is our legitimate interests in protecting members and the service and establishing, exercising or defending legal claims. We do not make admission or removal decisions solely by automated means.

There is no public member directory. Personal contact details are shared for an introduction only with the permission of the people involved. Members decide what they share in private settings; we ask them to use that information only for the purpose for which it was provided.

To address a specific report or safety concern, we may review relevant messages or material shared through spaces we operate. We do not promise to monitor every conversation. Access to reviewed material is restricted to people who need it for the stated purpose.

We use service providers to operate the service: Supabase for sign-in, database and file storage; Vercel for hosting and service logs; Resend for enquiry and member emails; and Stripe for hosted payments. If the optional biography research feature is enabled and requested, Google processes the professional details described above. Event venues or hosts receive only the information needed to administer an event, and introductions share details only with permission.

We do not sell applicant or member contact details. Providers may process information in or access it from outside the United Kingdom. Where UK data-protection law requires a transfer safeguard, we use an applicable adequacy decision or an approved transfer mechanism, such as the UK International Data Transfer Agreement or UK Addendum, with a transfer risk assessment where required. You may ask us for details of the safeguards relevant to your information.

We apply these periods unless a longer period is required by law or reasonably needed for a complaint or legal claim:

• Enquiries and applications that do not become membership: up to 12 months after the last contact or decision.
• Member profile, directory and service data: while membership is active, then delete or anonymise within 90 days after it ends.
• Payment and accounting records: six years after the end of the relevant accounting period.
• Safety or complaint records: up to six years after the matter closes where reasonably needed to protect members or establish, exercise or defend a legal claim.
• Hosting, authentication and security logs: under the relevant provider’s configured retention period, and no longer than needed for security or fault investigation.

Backups may retain deleted information until the next scheduled replacement. Where we keep a record longer for a specific reason, we restrict access and delete it when that reason ends.

Depending on the circumstances, you may ask for access, correction, deletion, restriction, objection or portability. You may also complain to the UK Information Commissioner’s Office. Some rights depend on the legal basis and are subject to exemptions.

Use our privacy request form. It asks only for your name, email address and the request. We may ask for reasonable information to confirm your identity or locate the relevant record. Please do not send passwords, one-time codes or payment card details.

We use reasonable technical and organisational measures to protect personal information. No internet transmission or storage system can be guaranteed completely secure. The hosted payment page and other external services have their own privacy notices. We will update this notice when our use of information changes.

Roger Morgan, trading as The Elite Circles. Service address: Crown Lodge, 12 Elystan Street, London SW3 3PP, United Kingdom.

Last updated: 2 October 2026.