Signal CX
SignalCX (registered as Labinah Management Training Ltd)
This policy was updated in June 2026 to reflect changes introduced by the Data (Use and Access) Act 2025 (DUAA).
Version: June 2026 | Next review due: June 2027
SignalCX (registered as Labinah Management Training Ltd) is committed to protecting your personal data and this privacy policy states how we collect your personal data, how we store it and how we use it.
This privacy policy applies to our websites including www.signal.cx and www.serviceanimals.com, products and services which are offered by SignalCX.
The purpose of this policy is to give you a clear explanation about how SignalCX collects and uses the personal data you provide to us and that we collect. We ensure that we use your information in accordance with all applicable laws concerning the protection of your personal data.
If you have any queries about this policy or your personal data, please contact:
Michelle Maguire
Data Protection Lead
Labinah Management Training Ltd t/a SignalCX
International House, 6 South Molton Street, London, W1K 5QF
Email: privacy@signal.cx
Call: 0208 087 0178
The personal data we collect will be used for the following purposes:
Our legal basis for processing of your personal data is:
The legitimate interests pursued by us are as follows:
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal or transactional information stored on our website and systems.
The security measures we have put in place include:
We believe in being open, honest and transparent with our clients and suppliers and want you to feel comfortable about your decision to give us your personal data and how we use it.
We will use the details you provide to us to communicate with you about how we can help you in your role and help your company achieve its objectives.
We promise that we will only communicate with you in the way you wish us to and we will always respect your privacy. You can change your mind at any time and it’s quick and easy to let us know that you no longer want to hear from us by contacting the Data Protection Lead.
We may contact you for marketing purposes by email or text message in the following circumstances:
Where you have given consent: If you have actively opted in to receive marketing communications from us (for example, by completing a sign-up form on our website or explicitly agreeing at the point of contact), we will use your email address and/or mobile number to send you relevant updates, insights and information about our services.
Where we rely on legitimate interests (B2B outreach): Where we have obtained your business contact details from publicly available sources (such as LinkedIn, TendersDirect or PublicContractsScotland), we may contact you about services relevant to your professional role. We do this on the basis of our legitimate interest in promoting our services to relevant professionals. You will always be offered a simple way to opt out at the time of first contact and in every subsequent communication.
In both cases, you can withdraw your consent or object to marketing at any time, free of charge, by contacting our Data Protection Lead or by using the unsubscribe link included in every marketing email we send.
If you have provided us with your postal address or telephone number, we may send you direct mail or telephone you about our work unless you have told us that you would prefer not to receive such information. We also actively check telephone numbers against the Corporate Telephone Preference Service (CTPS) and will only make telephone calls to you where your telephone number is listed on the CTPS if you have specifically told us that you do not object to such calls and have consented to receive them from SignalCX.
You can change any of your contact preferences at any time, including telling us that you don’t want us to contact you for marketing purposes, by contacting the Data Protection Lead:
Michelle Maguire
Data Protection Lead
Labinah Management Training Ltd t/a SignalCX
International House, 6 South Molton Street, London, W1K 5QF
Email: privacy@signal.cx | Tel: 0208 087 0178
We will never pass your personal data on to other organisations for them to use for their own marketing purposes.
However, we may disclose your personal data in the following circumstances:
Given that the Internet is a global environment, using it to collect and process personal data may involve the transmission of data on an international basis. Where personal data is transferred outside of the United Kingdom, we take steps to ensure that appropriate safeguards are in place.
In accordance with the Data (Use and Access) Act 2025, we assess whether the standard of data protection in the receiving country is not materially lower than that in the United Kingdom. Where required, we rely on UK-approved standard contractual clauses or on countries that have received a UK adequacy decision from the Secretary of State.
All data is held securely and in line with the requirements of UK data protection legislation. By communicating electronically with us, you acknowledge and agree to our processing of personal data in this way.
We keep your personal data for up to 6 years and 1 month after the creation date to operate the service in accordance with legal requirements and tax and accounting rules. Where your information is no longer required or is no longer relevant, we will ensure it is disposed of in a secure manner.
For Service Animals related data please refer to the Service Animals data processing section.
How to Make a Data Protection Complaint
If you have a concern about how we have handled your personal data, we encourage you to raise it with us in the first instance so that we can try to resolve it promptly.
You can submit a complaint via email to our Data Protection lead using the contact details below:
Michelle Maguire, Data Protection Lead
Labinah Management Training Ltd t/a SignalCX
International House, 6 South Molton Street, London, W1K 5QF
Email: privacy@signal.cx | Tel: 0208 087 0178
We will acknowledge your complaint within 30 days of receipt. We will then investigate and aim to provide you with a full response without undue delay.
If you are not satisfied with our response, or if you would prefer to escalate your complaint directly, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) — see “Your Rights” below.
At any point while we are in possession of your personal data, you have the following rights:
1. The right to access your personal data
2. The right to rectification and update your personal data
3. The right to request to have your personal data erased
4. The right to restrict processing of your personal data
6. The right to data portability
7. The right to lodge a complaint with a supervisory authority
1. The right to access your personal data
You have a right to obtain confirmation that your personal data is being processed. You also have the right to request a copy of your personal data we hold.
We will provide a copy of your personal data within one calendar month of receiving your written request. Should you wish to exercise this right we require you to prove your identity with two pieces of approved identification (photo ID and proof of address such as a utility bill). Please address requests to the Data Protection Lead.
2. The right to rectify and update your personal data
The accuracy of your personal data is important to us. You can rectify or update your personal data, including your address and contact details, at any time. Please address requests to the Data Protection Lead.
Please provide as much information as possible about your request. We will investigate and confirm our decision within one calendar month of the request.
3. The right to request to have your personal data erased
You have the right to request that your personal data be erased. This is not an absolute right, and we will review these on a case-by-case basis. Should you wish to exercise this right please address requests to the Data Protection Lead.
Please provide your reason for the request. We will consider this and advise you of our decision within one calendar month of the request.
4. The right to restrict processing of your personal data
You have the right to ‘block’ or suppress processing of your personal data. However, we will retain just enough of your personal data to ensure that the restriction is respected in the future. Please address requests to the Data Protection Lead with your reasons. We will respond within one calendar month.
5. The right to object
You have the right to object to your personal data being processed for marketing and for research purposes. From the very first communication from us, and in every marketing communication we send thereafter, you will have the right to object to marketing. You can exercise this right by contacting the Data Protection Lead. SignalCX will action your request within one calendar month of receiving it.
6. The right to data portability
Where we process your personal data on the basis of your consent or to perform a contract, and that processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format. You may also request that we transmit your data directly to another controller where technically feasible. Please address requests to the Data Protection Lead.
7. Your right to lodge a complaint with a supervisory authority
We encourage you to contact us in the first instance using the details in the “How to Make a Data Protection Complaint” section above. If you remain dissatisfied following our response, or if you wish to seek independent advice, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
The ICO is the UK’s independent body set up to uphold information rights in the public interest.
The Office of the Information Commissioner
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: +44 (0) 303 123 1113 (local rate) or +44 (0)1625 545 745 (national rate)
Website: www.ico.org.uk
This Cookie Policy explains how SignalCX (registered as Labinah Management Training Ltd) uses cookies and similar technologies on its websites, including www.signal.cx and www.serviceanimals.com. The cookies and third-party services used may vary depending on the website and functionality being accessed.
Strictly Necessary Cookies
These cookies are required for the operation of our websites and enable core functionality such as remembering your cookie preferences and maintaining website settings.
| Cookie Name | Purpose |
| acceptanceState | Stores your cookie consent preferences |
| wp-settings-* | Stores WordPress user preferences |
| wp-settings-time-* | Stores timestamps associated with WordPress user preferences |
Analytics Cookies
These cookies help us understand how visitors use our websites and allow us to improve content, navigation and performance.
| Cookie Name | Purpose |
| _ga | Used by Google Analytics to distinguish visitors |
| ga* | Used by Google Analytics 4 to maintain session state and generate website usage statistics |
| _gid | Used by Google Analytics to distinguish visitors |
| _gat | Used by Google Analytics to manage request rates |
Marketing Cookies
These cookies help us understand the effectiveness of advertising campaigns and marketing activities.
| Cookie Name | Purpose |
| _gcl_au | Used by Google Ads to measure advertising effectiveness and conversion activity |
Functional and Communication Cookies
These cookies support website forms, customer communications and visitor identification.
| Cookie Name | Purpose |
| hubspotutk | Used by HubSpot to recognise visitors and associate form submissions with a visitor record |
| __hstc | Main HubSpot visitor tracking cookie |
| __hssc | HubSpot session tracking cookie |
| __hssrc | HubSpot session management cookie |
Attribution Cookies
These cookies help us understand how visitors arrive at our websites and which pages they visit.
| Cookie Name | Purpose |
| handl_ip | Stores visitor attribution information |
| handl_landing_page | Records the page through which a visitor first entered the website |
| handl_url | Records website URL attribution information |
| handl_original_ref | Records the original referring source where available |
Third-Party Services
SignalCX websites may use third-party services including Google Analytics, Google Tag Manager, Google Ads, HubSpot, Microsoft Clarity, LinkedIn Insight Tag, PayPal and Cloudflare. These services may place cookies on your device or process information collected through cookies in accordance with their own privacy policies.
Not all services are used on every SignalCX website.
You can manage or delete cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our websites.
For more information about cookies generally, please visit www.allaboutcookies.org.
Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of those sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours. You should read other sites’ privacy policies before giving them your personal information.
Introduction
While carrying out our business activities relating to Service Animals®, we collect information from a range of sources and generate a substantial volume of data that is retained electronically. This is stored on Amazon Web Services (AWS) in a data centre situated in London (UK). Appropriate retention of data is necessary for our operational performance and is required to fulfil our range of client services.
However, the retention of data can lead to unnecessary and excessive use of electronic space, and indefinite retention of personal data can breach the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Failure to comply with these regulations can lead to significant financial penalties from the Information Commissioner’s Office (ICO). It is therefore essential that SignalCX has appropriate systems and processes in place for the preservation and timely disposal of documents and records in line with business requirements and relevant legislation.
Lawful Basis for Processing
The lawful basis for processing personal data in connection with Service Animals® is the performance of a contract between SignalCX and the client organisation (Article 6(1)(b) UK GDPR), and where applicable, our legitimate interests in operating and improving the service (Article 6(1)(f) UK GDPR). Data retained for tax and accounting purposes is processed on the basis of a legal obligation (Article 6(1)(c) UK GDPR).
Data Controller and Processor Relationship
In delivering Service Animals®, SignalCX acts as a data processor on behalf of the client organisation, which is the data controller. SignalCX processes participant data only in accordance with the documented instructions of the client organisation and in compliance with applicable data protection legislation.
A Data Processing Agreement (DPA) is in place between SignalCX and each client organisation, governing the terms under which personal data is processed. Participants wishing to exercise their data subject rights should contact their employer or client organisation in the first instance, or may contact SignalCX directly at serviceanimals@signal.cx.
Data Collected
In connection with Service Animals®, we may collect and process the following categories of personal data about individual participants:
Purpose
This policy sets out SignalCX’s approach to managing its information to ensure that records and documents are preserved in line with business and legislative requirements and that data is not retained for periods longer than necessary.
Scope
This Service Animals Data Retention Policy specifically applies to all staff, volunteers, consultants, contractors, trustees and, as appropriate, partnership organisations, partner staff and third parties of SignalCX. All records that are created, handled, stored, or processed by SignalCX, in electronic (soft copy) form or physically (hard copy) when the physical document forms part of a structured filing system.
Data Storage
For the purpose of this document, the term ‘Data’ pertains to Company and Individual data. All company and individual customer data is stored on a secure AWS server to ensure that applicable security, backup, retention and disposal controls can be carried out. AWS acts as a sub-processor of personal data on behalf of SignalCX and is subject to appropriate data processing terms. Data is stored in a UK-based AWS data centre. A current list of sub-processors used in the delivery of Service Animals® is available upon request.
Access to all data will be available to the data’s parent customers for a period outlined in the contract said company has in place with SignalCX. This period will only be as long as is reasonable to fulfil the contractual requirements with the client, will not be excessive, and the data subject’s right to erasure will be recognised and actioned in accordance with appropriate data protection legislation regardless of any contractually stated periods.
Anonymisation
SignalCX will maintain a record of non-personalised aggregated data on past individual participants in its Service Animals database to enable business planning and insight. To enable this, data will be ‘anonymised’ such that individuals cannot be identified within the dataset after a period of 5 years and 1 day. At this stage, the Personally Identifiable Information (PII) will be erased permanently without backup and will not be retrievable by any means. Anonymised profiles will remain on the Service Animals database indefinitely to provide benchmarking analysis and any statistical information required to deliver the client contract.
Right to Erasure (Right to Be Forgotten)
As per UK GDPR, participants have the right at any stage to request that their personal data be erased from the Service Animals® system. Erasure requests can be submitted by email to serviceanimals@signal.cx. The request will be actioned as quickly as possible, and the participant will no longer receive communications from serviceanimals.com. Deleted profiles cannot be retrieved.
Once a participant’s PII data has been erased at their request, it will not be re-added to the system without a fresh lawful basis and, where possible, the individual’s knowledge. SignalCX will inform the relevant client organisation of any erasure request that affects their account, in accordance with the terms of the applicable Data Processing Agreement.
Individuals who have previously requested erasure may purchase a new profile at any time of their own volition or through their relevant client organisation.
This privacy policy is subject to change from time to time to reflect changes in law or our data processing practices. It was last reviewed and updated in June 2026.
We commit to reviewing this policy at least annually, or following any significant change in data protection legislation or our processing activities. Where changes are material, we will communicate these to you.
This policy takes account of the Data (Use and Access) Act 2025 (DUAA), which amends the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).
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