Legal
Privacy Policy
Last updated: 25 October 2026.
Who we are
This website is operated by Universal Pozzolanic Silica Alumina Ltd ("UPSA", "we", "us"), a private limited company registered in England and Wales under company number 14892437, with its registered office at Quadrant House, Floor 6, 4 Thomas More Square, London E1W 1YW. Our office is at 21 Knightsbridge, London SW1X 7LY.
UPSA is the controller of the personal data described in this policy. Questions about this policy or your data can be sent to our contact form. We are not required to appoint a Data Protection Officer.
The personal data we collect
When you submit an enquiry
Our contact form (including sample requests) and our investor enquiry form collect:
- your name and email address (required);
- optionally, your organisation, telephone number, country and role;
- details of your enquiry — enquiry type, investor type, the application you are interested in, an estimated annual volume in tonnes, and your message;
- confirmation that you agreed to this policy, and the date and time of submission.
Please do not include sensitive personal data (such as health information) in your message.
When you use the "Ask about WPSA" assistant
Questions you type into the assistant are sent, together with the conversation so far, to an artificial-intelligence service so that an answer can be generated. We do not save these conversations to our enquiry records, and the conversation is cleared when you close or reload the page. Please do not enter personal or confidential information into the assistant.
Technical data
Our hosting provider processes technical data needed to deliver the website securely, such as IP address, browser type and request logs. We do not currently use analytics or advertising cookies; see our Cookie Policy.
How we use your data and our lawful bases
| Purpose | Lawful basis (UK GDPR Article 6) |
|---|---|
| Responding to product, technical and sample enquiries | Legitimate interests in answering enquiries and developing commercial relationships; or steps taken at your request before entering into a contract |
| Handling investor enquiries, including requests for the Competent Person's Report under a non-disclosure agreement | Legitimate interests in engaging with prospective investors and protecting confidential information |
| Following up on your enquiry by email or telephone | Legitimate interests. We will not add you to marketing mailings without your separate consent |
| Operating, securing and improving the website and the assistant | Legitimate interests in running a secure, functioning website |
| Keeping records required by law and establishing or defending legal claims | Legal obligation; legitimate interests |
Where we rely on legitimate interests, we have considered that these are not overridden by your rights. You can object at any time (see "Your rights").
Who we share it with
Only UPSA personnel who need to deal with your enquiry can access it. We use the following categories of service provider, each acting on our instructions under a written contract:
- website hosting and content delivery;
- cloud database hosting, where enquiries are stored;
- an artificial-intelligence service that generates the assistant's answers;
- email and office software.
We may also share data with our professional advisers (such as lawyers and accountants), with the independent technical consultants who evaluate the project where relevant to your enquiry, and with regulators, courts or law enforcement where the law requires it. We do not sell personal data.
International transfers
Some of our service providers process data outside the United Kingdom, including in the European Economic Area and the United States. Where this happens, we rely on UK adequacy regulations or on appropriate safeguards such as the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for details of the safeguards used.
How long we keep it
- Enquiries that do not lead to an ongoing relationship: up to 24 months from our last contact with you.
- Where an enquiry leads to a commercial or investment relationship, or an NDA: for the duration of that relationship and six years afterwards, in line with limitation periods under English law.
After these periods, the data is deleted or anonymised.
Security
Enquiry data is sent over encrypted connections and stored in a database that the public cannot read. Access to submitted enquiries is restricted to password-protected staff access. No method of transmission or storage is completely secure, but we take appropriate technical and organisational measures to protect your data.
Your rights
Under UK data protection law you have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected;
- have your data erased, or its use restricted, in certain circumstances;
- object to processing based on legitimate interests, including follow-up contact;
- receive your data in a portable format, where applicable.
To exercise any of these rights, email our contact form. We will respond within one month. There is normally no charge.
If you are unhappy with how we have handled your data, please contact us first. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113.
Changes to this policy
We will update this policy if our processing changes. The date at the top of this page shows when it was last revised.