Universal Business Team (UBT) is committed to the protection of your personal information in accordance with the Data Protection Act 1998 and the Data Protection Directives set out in the European Union directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data.  UBT refers to UBT (EU) Ltd trading as 'UBT', company 4938684 registered in England and Wales. The registered address is: Exchange Place, Poseidon Way, Warwick, CV34 6BY, UK..  This Privacy Policy shall apply to UBT and any entities which are owned or controlled by UBT that are involved in the business conducted by UBT.

This Privacy Policy describes the manner in which UBT collects, holds, uses and discloses personal information.  If you wish to make any inquiries regarding this Privacy Policy, you should contact UBT's Privacy Officer by telephone on Tel +44 (0)24 7649 6232   or by email at the following address: [email protected]

UBT may, from time to time, review and update this Privacy Policy to take account of new laws and technology.  All personal information held by UBT will be governed by its most recent policy, posted on this website.  This Privacy Policy was last updated in November 2011.


1.   What is "Personal Information"

1.1   "Personal Information" means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.


2.   When do we collect Personal Information?

2.1  UBT collects Personal Information from its customers and potential customers in a variety of ways.  UBT may collect Personal Information such as your name, contact details and occupation when you visit or register on our website, use products or services, enter promotions or sweepstakes or contact us by telephone.  From time to time, UBT conducts surveys that may include questions relating to your Personal Information.  Any Personal Information you agree to provide in response to these surveys will also be collected by UBT and may be held, used and disclosed in accordance with this Privacy Policy.

2.2  UBT may also collect Personal Information about you via suppliers and business partners.  However, UBT will only collect your Personal Information in this way if it is not reasonable or practical to collect this information directly from you.


3.   Information collected via this website

3.1  UBT will not collect any Personal Information about visitors to this website except when they knowingly provide it or as otherwise described below. For example, UBT will collect Personal Information from users to its website when they register to use the website, receive e-mail updates from UBT, or enter promotions or sweepstakes.


Click Stream Data

3.2  When you visit and browse this website, UBT’s website host will collect Personal Information for statistical, reporting and maintenance purposes.

3.3  This information will not be used to identify you and may include:

  • the number of users visiting this website and the number of pages viewed;
  • the date, time and duration of a visit; or
  • the path taken through this website.

3.4  UBT’s website host uses this information to administer and improve the performance of this website.



3.5  Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns.

3.6  If you access this website, a cookie is downloaded onto your computer's hard drive when you first log onto this website and it is automatically deleted from your hard drive after a period of thirty days.


Web Beacons

3.7  Web beacons are images that originate from a third party site to track visitor activities. UBT currently uses web beacons to track the visiting patterns of individuals accessing this website.


4.    How UBT uses the Personal Information it collects about you

4.1  UBT uses the information it collects about you to:  

  • Provide you with products or services you have requested;
  • Personalise and customise your experiences with this website;
    • Help UBT research the needs of its users and to market its products and services with a better understanding of your needs and the needs of users generally;
    • Communicate with you;
      • Provide you with ongoing information about UBT in which UBT believes you may be interested;
      • Give you the opportunity from time to time to receive e-mail and 'e-newsletters' from UBT; or
      • Other Personal Information provided voluntarily by you is used to better understand UBT's users and to help improve and promote its services.

UBT will only collect and use your Personal Information in accordance with this Privacy Policy or otherwise with your prior express written consent.

4.2   If you choose not to provide your Personal Information to UBT for the purposes set out in this Privacy Policy, the only consequence for you will be that we will not be able to provide you with the requested service or access to the site.


5.   Who we disclose your Personal Information to

5.1  UBT discloses the information about its customers and potential customers if or when UBT:

  • has your consent to share the information;
  • or someone acting on UBT’s behalf provides the product or service you have requested; or
  • reasonably believes that your actions on the website violates UBT’s Terms of Use.

5.2  UBT may disclose Personal Information to third parties but only to the extent necessary to fulfil the purposes for which the Personal Information was collected.  For example, UBT may disclose Personal Information to UBT’s officers and employees and its professional advisers and consultants to help improve the services offered by UBT, but only on a confidential and need-to-know basis. 

5.3  UBT may also disclose your Personal Information to our website host in certain limited circumstances, for example ensuring that if the website experiences a technical problem it is able to operate in an effective and secure manner.

5.4  UBT may disclose your Personal Information to organisations that are located in foreign countries solely for the purposes set out in this Privacy Policy provided that such disclosure is permitted under the Data Protection Directives .  For example, the Data Protection Directives permit disclosure to a person in a foreign country where

UBT reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Data Protection Directives .


6.   Marketing

6.1  UBT may use your Personal Information to provide you with promotional material about UBT or the services and products offered by UBT.  If you do not wish to receive promotional information, you can contact our Privacy Officer by emailing [email protected]  at any time so that your name can be removed from its marketing lists.

6.2  Otherwise, UBT will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted by the Data Protection Directives.


7.  Finding out what Personal Information UBT holds about you

7.1 You are entitled to access Personal Information that UBT holds about you.  If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted under the Data Protection Directives.  If UBT refuses your request to access your Personal Information, it will provide you with reasons for the refusal.

7.2  A request for access can be done in any of the following ways:

phone:  +44 (0)24 7649 6232

email:  [email protected] 

write to:

Exchange Place, Poseidon Way, Warwick, CV34 6BY, UK.


8.  Updating, storage and security of Personal Information held by UBT

8.1   UBT aims to keep your Personal Information secure and up to date.  Any Personal Information that is collected via this website or which is held on UBT's computer systems is protected by SSL encryptions for data transmission.

8.2   Personal Information that is held by UBT in hard copy is stored securely on its premises and is only disclosed or used for the purposes described in this Privacy Policy.

8.3   You can update your contact and profile information at any time by contacting our Privacy Officer on the number above or you may edit your UBT account information and preferences.  If we find that we have no further need for your Personal Information we will permanently de-identify it or remove it from our system and destroy all record of it.  UBT welcomes any changes to your details so as to keep our records up to date.


9.  What to do if you have a question, problem or complaint about our use of your Personal Information

9.1    If you feel that your privacy has not been respected or that UBT has conducted itself inconsistently with this Privacy Policy or the Data Protection Directives in respect of your Personal Information, please contact our Privacy Officer in any of the following ways:

phone:  +44 (0)24 7649 6232

email:  [email protected] 

write to:

Exchange Place, Poseidon Way, Warwick, CV34 6BY, UK.