0333 344 9588enquiry@reonex.co.uk
REONEX

REONEX Referral Portal Privacy Notice

Version: 0.1
Effective date: TODO(JAMIE) — set on approval
Status: ⚠️ DRAFT — NOT APPROVED. Rebranded from the inherited document on 30 October 2026. Not reviewed by a solicitor or a data-protection adviser. PORTAL_DOCUMENTS_APPROVED remains false, so partner registration is rejected until this is approved.

TODO(JAMIE): confirm REONEX's ICO registration. This notice describes a controller processing partner and referred-contact personal data at scale, including financial records. Most UK organisations doing that owe the ICO data protection fee and must be on the register. No registration number is published on reonex.co.uk and none could be verified here. If REONEX is registered, add the number below. If it isn't, that needs sorting before this portal collects a single partner record.

1. Who we are

Reo Group Ltd, trading as REONEX (REONEX, we, us or our), is the controller of personal information handled through the referral programme and referral portal.

Company number: 14840484
Registered office: 521 Thornton Road, Bradford, West Yorkshire, BD8 9RB, England
VAT number: 441639200
ICO registration number: TODO(JAMIE)
Email: enquiry@reonex.co.uk
Telephone: 0333 344 9588

This notice explains how we use information about:

It supplements the main REONEX website privacy policy at https://reonex.co.uk/privacy-policy/ where you use the referral portal. TODO(JAMIE): the two should be read together and kept consistent — the website policy was last updated 6 May 2025 and does not mention the referral portal, partner commission records or partner bank details.

2. Information we collect

Depending on your relationship with us, we may collect:

Partner and applicant information

Referred contact information

Partners must not submit passwords, credentials, unnecessary financial information, special-category information, criminal-offence information or unrelated personal details about a referred person.

Staff-user information

3. Where information comes from

We obtain information:

Where we receive a referred person's information from a partner, we will provide appropriate privacy information within a reasonable period and, where we contact that person, no later than our first communication unless a lawful exception applies.

4. Why we use information and our lawful bases

We use personal information only where we have an identified purpose and lawful basis.

Purpose Typical lawful basis
Create an account, consider an application and administer programme membership Taking steps at your request before entering a contract; performance of the Referral Programme Terms; and legitimate interests in operating a trustworthy referral programme
Verify applicants and prevent duplicate, fraudulent or abusive accounts Legitimate interests in protecting REONEX, partners, prospects and the programme
Receive, assess and progress referrals Performance of the partner agreement for partner data; legitimate interests of REONEX, the partner and the referred business in considering a relevant business introduction for referred-contact data
Contact a referred business about the stated business requirement Legitimate interests, following a proportionate assessment of the introduction, relationship and likely expectations of the contact
Calculate commission and manage invoices and bank-transfer payouts Performance of the partner agreement and compliance with accounting, tax and other legal obligations
Send verification, security, referral, commission and payment messages Performance of the partner agreement and legitimate interests in operating and securing the programme
Maintain audit, security and fraud-prevention records Legitimate interests in security, accountability, dispute handling and protection of legal rights; legal obligation where applicable
Respond to rights requests, regulators, courts or law enforcement Legal obligation and the establishment, exercise or defence of legal claims
Use non-essential analytics or similar technologies Consent where required; essential portal security and session technologies are used because they are necessary to provide and secure the service

We do not use portal registration or referral information for unrelated electronic marketing without identifying an appropriate lawful basis and meeting applicable electronic-marketing rules.

5. Our legitimate interests

Where we rely on legitimate interests, those interests include:

We must balance these interests against the rights and reasonable expectations of the people affected. We do not rely on legitimate interests where our interests are overridden by those rights. We document the assessment for material processing involving referred contacts and partner vetting.

6. Partner responsibilities when submitting a referral

The partner must confirm that they have a genuine business or professional relationship with the referred person, or another lawful and reasonable basis for making the introduction. The partner must tell the person that their details will be shared with REONEX, or obtain permission where permission is required.

This declaration does not remove REONEX's responsibility to identify and document its own lawful basis. We review referrals before using the information and provide the referred person with this notice as required.

7. Automated decisions

We may use automated matching to flag possible duplicate referrals or unusual activity. Automated flags do not by themselves approve, reject or penalise a partner or referral. An authorised person makes the substantive decision.

We do not currently make decisions based solely on automated processing that produce legal or similarly significant effects.

8. Who we share information with

We may share information, only where necessary, with:

We do not sell personal information. We do not allow service providers to use portal information for their own unrelated purposes.

9. International transfers

Some suppliers or their support operations may process information outside the United Kingdom. Before permitting a restricted transfer, we will use an applicable UK adequacy regulation or approved safeguards, such as the UK International Data Transfer Agreement or UK Addendum, and carry out any required risk assessment.

You may contact us for further information about the safeguards relevant to your information.

10. How long we keep information

We keep information only for as long as necessary for the relevant purpose, legal requirements, disputes and security. Our intended baseline periods are:

Record Intended retention
Incomplete/unverified signup Up to 90 days after the verification opportunity expires
Rejected partner application and vetting decision 12 months after the final decision, unless needed longer for an active complaint, fraud prevention or legal claim
Active partner account and programme records For the life of the account and ordinarily 6 years after closure or the final programme transaction
Unsuccessful or closed referral that does not become a customer Ordinarily 3 years after closure, subject to dispute, suppression and legal requirements
Successful referral and associated contract/commission history For the support-contract relationship and ordinarily 6 years after the final related transaction or end of the relevant financial year, whichever requires the longer period
Invoices, VAT records, commission and payout records At least 6 years, or longer where tax, accounting, investigation or legal requirements apply
Routine security and access logs Ordinarily 12 months; relevant extracts may be retained longer where connected with an incident, investigation or claim
Audit records For the period needed to demonstrate programme, security and financial accountability, aligned with the underlying record and applicable legal limitation periods

These periods may be extended where records cover multiple accounting periods, a regulator or authority requires preservation, litigation is anticipated or active, or another legal requirement applies. When identifiable information is no longer needed, we delete it securely or anonymise it.

11. Invoices and bank details

Partners provide bank-transfer details on their invoices. Invoices are financial records and are stored in private, access-controlled storage rather than public web storage.

Access is limited to authorised Finance and administrative users with a business need. Bank details must not be placed in referral notes, public links or ordinary portal messages. We may verify new or changed payment information before using it.

12. Security

We use proportionate technical and organisational safeguards, including access controls, individual staff accounts, mandatory administrator MFA, encryption in transit, secure password hashing, role-based permissions, logging, protected backups, patching and review of privileged and financial actions.

No internet service can guarantee absolute security. If you believe your account or personal information may be at risk, contact us promptly at enquiry@reonex.co.uk.

13. Your data-protection rights

Depending on the circumstances and lawful basis, you may have rights to:

These rights are not absolute. For example, we may need to retain invoices, commission records, audit evidence or information required for legal claims.

Your right to object

You have the right to object to processing based on legitimate interests. Tell us about your particular situation and we will stop unless we have compelling legitimate grounds to continue or the information is needed for legal claims. You have an absolute right to object to direct marketing.

To exercise a right, contact enquiry@reonex.co.uk. We may need to verify your identity before acting, but we will not request more information than is reasonably necessary.

14. Complaints

Please contact us first so we can investigate and address your concern.

You may also complain to the UK Information Commissioner's Office:

You may have the right to complain to another relevant supervisory authority depending on where you live or work.

15. Cookies and local storage

The portal uses essential cookies or similar storage for authentication, security, preferences and session continuity. Essential technologies cannot be disabled through the portal because the service cannot operate securely without them.

We will not activate non-essential analytics or marketing technologies until the required information and consent controls are in place.

16. Children

The referral programme is intended for adults acting in a business or professional context. People under 18 must not register or submit referrals.

17. Changes to this notice

We version this notice and record the version accepted or acknowledged by portal users. If a change materially affects how we use information, we will provide an appropriate notice and, where necessary, request a new acknowledgement or consent.

18. Contact us

For privacy questions or rights requests:

Reo Group Ltd, trading as REONEX
521 Thornton Road
Bradford
West Yorkshire
BD8 9RB
England

Email: enquiry@reonex.co.uk
Telephone: 0333 344 9588