Privacy Page

Mantle Hosting Limited - Data Privacy Notice


(A)             Welcome to Mantle’s privacy policy.

Mantle respects your privacy and is committed to protecting your personal data.

This privacy policy will inform you as to how We look after personal data which we hold in relation to our customers, potential customers, visitors of our website (regardless of where you visit it from) and other parties with whom we do or want to do business, and tell you about your privacy rights and how the law protects you.

This Policy applies as between you as the User of this Website and Mantle, the owner and provider of this Website. This Policy also applies to

our use and processing of any and all Data collected by us in relation to your use of the Website and any Data that we might collect and process about you from time to time such as data collected from our Clients as part of our work for our Clients.

(B)            This privacy policy describes, generally, how We, in our capacity as a “controller” or a “processor” under applicable laws process your Data relating to:


  • the use of our websites, marketing communications and associated services that link to this privacy policy
  • our former, current and prospective clients, including information related to the points of contact at our commercial entity clients,
  • individuals who communicate with us
  • individuals who use our goods and services, either for themselves on or behalf of an organization or entity or our Clients, and individuals whose Data we receive in providing goods and/or services.



Our use, disclosure and processing of Data about you will vary depending upon the circumstances.  This privacy policy is intended to describe our overall privacy and data protection practices.  In some cases, different or additional notices and policies about our data collection
and processing practices may be provided and apply to our processing of certain personal information and Data such as, by way of example only, Mantle acting as a data controller or a data processor of your Data if and when you use our app. A lot of the processing of your Data by us will be in relation to or in connection with the processing of your Data for or on behalf of our Clients who are involved in providing, operating and administering your pension and pension benefits.

This privacy policy does not apply to job applicants and candidates who apply for employment with us through our job application process
which is not via our Website and/or to our employees and non-employee workers whose Data is subject to different privacy policies which are provided to such individuals in the context of their employment or working relationship with us.

When we provide goods and services to our Clients we may act as controller or processor under applicable privacy and data protection laws. This means that we may receive or collect your Data from or on behalf of our Client.  In this case we will only process Data for or on behalf of and subject to the instructions of our Clients (who, from a privacy law perspective, are “controllers” with respect to your Data that we process for them or on their behalf). In some cases, where we are acting as a “processor” and our Clients’ privacy policies (and not this one) will apply to and control the processing of your Data. If you have any questions which privacy policy may apply, please contact us at the contact details below. Where we act in our capacity as a controller of your Data for the purposes of the General Data Protection Regulation this privacy policy will apply, as explained below. 

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Cookie”, “Cookies” means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out under the section headed Cookies in Clause 5;


“Cookie Law” means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;


“Clients” means our clients which include Pension companies, Pension administrators and/or actuarial consultancies, employee benefit consultancies, investments consultancies, in-house administrators, insurance firms and/or other parties to whom we provide goods and/or services such as technology related goods and/or services.


“Data” means collectively all information that you submit to Mantle via the Website and/or all information about you which we may obtain or may receive from time to time including from our Clients and third parties. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 2018 and the EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR);


“Mantle”, “We”, “us” and “our” means all and/or any companies in the 3173 group of companies that handle or process your Data as data controllers or data processors and as explained in this privacy policy, and details of these companies in the 3173 group of companies
are provided below.


“Pension administrator” means a party that operates, creates, maintains and/or administers a pension scheme for and/or on behalf of a Pension company; “Pension company” means a company that has a pension scheme where you are a member of that pension scheme and/or a policy holder and/or have some other benefit or entitlements in relation to that pension or scheme and reference to Pension company includes that company’s nominated representatives; Policy” means this privacy policy;


“User” and “your” and “you” means an individual that we obtain Data about including where we obtain that Data from:

(i)               Our Clients and third parties; and

(ii)             Where an individual accesses the Website and is not employed by Mantle and is not acting in the course of their employment for Mantle; and


“Website” means the website that you are currently using at and any sub-domains of this site unless expressly excluded by their own terms and conditions.


Unless the context otherwise requires, words in the singular shall include the plural and, in the plural, shall include the singular. Any words following the terms including, include, in particular, for example or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase or term preceding those terms.

2. Important Information and Who We Are

Purpose of this policy

This Website is not intended for or directed at children, and We do not knowingly collect Data relating to children. However, as part of our goods and/or services provided to our Clients it may be that from time to time, we process information about children such as if and when our Clients and/or third parties provide us with data that contains information about you such as where you are a pension policy holder or member of a pension scheme and those details include information about beneficiaries, dependents and/or children.


It is important that you read this Policy together with any other privacy policy or fair processing policy. We may provide on specific occasions
when We are collecting or processing personal Data about you so that you are fully aware of how and why We are using your Data. This Policy supplements other notices and privacy policies and is not intended to override them.


This privacy policy is issued on behalf of Mantle (as defined above) which for the purposes of this privacy policy consists of the 3173 Group
as defined below. When we mention “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the 3173 Group (as defined below) that is responsible for handling or processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.

Mantle Services Limited is the controller of this Website and is responsible for this website at and is the company that you should contact in the first instance regarding any processing of your Data via this website by Mantle.

Mantle (as defined above) may act as a data controller or data processor as explained in (B) above.

The 3173 group of companies is made up of different legal entities, details of which are as follows (the 3173 Group):

(a)             Mantle Services Limited of Linen Loft, Adelaide Street, Belfast, Northern Ireland, BT2 8FE (Company number NI623455);

(b)             Mantle Hosting Limited of Linen Loft, Adelaide Street, Belfast, Northern Ireland, BT2 8FE (Companynumber NI608643);

(c)             The 3173 Company Limited of Linen Loft, Adelaide Street, Belfast, Northern Ireland, BT2 8FE (Company number NI055847);

(d)             Spence & Partners Limited of Linen Loft, Adelaide Street, Belfast, Northern Ireland, BT2 8FE (Company number NI037760); and

(e)             Dalriada Trustees of Linen Loft, Adelaide Street, Belfast, Northern Ireland, BT2 8FE (Company number NI038344) 

We (Mantle) 
have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy and/or data processing by companies in the 3173 Group, including any requests to exercise, please contact the data privacy manager using the details set out below.


Contact details

If you have any questions about this Policy or our privacy practices, please contact our data privacy manager in the following way:

Email address:

Postal address: Mantle Services Limited of Linen Loft, Adelaide Street, Belfast, Northern Ireland, BT2 8FE

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues whose contact details can be found at this site:

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance to see if we can help you with any concerns or questions that you may have although you may of course contact the ICO at any time and before you contact us.

Mantle may, from time to time, expand or reduce our business, and this may involve the sale and/or transfer of control and/or other dealings with all of or part of Mantle. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.


In the event that any Data submitted by Users is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.


Changes to the privacy policy and your duty to inform us of changes

It is important that the personal Data We hold about you is accurate and current. Please keep us informed if your personal Data changes during your relationship with us.

Mantle reserves the right to change this Policy as We may deem necessary from time to time or as may be required by law. We keep this Policy under regular review. This version was last updated in  December 2023. Historic versions can be obtained by contacting us.


Any changes will be posted on the Website, and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.


3. Third-party links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We do not control these third-party websites and are not responsible for their privacy statements. This Policy does not extend to your use of any websites that can be accessed from this Website, including, but not limited to, any links We may provide to social media websites. When you leave our Website, We strongly encourage you to read the privacy policy of every website you visit.


The data we collect about you

Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal Data about you, which We have grouped together as follows:

  •                  Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
  •               Contact Data includes home address, email address and telephone numbers;
  •                  Demographic information such as postcode, preferences and interests;
  •                  Financial Data includes bank account details;
  •                Transaction Data includes details about payments to and from you and other details of products and services (including any pensions);
  •                  Technical Data includes internet protocol (IP) address (automatically collected), your login data, browser type and version, time zone              settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use          to access this website;
  •              Profile Data includes your username and password, purchases or orders made by you or changes requested by you (including any                  orders or changes relating to or connected with your pension)  your interests, preferences, feedback and survey responses and other                details about you such as your CV if you are applying for employment with us and inferences drawn from any of the Data that we                    process about you so as to create a profile about you which may include your preferences, characteristics, behavior and attitudes by you          or changes requested by you (including any orders or changes relating to or connected with your pension) your interests, preferences,              feedback and survey responses and other details about you such as your CV if you are applying for employment with us and inferences            drawn from any of the Data that we process about you so as to create a profile about you which may include your preferences,                        characteristics, behavior and attitudes;
  •              Usage Data includes information about how you use our website, products and services;
  •          Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your                       communication preferences; and/or
  •              Pensions Data includes information about you and your pension including Data that has been passed or transferred to us by our Clients          and/or third parties and this will include information such as your contact details, salary history, pension benefits, membership dates,                contributions to the pension scheme, dependents (which may include details of your family and dependents including children),                        investment information, your age and medical history and pension benefits and entitlements.
  •              a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected).


We also collect, use and share Aggregated Data, such as statistical or demographic Data, for any purpose. Aggregated Data could be derived from your personal Data but is not considered personal Data in law as this data will not directly or indirectly reveal your identity. For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if We combine or connect Aggregated Data with your personal Data so that it can directly or indirectly identify you, We treat the combined Data as personal
Data, which will be used in accordance with this Policy.

We may from time to time collect and process Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your
health, and genetic and biometric data) and criminal records as part of our work for our Clients regarding helping them administer pensions and pension schemes of which you may be a policy holder or pension member. We do not collect any information about criminal convictions and offences on this Website.

Where we hold ‘special categories’ of personal data, we will only process special categories of personal data for the purposes of carrying out
our obligations as a data processor (and where this data has been passed to us by Clients and/or third parties who are data controllers) and where we need to process this data so as to establish and monitor and maintain details regarding your rights to your pension scheme and your benefits and entitlements under a pension scheme. Our legal basis for processing special categories of personal data is your prior explicit consent which may have been obtained from you during the course of you joining the relevant pension scheme or otherwise.


The reason we need to hold and process this special category data is as a contracted processor or sub-processor on behalf of our Clients  or third parties who use Mantle to hold and process data so that they can properly operate and administer benefits and pay pension and other benefits to you as a policy holder or pension scheme member as and when those benefits and entitlements are due to be provided to you.


If you fail to provide personal data

Where We need to collect personal Data by law or under the terms of a contract We have with you and/or one of our Clients, and you fail to provide that Data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with goods or services). In this case, We may have to cancel a product or service you have with us, but in these circumstances We (and/or our Clients and/or a relevant third party) will notify you if this is the case at the time.


4. How is your personal data collected?

We use different methods to collect Data from and about you, including:


  •  Information that we ask for, and you provide to us, that is necessary for us to supply your business with our software, support, and other related services.
  •  When you opt to submit personal information, in order for us to send you further information or email alerts; when you request to view certain content, such as white papers, or when you register for an event, conference or webinar.
  • Information which is collected and stored during normal use of our websites and portals, such as your IP address and the pages you visited.
  • Direct and Indirect interactions. You may give us your Identity, Contact and Financial Data, Transaction Data, Demographic and Financial Data, Profile Data and Pensions Data directly or indirectly by filling in forms or by corresponding or communicating with us and/or our Clients by post, phone, email or otherwise. This includes personal Data you provide to us and/or that our Clients provide to us about you when you:
    •          apply for or use our products or services and/or our Client’s products or services;
    •     create an account on our Website or a website of one of our Clients
    •     subscribe to our service or publications or services or publications of our Clients;
    •      request marketing to be sent to you;
    •      enter a competition, promotion or survey; or
    •     give us or our Clients feedback or contact us or one of our Clients



  • Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal Data by using Cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our Cookies. Please see the section of this Policy headed Cookies for further details.



  • Third parties or publicly available sources. We may receive personal Data about you from various third parties and public sources as set out below:



  • Technical Data from the following parties:

(a)            analytics providers such as Google based outside the United Kingdom;

(b)            advertising networks; and

(c)             search information providers.               

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register based inside the United Kingdom.

5. How we use your personal data

Any personal Data you submit will be retained by Mantle.

Unless We are obliged or permitted by law to do so, and subject to the section headed Third-Party Websites and Services, your Data will not be disclosed to third parties. This does not include our affiliates and/or other companies within our group and/or our Clients who (as data controllers) have engaged us (as data processors) to process your data for them so that they can operate and administer and manage your pension.

We will only use your personal Data when the law allows us to. Most commonly, We will use your personal Data in the following circumstances:

·                   where We need to perform the contract or We are about to enter into or have entered into with you;

·                   where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not                             override those interests; and/or

·                   where We need to comply with a legal obligation.


Generally, We do not rely on consent as a legal basis for processing your personal Data (except in the case of special category data which is covered elsewhere in this privacy policy), although We will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.


All personal Data is stored securely in accordance with the principles of the Data Protection Act 2018. For more details on security, see Clause 8 below.


Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways We plan to use your personal Data and which of the legal bases We rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that We may process your personal Data for more than one lawful ground depending on the specific purpose for which We are using your Data. Please contact us if you need details about the specific legal ground We are relying on to process your personal Data where more than one ground has been set out in the table below.



Type of data

Lawful basis for processing, including basis of legitimate interest

To register you as a new customer

(a)   Identity

(b)   Contact

Necessary for our legitimate interests in relation to providing goods and/or services to you and developing and growing our business

To process and manage and deliver goods and services to you in relation to your pension including using your Pension Data. This can include associated uses such as tracing you so as to notify you about circumstances or matters relating to you in relation to the goods and/or services provided to you if you have moved address

(a)   Identity

(b)   Contact

(c)   Financial

(d)   Transaction

(e)   Profile

(f)    Pensions Data

(g)   Marketing and Communications

Necessary for our legitimate interests (to keep our records updated and to study and understand how customers use our products/services and our Client’s products/services and to fulfil contracts with our Clients and to develop and grow our business)

To manage our relationship with you, which will include:

(a)   Notifying you about changes to our terms or privacy Policy

(b)   Asking you to leave a review or take a survey

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Marketing and Communications

(a)   Performance of a contract with you

(b)   Necessary to comply with a legal obligation

(c)   Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw competition or complete a survey

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing and Communications

(a)   Performance of a contract with you

(b)   Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a)   Identity

(b)   Contact

(c)   Technical

(a)   Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b)   Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing and Communications

(f)    Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences including improving the security and functioning of our website, networks and information.

Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance and/or to provide a better user experience, including the use of AI (e.g., machine learning). This includes marketing analytics and analytics related to the organization of events and meetings.

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing Communications

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a)   Identity

(b)   Contact

(c)   Technical

(d)   Usage

(e)   Profile

(f)    Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available. This includes:

(i)     administrative and regulatory tasks and reporting obligations associated with this activity

(ii)   data analytics to compare your details with our applicant pool including administration and operation of any employment related tests

(iii) keep recordings of any interviews whether in writing or otherwise

(iv) add your details to our database and share your details with third parties such as other recruiters for the purpose of keeping you up to date with job opportunities

(v)   administration of any employee related matters including administration of employee benefits

(a)   Identity

(b)   Contact

(c)   Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Using social content so as to understand what is being said to us and about us and our clients on social media (only publicly accessible content) including market trends. Monitoring conversations and comments and monitoring publicly available opinions, statements or other interactions on social media channels.

(a)   Identity

(b)   Contact

(c)   Technical

(d)   Usage

(e)   Profile

(f)    Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Audio, video and transcription captured during any events or meetings (whether pre-recorded or live) to inform participants and viewers and any other users about the relevant content of such events and meetings including online publication of recordings for marketing purposes.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business



We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

1.                 use of Data for direct marketing purposes; and


2.                 sharing Data with third parties.


Promotional offer from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what We think you may want or need or what may be of interest to you. This is how We decide which products, services and offers may be relevant for you (we call this marketing).


You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.


Third-party websites and services

Mantle may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, the following:

·                   payment processing;

·                   delivery of purchased services;

·                   search engine facilities;

·                   advertising and marketing; and/or

·                   locating and tracing services.

The providers of such services may have or be given access to certain personal Data provided by the Users of this Website and/or Data that you have provided to our Clients who have in turn provided this Data to us as a data processor so as to assist them with operating and administering your pension.

Any Data used by such parties is used only to the extent required by them to perform the services that Mantle requests. Any use for other purposes is strictly prohibited.

Furthermore, any Data that is processed by third parties shall be processed within the terms of this Policy and in accordance with the Data Protection Act 2018.


Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.



This Website may place and access certain Cookies on your computer. Mantle uses Cookies to improve your experience of using the Website
and to improve our range of services. Mantle has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current EU Cookie Laws. 

You may, if you wish, deny consent to the placing of Cookies by 
amending the privacy settings within your browser; however, certain features of the Website may not function fully or as intended.


You can set your browser to refuse all or some browser Cookies or to alert you when websites set or access Cookies. If you disable or
refuse Cookies, please note that some parts of this website may become inaccessible or not function properly.

Certain features of the Website depend upon Cookies to function. Cookie Law deem these Cookies to be “strictly necessary”. These Cookies are shown below. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings.

This Website uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse usage
statistics, enabling us to better understand how Users use the Website. This, in turn, enables us to improve the Website and the services offered through it. You do not have to allow us to use these Cookies, as detailed below. However, whilst our use of them does not pose any risk to your privacy or your safe use of the Website, it does enable us to continually improve our business.

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to
disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently, including but not limited to, personalisation settings.


It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.


Change of Purpose

We will only use your personal Data for the purposes for which We collected it unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If We need to use your personal Data for an unrelated purpose, We will notify you, and We will explain the legal basis which allows us to do so.


Please note that We may process your personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


6. Disclosures of your personal data

We may share your personal Data with the parties set out below for the purposes set out in the table Purposes for which We will use your personal data above.

·                   Internal Third Parties as set out in the Glossary.

·                   External Third Parties as set out in the Glossary.

·                   Specific third parties listed in the table Purposes for which We will use your personal data.

·                   Third parties to whom We may choose to sell, transfer or merge parts of our business or our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal Data in the same way as set out in this Policy.


We require all third parties to respect the security of your personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal Data for their own purposes and only permit them to process your personal Data for specified purposes and in accordance with our instructions.


7. International Transfers

If and when We transfer your personal Data out of the United Kingdom, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

·                   We will only transfer your personal Data to countries that have been deemed to provide an adequate level of protection for personal                       Data.

·                   Where We use certain service providers, We may use specific contracts approved for use in the United Kingdom which give personal                     Data the same protection it has in the United Kingdom.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal Data out of the United Kingdom.


8. Data security

Data security is of great importance to Mantle, and to protect your Data We have put in place appropriate physical, electronic and managerial security measures to prevent your personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, We limit access to your personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal Data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal Data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.


Mantle is certified to ISO 27001, Cyber Essentials Plus and Cloud Security Alliance CSA STAR, all of which are independently audited by external accreditation bodies.  Protecting information is vital, and achieving the high standards required for these certifications reaffirms our commitment to do so.


9. Data retention

How long will you use my personal data?

We will only retain your personal Data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal Data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal Data, We consider the amount, nature and sensitivity of the personal Data, the potential risk of harm from unauthorised use or disclosure of your personal Data, the purposes for which We process your personal Data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, We have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your Data: see your legal rights below for further information.


In some circumstances, We will anonymise your personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.


10. Your legal rights

Under certain circumstances, you have rights under Data protection laws to do the following in relation to your personal Data:

·                   request access to your personal Data;

·                   request correction of your personal Data;

·                   request the erasure of your personal Data;

·                   object to the processing of your personal Data;

·                   request restriction of processing your personal Data;

·                   request transfer of your personal Data; and/or

·                   right to withdraw consent.


If you wish to exercise any of the rights set out above, or if you wish to make a data subject access request, please contact  


No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.


What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal Data (or to exercise any of your other rights). This is a security measure to ensure that personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, We will notify you and keep you updated.


11. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


Third parties

Internal Third Parties

Companies in the 3173 Group and 3173 Topco Limited and 3173 Limited which are based in the United Kingdom and provide pensions related services and undertake leadership reporting.

External Third Parties

·                   Service providers acting as processors based the United Kingdom who provide IT and system administration services, such as those used to provide customer relationship management services, data centres, software support services, finance and billing services, marketing platforms, software development tracking services, training programmes, event registration services, and online advertisements.

·                   Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.


·                   HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.


Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which overrides your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

·                   If you want us to establish the data’s accuracy.

·                   Where our use of the data is unlawful, but you do not want us to erase it.

·                   Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

·                   You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


Lets talk about you​

To discuss how we can help with your company pensions and challenges, please contact us.

For general enquires

Linen Loft
27-37 Adelaide Street
Belfast , BT2 8FE UK
+44 28 9041 2888

Mantle is a software product, created and developed by Mantle Hosting Limited. The software is marketed and sold by Mantle Services Limited.
Mantle Hosting Limited is certified under ISO/IEC 27001:2013 (click here to download certificate) and CSA STAR (click here to download certificate) for services and activities related to Mantle.  Click here to view our Data Privacy Notice.