1. Scope and who we are
This Privacy Policy applies to personal information processed by Luchar Concept Two Five Four Media Limited ("Concept254", "we", "us" or "our") through concept254.com, our enquiry and quotation tools, client work, business-development systems and professional communications.
We operate primarily across Kenya, South Africa and the United Kingdom and may work with people or organisations elsewhere. Depending on the person, market and activity, applicable law may include Kenya's Data Protection Act, 2019 and regulations, South Africa's Protection of Personal Information Act, 2013 (POPIA), or the UK GDPR, Data Protection Act 2018 and Privacy and Electronic Communications Regulations (PECR). Mandatory local protections continue to apply where they provide additional rights.
Our Outreach & AI Communications Notice provides additional information for business contacts who receive a communication from us.
2. Information we collect
Depending on how you interact with Concept254, we may process:
- name, business email address, business telephone number, job title and preferred contact method;
- organisation name, website, public business address, industry, company size, country and market;
- project requirements, service selections, budget range, timelines, goals, references and correspondence;
- files you intentionally provide, such as documents, images, spreadsheets or PDFs;
- publicly visible website characteristics, including technical, accessibility, analytics, search, content and contact-channel observations;
- the source and date of collection, qualification score, relevant service match and communication eligibility decision;
- email delivery, bounce, complaint, reply, unsubscribe, suppression and conversation status;
- consent, objection, lawful-basis and authorization records; and
- security and technical information such as server logs, timestamps, device or network information and automation execution records.
3. Where information comes from
We receive information directly from people who contact us, request a quote, reply to a message or become clients. For proportionate business development, we may also obtain business and professional information from an organisation's own website, public business directories, search services, professional data providers, prior correspondence, referrals and other lawfully accessible public sources.
Where information was not collected directly from you, you may ask us for the available source information by emailing hello@concept254.com.
4. How we use personal information
We use personal information where appropriate to:
- receive, review and respond to enquiries and quotation requests;
- prepare estimates, proposals, project scopes and client communications;
- discover organisations that may reasonably benefit from relevant Concept254 services;
- review public business websites, assess fit and avoid irrelevant outreach;
- create, approve, send and track proportionate business communications;
- classify replies, answer routine questions and route commercial intent to a person;
- maintain CRM, delivery, suppression and evidence records;
- deliver services and administer client relationships;
- secure, diagnose and improve our systems; and
- meet legal, accounting, dispute-management and regulatory obligations.
We do not sell personal information or use sensitive information to select outreach recipients.
5. Legal bases and market authorization
The basis depends on the activity and applicable law. It may include steps requested before a contract, performance of a contract, compliance with a legal obligation, consent, or a documented legitimate interest that is necessary, proportionate and balanced against individual rights.
A privacy notice does not itself authorize a marketing message. Before outreach, Concept254 applies market-specific rules, source and recipient checks, suppression screening and any required consent or existing-customer condition. Where consent is required, we do not substitute legitimate interests for consent. Where we rely on legitimate interests, you may object at any time.
6. Profiling, automation and artificial intelligence
We use automated tools to organize business information, review public website signals, score relevance, match potential needs to services, prevent duplicates, prepare draft communications, classify replies and identify when a human should take over. A low score may mean that we do not contact an organisation.
Automated scores are business-development indicators, not legal, credit, employment or similarly significant decisions. Artificial intelligence may assist with drafting and routine responses, but it is not authorized to conclude a contract, approve final pricing, promise delivery dates or make binding commitments for Concept254. A person can request human assistance at any time.
7. Direct marketing and communication choices
Our outreach is directed to relevant businesses and professional roles, subject to the law applicable to the recipient. Every eligible first-contact message must identify Concept254, explain the business context, provide access to this notice and offer a clear way to object or unsubscribe.
You can object by using an unsubscribe mechanism or replying "unsubscribe". We place the address or contact point on a suppression list and stop further marketing. Suppression information is retained only as needed to honour the objection and demonstrate compliance. Service, security or legally required messages may still be sent where they are not marketing.
See the Outreach & AI Communications Notice for Kenya, South Africa, UK and unsupported-market controls.
9. International transfers
Our international operations and cloud suppliers may process information outside the country in which it was collected. Where required, we use lawful transfer mechanisms and reasonable contractual, technical and organisational safeguards, taking account of the applicable Kenyan, South African or UK transfer requirements.
10. How long we keep information
We retain information only for as long as reasonably necessary for its purpose. Prospect and qualification records are periodically reviewed and deleted or anonymised when no longer relevant; correspondence and opportunity records may be retained while a commercial relationship remains reasonably possible; client, accounting and contractual records are retained for applicable legal periods.
Delivery and automation logs are kept for operational and security needs. Suppression records may be retained longer than ordinary prospect records because deleting them could cause an unwanted re-contact. Retention may be extended for a dispute, legal hold, security investigation or binding legal obligation.
11. Security
We use reasonable technical and organisational measures including access controls, credential protection, bounded automation, data minimisation, logging controls, duplicate prevention and suppression checks. No internet or storage method can be guaranteed completely secure.
12. Your privacy rights
Depending on applicable law, you may request access, source information, correction, deletion, restriction or portability; object to direct marketing or other processing; withdraw consent; and request meaningful information about relevant automated processing. You may also complain to the Office of the Data Protection Commissioner in Kenya, South Africa's Information Regulator, the UK Information Commissioner's Office, or another competent regulator.
Email hello@concept254.com to exercise a right or request human review. We may verify identity and will respond under the applicable law. An objection to direct marketing will be actioned without requiring you to justify it.
14. Children
Concept254 is directed to businesses, founders and professionals. We do not knowingly solicit children or use children's information for business outreach.
15. Changes to this policy
We may update this policy when our systems, suppliers, markets or legal obligations change. Material changes will be published here with a revised effective date.
16. Contact us
For privacy questions, objections, requests or complaints, email hello@concept254.com. For general enquiries, use our contact page.