Devon data campus
Privacy policy
Last updated 28 July 2026
Xlinks respects your privacy and is committed to protecting your personal data. This privacy policy informs you about how we look after your personal data either when you provide it to us directly or indirectly, in person, by phone, by email or when you visit our website (regardless of where you visit it from). This privacy policy also tells you about your privacy rights and how the law protects you.
Purpose of this privacy policy
This privacy policy aims to give you information on how Xlinks collects and processes your personal data in connection with the Devon Data Campus projects. This includes data obtained through our website, other public sources or otherwise when you interact with us whether in person (for example, when attending one of our consultation events or information days), by phone or by email. This includes any personal data you may provide when you:
register your interest in our projects either through our website or through any other means of engagement
provide views or feedback on our projects, whether as part of a consultation, public information days or written representations process or otherwise
contact us with enquiries, requests or to make a complaint
otherwise contact or interact with us.
It is important that you read this privacy 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.
Controller
This privacy policy applies to Xlinks 1 Ltd (13481017) with registered office address at Kingfisher House, Woodbrook Crescent, Billericay CM12 0EQ and the following affiliated entities with the same registered office address: Stratus Data Developments Limited (16136860) and Nexus Auxiliary Equipment 1 Limited (16464130). Xlinks 1 Ltd and each of those affiliated entities are independent controllers in respect of the personal data they process under this privacy policy. When we refer to “we”, “us”, and “our”, we mean any one or more of those data controllers, as appropriate. By “you” or “your” we mean any individual, sole trader and/ or partnership that uses our website, or interacts with us in another way and provides personal data to us. This privacy policy supplements, or may be supplemented by, other privacy policies you might have from us – but it doesn’t replace them.
Contact details
If you have any questions about this privacy policy or our privacy practices, you can contact us in the following ways:
Xlinks Data Privacy
Kingfisher House
Woodbrook Crescent
Billericay
CM12 0EQ
United Kingdom
Website: https://www.devondatacampus.com
Email: privacy@xlinks.co
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 28 July 2026.
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.
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. When you leave our website, we 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 who is identifiable or can be identified. It does not include data that has been anonymised so that individuals are no longer identifiable.
Whenever you interact with us, we may collect, use, store and transfer different kinds of personal data about you. The following types of data may be collected from you:
| Identity Data | first name, last name, title, date of birth, marital status, gender and job role (where communicating on behalf of an organisation), and your image or other physical characteristics where captured in photographs or video recordings |
| Contact Data | address, email address and telephone numbers |
| Technical Data | internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website |
| Correspondence Data | Views, comments, preferences, feedback, responses and representations whether as part of a consultation process or otherwise, and project updates to interested parties on an ongoing basis |
| Enquiry Data | information you provide when you contact us (including through in person or written feedback or survey responses) via:
or interact with us at any public information day, consultation event, exhibit, industry or other public event |
| Usage Data | information about how you use our website |
| Marketing and Communications Data | your preferences in receiving marketing from us and our third parties and your communication preferences |
| Special Category Data | this may include personal data relating to your race or ethnicity, political or religious views, sexual orientation or your health, which you provide to us voluntarily. In limited circumstances, where you provide health-related information which is relevant to our assessment of the impact of the Devon Data Campus projects on affected households or neighbours, we may ask follow-up questions to better assess the impact and identify appropriate mitigation measures |
| Personal Data Relating to Children | information relating to children that you provide voluntarily to us e.g. in response to consultations or written representations as part of examination in the planning process. In limited circumstances, where information relating to a child is relevant to understanding or assessing the impact of the Devon Data Campus projects on affected households or neighbouring properties, we may collect additional information about the child. This may include information about a child's protected characteristics under the Equality Act 2010 or other particular needs or circumstances, where relevant to assessing potential impacts and identifying appropriate mitigation measures |
| Other Data | any other information relating to you that you may voluntarily provide to us, such as information about your personal circumstances, disability or health conditions, or those of your dependents, that you believe are relevant to Xlinks’ plans or proposed projects |
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 privacy policy.
We do not collect any information about criminal convictions and offences.
If you voluntarily provide us with Special Categories of Personal Data about you or your dependents which you believe is relevant to us or our projects, or if we collect it as part of our assessment of the potential impacts on affected households or neighbouring properties, we may record such information and use it for the purposes described in this privacy policy. We ask that any such information is kept to a minimum and if it is personal data about other individuals, you should ensure you have their permission to share it with us, or are otherwise legally permitted to do so, e.g. in the case of your minor children.
How is your personal data collected?
We use different methods to collect data from and about you including through:
| Direct interactions | You may give us your Identity Data, Contact Data, Correspondence Data, Enquiry Data and Special Category Data by filling in forms or by corresponding with us in person or by post, phone, email or otherwise. This includes personal data you provide when you do one of the following (non-exhaustive list):
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| 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 and other similar technologies as described in the cookies section below. |
| Third parties or publicly available sources | We will receive personal data about you from various third parties and public sources, for example (non-exhaustive):
We may also periodically monitor publicly available discussions, forums, comments and posts on social media platforms such as Facebook for the purposes described below. Where reasonably necessary for those purposes, we may retain links to, or copies of, relevant content, including screenshots. |
How we use your personal data
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 you have given your consent, so have specifically provided your personal data for a specific purpose e.g. if you provide your contact details so that we can keep you updated on our projects.
Where we need to perform the contract 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.
Where we need to comply with a legal obligation, and to ensure we can meet, demonstrate and/or establish our legal rights and responsibilities.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. We may also need to get your explicit consent if we process any Special Category Data which you voluntarily provide to us, depending on how this will be used. You have the right to withdraw such consent at any time by contacting us at privacy@xlinks.co.
Purposes for which we will use your personal data
We have set out in more detail below, in a table format, the purposes for which we will use your data and the legal bases which we rely on to do so:
| Project updates | To keep you updated on Xlinks’ projects | Consent |
| Communications | To respond to and manage queries, requests for information and complaints | Legitimate interests – to ensure that stakeholders are kept informed, and complaints are dealt with |
| Project planning | To inform planning of projects and the application for planning and other statutory consents | Legal obligation |
| Planning consultations / planning process | To conduct consultation and stakeholder engagement activities, obtain and consider views and feedback, analyse consultation responses, respond to representations, and support the design, assessment, planning and development of our projects | Legal obligation (for statutory consultations) Legitimate interests (for non-statutory consultations) – to obtain stakeholder views on projects and to take account of any views in the planning and development of any project Recognised legitimate interest – sharing personal information to help other organisations perform their public tasks or official functions Substantial public interest (statutory etc and government purposes) (where Special Category Data is processed for this purpose) |
| Contract and supply chain opportunities | To engage with you in respect of the opportunity to tender to provide supplies or services to Xlinks and the provision of supplies or services to or by Xlinks | Legitimate interests – to engage with potential suppliers |
| Events and promotional activity |
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Legitimate interests – to manage attendance at our events and the smooth running of events Legitimate interests – for photographs and video footage to be taken Recognised legitimate interest – sharing photographs and video footage with law enforcement authorities to help them perform their public tasks or official functions, including proactively sharing where we reasonably consider this necessary to help prevent or respond to an incident or safety/security risk |
| Public and stakeholder engagement monitoring | To understand public views about the Devon Data Campus projects, support stakeholder engagement activities, inform project planning and engagement activities, and help ensure the safety and security of events. | Legitimate interests – to engage effectively with stakeholders and local communities, inform project planning and development, and help ensure the safety and security of project events |
| Our business purposes |
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Legitimate interests – for running our business, provision of administration and IT services, network security. |
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Legitimate interests – to improve our website and to improve user and stakeholder relationships and experiences | |
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Legitimate interests – to ensure continuity of operations | |
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Legitimate interests – to exercise and defend our legal rights Legal obligation |
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Legitimate interests – to exercise and defend our legal rights | |
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Legal obligation | |
| Managing our relationship with you | To notify you about changes to our privacy policy or any other terms and to ask you to leave a review or take a survey | Legal obligation Legitimate interest - to improve user and stakeholder relationships and experiences |
We may use your personal data for other purposes, but this will be made clear at the point of collection and a separate and supplementary privacy policy will be issued.
If you choose not to provide your personal details to us, we may not be able to deliver the information or services which you have requested and in respect of which we have asked you for that personal data. If the failure to provide the personal data means that we are unable to perform a contract with you, we may have to cancel that contract, but will advise you of the same.
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.
Automated decision-making
Automated decision-making occurs when a decision is made about you based on your personal data, which has a legal or similarly significant effect on you, but which is made by an automated system and without meaningful human involvement. We do not currently make any automated decision-making about you.
Cookies
Like other websites, information and data on visitors to the Xlinks’ website may be automatically collected through cookies and similar technologies. Cookies are small files placed on website users’ device to distinguish you from other users of the website. This helps us to provide you with a high-quality experience when you browse the website and also allows us to improve the website. We use cookies to analyse the flow of information; customise the services and content; measure promotional effectiveness; and promote trust and safety.
Our website is hosted using Squarespace which may place cookies and similar technologies on your device when you use our website. These include:
Necessary and required cookies
These cookies are required for the website to operate and to support core functionality, ensuring that website features work as intended. They are also used to remember user preferences and choices, such as language preferences or customised settings. These cookies allow Squarespace, our hosting platform, to securely serve this website to you.
The necessary and required cookies used on Xlinks’ website may include:
| Name | Duration | Purpose and duration |
|---|---|---|
| Crumb | Session | Prevents cross-site request forgery (CSRF) |
| ss_cvr | 2 years | Identifies unique visitors and tracks a visitor’s session on a site |
| Ss_cvt | 30 minutes | Identifies unique visitors and tracks a visitor’s session on a site |
| ss_performancecookiesAllowed | 30 days | Remembers if a visitor agreed to placing Performance and Analytics cookies on their browser, if your site has a cookie banner and is restricting the placement of cookies |
| ss_marketingcookiesAllowed | 30 days | Remembers if a visitor agreed to placing Marketing cookies on their browser, if your site has a cookie banner and is restricting the placement of cookies |
These cookies are necessary for the website to function and cannot usually be switched off through our website.
Analytics and performance cookies
These cookies help us understand how visitors interact with our website, including how the website is used and how it performs. They provide quantitative measures of website visitors so that we are able to count visits and traffic sources to help us improve the website and users’ experience.
The analytics and performance cookies used on Xlinks’ website may include:
| Cookie Name | Duration | Purpose |
|---|---|---|
| ss_cvr | Two years | Identifies unique visitors and tracks a visitor’s sessions on a site |
| ss_cvt | 30 minutes | Identifies unique visitors and tracks a visitor’s sessions on a site |
We will only use these cookies where you have given consent via our cookie banner.
Advertising Cookies
These cookies are used by advertising companies to serve ads that are relevant to your interests
We will only use these cookies where you have given consent via our cookie banner.
Cookie banner and settings
You can manage your cookie preferences through the cookie banner or cookie settings tool on our website, where available. You can also 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.
For more information about the cookies used by Squarespace, please see Squarespace’s guidance on the cookies it uses here: The cookies Squarespace uses – Squarespace Help Center.
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 prior to that further processing and we will explain the legal basis which allows us to do so and update our privacy policy accordingly.
Disclosures of Your Personal Data
We may share your personal data with the following third parties for the purposes set out in this Privacy Policy:
Website hosting, IT support and system administration services
Data management providers
Email service providers and communications providers
Third party agents and contractors for the purposes of the provision of services (for example, professional advisers, legal advisors, and investor and other screening and profile services), third-party consultation, communications and corporate affairs consultants assisting us in receiving, managing and responding to enquiries and other consultants supporting the planning, consultation and development of our projects
Our insurers and auditors
Members of the project supply chain
Our group companies
Our joint venture partners
Providers of social media platforms
Government or regulatory authorities including planning authorities and/or law enforcement officials (including planning authorities, Ofgem, the Health & Safety Executive) if required for the purposes above, if mandated by law or if required for the legal protection of our own legitimate interests in compliance with applicable laws
In the event that we sell any business assets, purchasers or prospective purchasers of all or part of our assets or our business, and their professional advisers, in connection with the purchase
We will also share your personal data where we have your consent or are otherwise legally permitted to do so.
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.
International Transfers
We may share your personal data within the Xlinks Group. This may involve transferring your data outside the UK, including to Morocco and the EU. Many of our external third parties are based outside the UK so their processing of your personal data may involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we will take appropriate technical and organisational measures to ensure a degree of protection is afforded to it and that your personal data is safeguarded in accordance with applicable data protection laws. Depending on the circumstances, this may include transferring personal data to countries that are the subject of UK adequacy regulations, implementing approved transfer mechanisms such as the International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission’s Standard Contractual Clauses, or relying on another lawful transfer mechanism permitted under applicable data protection law. Where required, we will assess whether the personal data will continue to receive a level of protection that is not materially lower than that provided under UK law and implement any additional safeguards considered necessary.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the steps we take to protect your personal data in these cases.
Data Security
We have put in place appropriate 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.
Data Retention
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.
Where you provide feedback, consultation responses, representations, objections, enquiries or other correspondence relating to the projects, we may retain this information for the duration of the consultation, planning, development and operational phases of the project, and for a reasonable period afterwards where necessary to comply with legal or regulatory requirements, respond to enquiries or complaints, maintain an accurate record of the consultation process, or establish, exercise or defend legal claims.
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.
In some circumstances you can ask us to delete your data: see 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.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
| Your right of access | You have the right to ask us for copies of your personal information. |
| Your right to rectification | You have the right to ask us to correct personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. |
| Your right to erasure | You have the right to ask us to erase your personal information in certain circumstances, provided that the personal data is no longer necessary for the purposes for which it was collected or we are required to retain it. |
| Your right to restriction of processing | You have the right to ask us to restrict the processing of your personal information in certain circumstances. |
| Your right to object to processing | You have the right to object to the processing of your personal information in certain circumstances. |
| Your right to data portability | You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. |
| Decisions based on automated decision-making | You have the right to make representations or contest, or seek human intervention in respect of, any automated processing which produces a legal or similarly significant effect on you. |
Please contact us at privacy@xlinks.co if you wish to make a request. Please note that these rights are not absolute and exemptions apply in certain circumstances. When responding to access requests, we will carry out reasonable and proportionate searches for the personal data covered by the request.
Complaints
In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the UK Information Commissioner’s Office (or any successor organisation). You can report your concerns by telephoning their helpline on 0303 123 1113 or through their website here: Make a complaint about how an organisation has used your personal information | ICO.
However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can contact us about your complaint by emailing us at privacy@xlinks.co or write to us at Kingfisher House, Woodbrook Crescent, Billericay, CM12 0EQ, United Kingdom. We will acknowledge your complaint within 30 calendar days of receipt. We will respond to your complaint without undue delay and aim to resolve all issues promptly.
Procedural Matters
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of your other data protection rights). However, we may charge a reasonable fee if your request is manifestly unfounded or manifestly excessive. Alternatively, we could refuse to comply with your request in these circumstances. We will inform you if we believe this to be the case and explain the reasons why.
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 enable us to manage our response more efficiently.
Time limit to respond: We aim to respond to all data subject requests without undue delay and in most cases within one calendar month of receiving the request. Where we reasonably require further information from you to clarify your request or to verify your identity, the time period for responding will be paused until we receive that information. 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.