Privacy Policy

1. Data controller

Velvet Solutions Ltd, a company registered in England and Wales (company number TBC), is the data controller for personal data collected through this website and in the course of our brokerage services. Contact us regarding data protection matters at info@velvetsolutions.co.uk.

2. What we collect

We collect personal data in the following circumstances:

• Enquiry and brief forms. Name, email, phone number, company, and the content of your enquiry, sourcing brief or sell submission, submitted through our listing enquiry, sourcing brief, sell-your-plant and contact forms.
• Website analytics. Standard technical data such as pages visited, referring source, device and browser type, and approximate location derived from IP address, collected through privacy-conscious analytics.
• Correspondence. Personal data included in emails, calls or documents exchanged in the course of a brokerage engagement, including NDA counterparties and site contacts.

3. Lawful basis for processing

We process personal data on the following lawful bases under UK GDPR:

• Contract. Where processing is necessary to respond to your enquiry, provide brokerage services, or perform a contract with you.
• Legitimate interests. Where processing is necessary for our legitimate interests in operating and improving our business, marketing our services to prospective clients, and maintaining website security, provided those interests are not overridden by your rights.
• Legal obligation. Where processing is necessary to comply with a legal or regulatory obligation, such as anti-money laundering checks on a transaction.
• Consent. Where we rely on your consent, for example for optional marketing communications, which you may withdraw at any time.

4. Retention

We retain enquiry and transaction-related personal data for as long as necessary to provide our services and to meet legal, accounting and regulatory requirements, typically no longer than seven years after the last point of contact for completed transactions, and up to two years for enquiries that do not proceed. We delete or anonymise personal data when it is no longer needed for these purposes.

5. Third parties

We share personal data with the following categories of third party, only as necessary:

• Netlify, our website hosting and form processing provider, which receives and stores form submissions on our behalf as a data processor.
• Counterparties to a transaction, such as a buyer or seller, inspection firm, or logistics contractor, where necessary to progress an enquiry or engagement you have asked us to pursue, and generally only after an NDA or equivalent confidentiality protection is in place.
• Professional advisers, including legal and accountancy advisers, where necessary for the operation of our business.
• Regulators or authorities, where required by law.

We do not sell personal data to third parties.

6. International transfers

Because we work with buyers, sellers and partners worldwide, personal data may be transferred outside the UK. Where this happens, we take steps to ensure an adequate level of protection, including reliance on adequacy regulations or appropriate contractual safeguards such as the UK's International Data Transfer Agreement or equivalent standard contractual clauses.

7. Your rights

Under UK GDPR, you have the right to:

• Request access to the personal data we hold about you;
• Request correction of inaccurate data;
• Request erasure of your data, subject to our legal and legitimate retention needs;
• Object to or request restriction of certain processing;
• Request data portability where technically feasible; and
• Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, email info@velvetsolutions.co.uk. We will respond within one month.

8. Complaints

If you are unhappy with how we have handled your personal data, we would ask that you contact us first so we can try to resolve it. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk or by calling 0303 123 1113.

9. Contact for data requests

Data protection queries and requests should be sent toinfo@velvetsolutions.co.uk.

This document is a template pending review by Velvet Solutions Ltd's legal advisers.