Privacy Policy

1. Who We Are

CRICHEL CAPITAL LTD ("the Company", "we", "us", or "our") is a company registered in England and Wales. Our registered address is Dean Farm, Witchampton, Wimborne, England, BH21 5BU. We operate as a holding company (SIC 64209) and management consultancy (SIC 70229).

For the purposes of UK data protection law, CRICHEL CAPITAL LTD is the data controller in respect of personal data collected through our website at crichelcapital.site and through our business activities.

You may contact us regarding data protection matters at:

• Email: info@crichelcapital.site
• Telephone: +44 7828 732718
• Post: Dean Farm, Witchampton, Wimborne, England, BH21 5BU

2. Data We Collect

We may collect and process the following categories of personal data:

2.1 Identity Data

This includes your first name, last name, title, and job title where provided. We collect this information when you contact us, submit an enquiry form, or enter into a business relationship with us.

2.2 Contact Data

This includes your email address, telephone number, and postal address. This data is used to communicate with you in connection with your enquiry or engagement.

2.3 Business Data

Where you represent a company or organisation, we may collect the name of that organisation, your role within it, and information about the nature of the services you are seeking. This is necessary to assess and fulfil your enquiry.

2.4 Communications Data

This includes the content of any messages, emails, or correspondence you send to us, and records of our responses. We retain these to maintain an accurate record of our interactions.

2.5 Technical Data

When you visit our website, we may automatically collect certain technical information, including your IP address, browser type and version, operating system, referring URL, pages visited, and time and date of access. This data is collected through standard web server logs and, where applicable, cookies.

2.6 Usage Data

We may collect information about how you interact with our website, including which pages you visit, how long you spend on each page, and which links you click. This helps us understand how our website is used and to improve the user experience.

3. How We Collect Data

We collect personal data through the following means:

• Direct interactions: When you submit an enquiry form on our website, send us an email, or contact us by telephone, you provide us with personal data directly.
• Automated technologies: As you navigate our website, we may automatically collect technical and usage data through cookies, server logs, and similar technologies. Please see Section 9 for further details on cookies.
• Third parties: In the course of our business activities, we may receive personal data from third parties, such as companies that refer clients to us or professional advisers acting on behalf of clients.
• Publicly available sources: We may collect information about prospective clients or business contacts from publicly available sources, such as company registers, professional directories, or publicly accessible websites.

4. Lawful Basis for Processing

Under UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following lawful bases:

• Legitimate interests (Article 6(1)(f)): We process personal data where it is necessary for our legitimate business interests, provided those interests are not overridden by your rights and interests. This includes responding to enquiries, maintaining business records, and improving our services.
• Performance of a contract (Article 6(1)(b)): Where you engage our services, we process personal data as necessary to fulfil our contractual obligations to you.
• Compliance with a legal obligation (Article 6(1)(c)): We may process personal data where required to do so by applicable law, including tax, accounting, and anti-money laundering obligations.
• Consent (Article 6(1)(a)): Where we rely on your consent to process personal data, we will make this clear at the point of collection. You may withdraw consent at any time by contacting us.

5. How We Use Your Data

We use the personal data we collect for the following purposes:

• To respond to your enquiries and provide the information or services you have requested.
• To assess your suitability as a client and to scope potential engagements.
• To deliver management consultancy or holding company services where a formal engagement has been agreed.
• To manage our ongoing business relationship with you, including invoicing, correspondence, and reporting.
• To comply with our legal and regulatory obligations, including record-keeping requirements under company law, tax law, and anti-money laundering regulations.
• To maintain the security and integrity of our systems and website.
• To analyse and improve the performance and usability of our website.
• To send you information about our services where you have consented to receive such communications, or where we have a legitimate interest in doing so.

We will not use your personal data for automated decision-making or profiling in ways that produce legal or similarly significant effects on you without your explicit consent.

6. Sharing Your Data

CRICHEL CAPITAL LTD does not sell, rent, or trade your personal data to third parties. We may share your data in the following limited circumstances:

6.1 Service Providers

We may share personal data with carefully selected third-party service providers who assist us in operating our business, including IT service providers, hosting companies, and professional advisers (such as accountants and solicitors). These parties are required to process your data only on our instructions and in accordance with applicable data protection law.

6.2 Legal and Regulatory Requirements

We may disclose personal data to regulatory authorities, law enforcement agencies, or courts where required to do so by law, or where we reasonably believe that disclosure is necessary to protect the rights, property, or safety of CRICHEL CAPITAL LTD, our clients, or others.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, personal data held by us may be transferred to the relevant third party as part of that transaction. We will notify you of any such transfer and any changes to this Privacy Policy that may result.

6.4 With Your Consent

We may share your data with other parties where you have given your explicit consent for us to do so.

7. Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Enquiry and contact data: Retained for up to 2 years from the date of last contact, unless a formal engagement is entered into.
• Client engagement data: Retained for 7 years from the conclusion of the engagement, in accordance with our legal and regulatory obligations.
• Financial and accounting records: Retained for a minimum of 6 years as required by HMRC and the Companies Act 2006.
• Website technical data: Retained for up to 12 months in standard server logs.

Where personal data is no longer required, we will securely delete or anonymise it in accordance with our internal data management procedures.

8. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

• Right of access: You have the right to request a copy of the personal data we hold about you (a Subject Access Request).
• Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to request that we delete your personal data in certain circumstances, such as where the data is no longer necessary for the purpose for which it was collected.
• Right to restrict processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data.
• Right to data portability: Where processing is based on your consent or on a contract, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: You have the right to object to the processing of your personal data where we rely on legitimate interests as our lawful basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Rights related to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces legal or similarly significant effects on you.

To exercise any of these rights, please contact us at info@crichelcapital.site. We will respond to your request within one month of receipt. We may need to verify your identity before processing your request.

9. Cookies & Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your browsing experience and to collect usage data. Cookies are small text files placed on your device by your web browser when you visit a website.

9.1 Types of Cookies We Use

• Strictly necessary cookies: These are essential for the website to function correctly. They do not collect personal data and cannot be disabled.
• Analytical/performance cookies: These allow us to recognise and count the number of visitors to our website and to understand how visitors navigate the site. This helps us improve the way our website works.
• Functionality cookies: These are used to recognise you when you return to our website and to remember your preferences.

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website. For more information on managing cookies, visit allaboutcookies.org.

10. Data Security

CRICHEL CAPITAL LTD takes the security of your personal data seriously. We have implemented appropriate technical and organisational measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Secure storage of data with access controls limited to authorised personnel.
• Use of encrypted communications where applicable.
• Regular review of our data security practices and procedures.
• Staff awareness of data protection obligations.

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you provide data to us at your own risk. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the ICO as required by law.

11. International Transfers

CRICHEL CAPITAL LTD is based in England and primarily processes personal data within the United Kingdom. Where it is necessary to transfer personal data to a country outside the UK, we will ensure that appropriate safeguards are in place, such as standard contractual clauses approved by the ICO, or that the transfer is to a country that has received an adequacy decision from the UK Government.

We will not transfer your personal data to countries outside the UK without first ensuring that adequate protections are in place in accordance with applicable data protection law.

12. Children's Privacy

Our website and services are directed at business professionals and are not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If you believe that we have inadvertently collected personal data from a child, please contact us immediately at info@crichelcapital.site and we will take steps to delete such data promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or the services we offer. When we make material changes, we will update the "Last Updated" date at the top of this document. We encourage you to review this policy periodically to stay informed about how we protect your personal data.

Your continued use of our website or services following the posting of changes to this policy will constitute your acknowledgement of those changes.

14. Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, please contact us:

• Email: info@crichelcapital.site
• Telephone: +44 7828 732718
• Post: CRICHEL CAPITAL LTD, Dean Farm, Witchampton, Wimborne, England, BH21 5BU

We will endeavour to respond to all enquiries within 10 business days. If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.