Privacy Policy

1. Introduction

This Privacy Policy explains how Strudwick Capital Ltd ("Strudwick Capital", "we", "our" or "us") collects, uses, stores and protects your personal information when you use our website, submit an enquiry or communicate with us.

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We are committed to protecting your privacy and handling your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

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2. Who We Are

Strudwick Capital Ltd ("Strudwick Capital", "we", "us" or "our") is a business acquisition introducer and transaction-coordination business. We connect business owners considering a sale with suitable acquisition buyers and help coordinate information and communications through the acquisition process. We do not provide legal, tax, accounting, formal valuation or regulated financial advice.

Website: www.strudwickcapital.co.uk
Privacy contact: contact@strudwickcapital.co.uk

Strudwick Capital Ltd is the controller of the personal information described in this notice where we decide why and how that information is used

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3. Personal Information We Collect

The personal information we collect depends on how you interact with Strudwick Capital and the nature and stage of any potential transaction. The categories below are illustrative and may include:

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Identity and contact information: name, business or personal email address where appropriately provided or obtained, telephone number, postal or business address, company name, job title, role, ownership position and preferred communication method.

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Prospect and relationship information: source of contact information, company or professional role, outreach and campaign history, email verification status, correspondence, call and meeting notes, contact history, follow-up information, seller or buyer interest, relationship status, preferences, objections and Do Not Contact status.

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Business and seller information: business name, industry, trading history, locations, geographic coverage, services, ownership, management structure, number and categories of employees, owner involvement, assets, contracts, customers and customer concentration, recurring revenue, revenue mix, growth opportunities, strengths, challenges and other operational information relevant to assessing or preparing a potential transaction.

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Financial information: turnover, EBITDA, profitability, margins, historic and current financial performance, forecasts, revenue composition, working-capital or balance-sheet information, assets and liabilities, financial statements and other financial information relevant to a potential transaction.

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Seller and transaction information: reasons and timeframe for considering a sale, confidentiality requirements, succession considerations, valuation or price expectations, preferred transaction structure, preferred buyer characteristics, disclosure permissions, NDAs, expressions of interest, offers, Heads of Terms, due-diligence information, transaction status, completion information, fees and related records.

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Buyer information: organisation and contact details, acquisition strategy and criteria, sectors and services of interest, geographic preferences, preferred transaction size, funding position and source where appropriate, acquisition experience, investment objectives, transaction-structure preferences, decision-making authority and other information relevant to assessing suitability as an acquisition buyer.

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Communications: emails, correspondence, telephone and meeting notes, questions and responses, follow-up communications, information requests and records of interactions with us.

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Documents and transaction materials: financial statements, management accounts, company and corporate information, contracts, marketing materials, operational information and other documents or information appropriately provided in connection with assessing, preparing or progressing a potential transaction.

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Website, enquiry and technical information: information submitted through website or other forms and, depending on our website configuration, IP address, browser and device information, operating system, pages viewed, referring source, access times, website interactions, logs, cookies and similar technologies.

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Information relating to other individuals: where relevant to a potential transaction, information concerning directors, shareholders, employees, management, professional advisers, customers, suppliers or other individuals connected with a business. We seek to limit this information to what is necessary and proportionate for the relevant stage and purpose.

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Other relevant information: depending on your interaction with us and the nature of a potential transaction, we may process other personal information that is relevant, necessary and proportionate to providing our services, progressing a potential transaction, managing our business relationship or complying with legal obligations.

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We do not seek to collect special-category personal information or criminal-offence information as part of our ordinary activities unless it is genuinely necessary and there is an appropriate lawful basis and, where required, an additional condition for processing

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The categories above are intended to describe the types of personal information we may process and are not necessarily exhaustive. Depending on how you interact with us, the nature and stage of a potential transaction, and our legal or regulatory obligations, we may also collect or process other personal information where it is relevant, necessary and proportionate for the purposes described in this Privacy Notice.

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We do not seek to collect personal information that is unnecessary for these purposes. Where our use of personal information materially changes or we introduce a new purpose for processing, we will update this Privacy Notice and provide further information where required.

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4. How We Use Personal Information And Our Lawful Bases

Purpose

1. Identify relevant business owners, acquisition buyers and professional contacts; maintain prospect/CRM records; conduct proportionate B2B business development

2. Verify business email addresses and maintain accurate contact data

3. Respond to enquiries and arrange initial/discovery discussions

4. Assess seller/buyer fit, onboard clients and provide agreed introduction/coordination services

5. Prepare opportunities, match buyers, manage NDAs/disclosure, coordinate Q&A and transaction communications

6. Maintain security, prevent misuse, manage complaints and establish/defend legal rights

7. Maintain invoices, accounting and tax records and comply with applicable law

8. Optional activities where we specifically ask for consent

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Typical lawful basis

1. Legitimate interests, where those interests are not overridden by the individual's rights and subject to applicable PECR rules

2. Legitimate interests

3. Steps at your request before entering into a contract; legitimate interests where appropriate

4. Contract; steps before entering into a contract; legitimate interests where appropriate

5. Contract and legitimate interests

6. Legitimate interests and/or legal obligation

7. Legal obligation and contract

8. Consent; you may withdraw it at any time for that purpose

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5. Business-to-Business Direct Marketing

We may contact relevant business professionals about business-sale and acquisition opportunities or our related services where we believe the communication is relevant to their professional role and where applicable law permits us to do so. We may use publicly available business contact information for this purpose. UK GDPR applies where that information identifies an individual, even in a business context.

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You can object to direct marketing at any time. If you do, we will stop using your personal information for direct marketing and may retain a minimal suppression record so that we can respect your preference and avoid contacting you again.

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Electronic marketing rules differ for corporate subscribers and sole traders/certain partnerships. We apply the applicable Privacy and Electronic Communications Regulations (PECR) requirements to the relevant communication.

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6. How We Share Information

We do not sell personal information. We may share information where there is a lawful basis and the sharing is necessary and proportionate, including with:

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• prospective acquisition buyers and business owners as part of an agreed transaction process;

• solicitors, accountants, tax advisers and other professional advisers where appropriate;

• service providers supporting CRM, forms, automation, email, email verification, hosting, document storage/data rooms and IT/security;

• regulators, courts, law-enforcement bodies, HMRC or other authorities where required or permitted by law.

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For confidential seller opportunities, we use staged disclosure. An opportunity may initially be presented anonymously. More detailed or identifying information is released in accordance with the agreed confidentiality and seller-approval process, which may include an NDA before disclosure.

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7. Service Providers And International Transfers

We use third-party technology providers to operate our business. These may include Airtable for CRM, Make for automation, Tally for forms, ZeroBounce for email verification, email/hosting providers and secure document-storage or data-room providers. Some providers or their subprocessors may process information outside the United Kingdom.

Where a restricted international transfer occurs, we require an appropriate legal mechanism or safeguard where required by UK data-protection law, such as an adequacy arrangement or approved contractual safeguards

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8. Confidential Transaction Information

Business information can become increasingly sensitive as a potential transaction progresses. We seek to minimise disclosure and use staged access controls. Anonymous opportunity information may be used to establish buyer interest; confidential or identifying information is then released only as appropriate to the agreed process. Detailed due-diligence information should be shared through appropriately controlled channels rather than general marketing systems.

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9. Special-Category And Unnecessary Personal Information

Our ordinary services do not require us to collect large amounts of special-category personal information, such as detailed health, religious, political or biometric information. Please avoid providing such information unless it is genuinely necessary for a specific transaction or legal requirement. Where special-category information is processed, we will identify an appropriate legal basis and additional condition as required.

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10. Retention

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including providing our services, maintaining appropriate transaction and contractual records, respecting marketing objections, resolving disputes and meeting legal, tax and accounting obligations.

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• Prospect and buyer-pool records are reviewed periodically and removed or anonymised when no longer relevant.

• Minimal suppression information may be retained after a marketing objection so that we do not contact the person again.

• Transaction working material is reviewed when a transaction ends and unnecessary duplicate or detailed due-diligence material is removed when no longer justified.

• Company accounting and tax records are retained for the periods required by applicable law; UK company tax records generally need to be kept for at least six years from the end of the relevant company financial year, subject to exceptions.

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11. Security

We use technical and organisational measures designed to protect personal and confidential information against accidental or unlawful loss, alteration, unauthorised access or disclosure. Measures include access controls, account security, multi-factor authentication where available, data minimisation, controlled disclosure and appropriate supplier arrangements.

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12. Your Rights

Depending on the circumstances, you may have rights to:

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• access personal information we hold about you;

• correct inaccurate or incomplete information;

• request deletion of information;

• restrict certain processing;

• object to processing based on legitimate interests;

• object at any time to use of your personal information for direct marketing;

• request data portability where applicable;

• withdraw consent where we rely on consent, without affecting earlier lawful processing.

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These rights are subject to applicable legal conditions and exemptions. To exercise a right, contact contact@strudwickcapital.co.uk.

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13. Complaints

If you have concerns about how we use personal information, please contact us first so that we can try to resolve the issue. You also have the right to complain to the UK Information Commissioner's Office (ICO).

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14. Complaints

Our website may use cookies and similar technologies. Essential cookies may be required for the website to function. Where non-essential cookies or analytics require consent, we will provide appropriate choices. Please see our Cookie Policy for the cookies actually used on the website.

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15. Complaints

We may update this Privacy Notice when our services, systems or legal requirements change. The latest version will be published on our website with its update date.

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16. Complaints

Strudwick Capital Ltd
Website: www.strudwickcapital.co.uk
Privacy enquiries: contact@strudwickcapital.co.uk

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Website Disclaimer
Disclaimer

The information provided on this website is for general information only.

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Nothing on this website constitutes legal, financial, investment, tax, valuation or accounting advice.

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Strudwick Capital Ltd acts as a business acquisition introducer. Our role is to facilitate confidential introductions between business owners and prospective acquisition buyers.

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Any transaction should only proceed after obtaining appropriate independent professional advice from suitably qualified advisers.

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While every effort is made to ensure information on this website is accurate, no warranty is given regarding its completeness or accuracy.