Privacy notice

Sovereign Global Trading Ltd (“Sovereign”, “we”, “us” or “our”) is the controller of the personal data described in this notice. This means that we decide why and how that personal data is used.

We are a company registered in England and Wales under company number 17168382.

Our registered office is:

We may collect the following personal data.

Enquiry details

When you contact us through our website, we may collect:

• your name;
• your company or organisation;
• your work email address;
• your telephone number, where you choose to provide it;
• the type of enquiry; and
• the information included in your message.

Correspondence

We may collect information contained in later emails, telephone calls, meetings or other communications relating to your enquiry.

Technical information

Our website hosting and security infrastructure may generate limited technical information, such as:

• your IP address;
• browser or device type;
• the page requested;
• the date and time of the request; and
• security or diagnostic information relating to the request.

We collect enquiry information directly from you.

You do not need to provide special category personal data, such as information about your health, ethnicity, religion, political opinions, sexual orientation, trade union membership, genetic information or biometric data. Please do not include this type of information, or criminal offence information, in the contact form unless it is genuinely necessary.

The contractual lawful basis does not apply automatically to every business enquiry. Where you contact us as an employee, director, agent or representative of another organisation, we will normally rely on our legitimate interests in handling the enquiry.

Where we rely on legitimate interests, we consider whether the processing is necessary and proportionate and balance our interests against your interests, rights and freedoms.

The required contact-form fields are needed so that we can understand and respond to your enquiry. If you do not provide the required information, we may be unable to assess or respond to it.

Providing a telephone number is optional.

We do not currently use contact-form submissions to add people to marketing mailing lists or to send unrelated promotional communications.

We do not sell personal data.

We do not carry out solely automated decision-making or profiling using website enquiries where the decision would produce legal or similarly significant effects.

Access to personal data is limited to people who need it for the purposes described in this notice.

We may share personal data with:

• service providers supporting our website, hosting, email delivery, communications, IT, cybersecurity and business administration;
• professional advisers, including lawyers, accountants, auditors and insurers, where reasonably necessary;
• courts, regulators, law-enforcement bodies and public authorities where disclosure is required or permitted by law; and
• a buyer, investor, successor or professional adviser involved in a genuine sale, investment, reorganisation or transfer of all or part of our business or assets.

Service providers processing personal data on our instructions are required to protect it and use it only for the agreed purposes.

We will not ordinarily share the substance of your enquiry with a prospective commercial counterparty without telling you first, unless disclosure is required or permitted by law.

Some of our service providers may process personal data outside the United Kingdom.

Where personal data is transferred to a country that is not covered by applicable UK adequacy regulations, we use an appropriate safeguard where required under UK data protection law.

This may include an approved contractual safeguard or another legally recognised transfer mechanism.

You may contact us for further information about the safeguards relevant to your personal data.

We keep personal data only for as long as it is reasonably needed for the purposes described in this notice.

Our normal retention periods are:

• enquiries that do not result in a business relationship are normally deleted or anonymised within 12 months after the last meaningful contact;
• where an enquiry results in a contract or ongoing business relationship, relevant records may be retained for the duration of that relationship and for up to six years afterwards where needed for legal, tax, accounting, compliance or claims purposes; and
• routine technical and security logs are normally retained for no more than 30 days, unless a security incident, investigation, legal requirement or technical issue requires longer retention.

When deciding how long to retain personal data, we consider its nature and sensitivity, the purposes for which it is used, applicable legal requirements and the possible risks associated with retaining it.

Personal data may remain temporarily in restricted backups until those backups are overwritten through the ordinary backup cycle.

We do not currently use analytics cookies, advertising cookies, tracking pixels or similar tracking technologies on this website.

Our website hosting and security infrastructure may process limited technical information in server and security logs. This information is used to deliver, secure and troubleshoot the website and is not used by us to track visitors across different websites.

If we introduce analytics, advertising or other non-essential cookies or similar technologies in the future, we will update this notice and, where required, ask for consent before using them.

We use proportionate technical and organisational measures designed to protect personal data against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure.

These measures may include:

• access controls;
• data minimisation;
• secure transmission;
• appropriate account-security measures;
• service-provider due diligence;
• confidentiality obligations; and
• security and incident-management procedures.

No website, email service or internet transmission can guarantee absolute security.

Depending on the circumstances and the lawful basis on which we use your personal data, you may have the right to:

• request access to your personal data;
• ask us to correct inaccurate or incomplete personal data;
• ask us to erase your personal data;
• ask us to restrict how your personal data is used;
• object to certain uses of your personal data;
• receive certain personal data in a portable format; and
• withdraw consent where we rely on consent, without affecting processing that took place before consent was withdrawn.

Not every right applies in every circumstance. Certain rights are subject to conditions, legal limitations and exemptions.

There is normally no fee for exercising your rights.

We may ask for information needed to confirm your identity. We will normally respond within one month, although the law may allow additional time for particularly complex requests.

Please contact us first so that we have an opportunity to consider and address your concern.

You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: Make a complaint

To ask a question about this notice or exercise a data protection right, use our contact form and state that your message is a “data protection request”.

You may also write to:

We review this notice periodically and update it when our processing activities change.

Where appropriate, we will take reasonable steps to bring material changes to your attention.

The date at the top of this notice shows when it was last updated.