Privacy Policy

This Privacy Policy describes how Harlington Sourcing Ltd (“we”, “us”, “our”) collects, uses, and protects your personal information when you use our website (harlingtonsourcing.co.uk and related domains).

“Personal information” means any information that identifies or can be used to identify an individual.

We are committed to handling your personal information responsibly and transparently, in line with UK GDPR, GDPR (where applicable), and industry best practice.

1. Information We Collect

We collect both voluntarily provided information and automatically collected information.

Voluntarily provided information

Information you give us directly, such as when you:

• Complete a contact, callback or investor brief form on our website
• Contact us via email or phone

This may include:

• Name
• Email address
• Phone number
• Any message or brief you send us (including investment criteria and preferences)

Form submissions are stored in our systems (including Cloudflare services such as KV storage and our email systems) so we can handle your enquiry or investor brief.

Automatically collected information

Log data

Our hosting and security providers may automatically record limited technical data such as:

• IP address
• Browser type/version and operating system
• Date/time of access
• Requested URLs and referrer
• Error details (if errors occur)

This information is used to operate, secure, and troubleshoot the website and is not used to build marketing profiles.

Cookies

Our website currently uses only strictly necessary cookies (if any) required for security and basic functionality. We do not use analytics, advertising, or tracking cookies such as Google Analytics or advertising pixels. For more detail, see our Cookie Policy.

2. How We Use Personal Information

We use your information to:

• Provide and operate our website
• Respond to enquiries and callback requests
• Handle investor brief submissions
• Maintain internal records and administration
• Protect the security and integrity of our systems

We only process personal information where we have a lawful basis, such as:

• Legitimate interests (e.g. responding to enquiries, maintaining security)
• Performance of a contract or taking steps at your request before entering a contract
• Compliance with legal obligations

We do not sell or rent your personal data, and we do not use it to build advertising profiles or run behavioural advertising.

3. Security

We use commercially reasonable measures to prevent unauthorised access, misuse, loss, or alteration of your data.

No method of electronic transmission or storage is fully secure. You are responsible for maintaining password security and limiting access to your devices.

4. How Long We Keep Information

We retain personal information only as long as needed for the purpose for which it was collected, including:

• Responding to enquiries and callback requests
• Handling investor briefs and related opportunities
• Legal and regulatory obligations
• Record-keeping and security

Form data stored in systems such as Cloudflare KV and our email systems is reviewed periodically and deleted or anonymised when no longer required for these purposes.

5. International Transfers

Your data may be stored or processed outside the UK or EU, including where our hosting providers or service partners operate. We ensure that transfers are protected through:

• Standard Contractual Clauses (SCCs)
• Equivalent safeguards under UK GDPR

6. Your Rights

Under UK GDPR/GDPR, you have the right to:

• Access your personal information
• Request correction of inaccurate data
• Request deletion
• Restrict processing
• Object to processing
• Withdraw consent (where processing is based on consent)
• Request data portability

To exercise your rights, contact us: hello@harlingtonsourcing.co.uk

We will respond within the legally required timeframe.

7. Data Breaches

If a data breach occurs affecting your personal information, we will notify you and relevant authorities where legally required.

8. Business Transfers

If Harlington Sourcing Ltd is acquired or merges with another company, your personal information may be transferred as part of the assets. The new owner must continue to honour this Privacy Policy.

9. External Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their policies.

10. Cookies (Summary)

Our website currently uses only strictly necessary cookies (if any) to:

• Enable essential website and security functions

We do not currently use analytics, advertising, or other non-essential cookies, and we therefore do not show a cookie consent banner.

If we introduce non-essential cookies in the future, we will update this policy and our on-site controls to request consent where required. For full details, see our Cookie Policy.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will always be available on this page with a revised “Last updated” date.

12. Contact

If you have questions about this Privacy Policy or how we handle personal information, contact us:

hello@harlingtonsourcing.co.uk

Harlington Sourcing Ltd