PRIVACY POLICY

1. Introduction

Senator & Co (“Senator & Co”, “we”, “our” or “us”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, who we may share it with and the rights you have over your information.

It applies when you:

• visit senatorandco.co.uk (“our Website”);
• contact or make an enquiry with us;
• request a call or information about our services;
• become or consider becoming a client;
• work with us as a business contact, supplier, associate or professional adviser; or
• otherwise provide personal information to Senator & Co.

We handle personal information in accordance with applicable UK data protection law, including the UK GDPR and Data Protection Act 2018.

2. Information We May Collect

The information we collect depends on how you interact with us and the services you require.

It may include:

Contact Information

• your name;
• email address;
• telephone or mobile number;
• postal address.

Business & Organisation Information

• business or organisation name;
• business address;
• company or charity information;
• your position or role;
• information about your business, charity or organisation;
• details of the services or support you are interested in.

Enquiry & Client Information

When you contact us or become a client, we may collect information about:

• your enquiry;
• your business needs, plans or challenges;
• services you require;
• correspondence and communications with us;
• proposals, projects and services provided;
• invoices, payments and other relevant financial information.

Depending on the services requested, we may need additional information to provide appropriate professional support.

Website & Technical Information

When you use our Website, certain technical information may be collected automatically, including:

• IP address;
• browser and device information;
• pages visited;
• Website activity;
• cookie preferences.

Further information is available in our Cookies Policy.

3. How We Collect Your Information

We may collect personal information:

• directly from you;
• through forms on our Website;
• by email, telephone or other communications;
• during meetings or consultations;
• when providing services to you;
• from your business, charity or organisation;
• from someone who introduces or refers you to us;
• from professional advisers, associates or service providers;
• from publicly available sources such as Companies House, charity registers or business websites; and
• through Website technologies such as cookies, where applicable.

Where we receive personal information from another source, we will handle it in accordance with applicable data protection requirements.

Current ICO guidance requires privacy information to be provided when information is collected directly and, subject to applicable exceptions, within a reasonable period when personal information comes from another source.

4. How We Use Your Information

We only use personal information where we have a proper reason to do so.

We may use your information to:

• respond to enquiries and requests;
• arrange calls, meetings and consultations;
• understand what help or services you need;
• provide and manage our services;
• prepare proposals, quotations and agreements;
• manage our relationship with clients;
• provide accountancy, business, marketing, digital or other agreed support;
• arrange access to appropriate legal or specialist professional expertise;
• process invoices and payments;
• maintain business and financial records;
• communicate important information about our services;
• improve our Website and services;
• protect our business, Website and systems;
• prevent fraud or misuse;
• meet our legal, regulatory and professional obligations; and
• send relevant marketing communications where permitted by law.

We will not use your personal information for purposes that are incompatible with the reason it was originally collected unless permitted by law.

5. Our Lawful Bases

UK data protection law requires us to have a lawful basis for using personal information.

Depending on the circumstances, we may rely on:

Contract

Where using your information is necessary to take steps at your request before entering into a contract or to provide services under an agreement with you.

Legal Obligation

Where we need to use information to comply with a legal, regulatory, tax, accounting or other obligation.

Legitimate Interests

Where using information is reasonably necessary for the legitimate operation, administration, protection and development of Senator & Co or our services, provided those interests are not overridden by your rights and interests.

These interests may include responding to business enquiries, managing client relationships, improving our services, protecting our business and developing appropriate commercial relationships.

Consent

Where we ask for and receive your consent for a particular use of your information.

Where processing is based on consent, you may withdraw that consent at any time.

Different lawful bases may apply to different uses of your information.

6. Sensitive Personal Information

Senator & Co does not normally need sensitive or “special category” personal information simply for you to browse our Website or make a general enquiry.

However, depending on the nature of a professional service or matter, information you provide may occasionally contain sensitive personal information.

Where this happens, we will only use that information where there is an appropriate lawful basis and additional legal condition for doing so.

Please avoid providing unnecessary sensitive information through our general Website enquiry forms.

7. Sharing Your Information

We do not sell your personal information.

Where necessary and appropriate, we may share relevant information with trusted organisations or professionals who help us provide our services.

These may include:

• accountants and accountancy professionals;
• solicitors and legal professionals;
• business and financial advisers;
• specialist consultants;
• Senator & Co associates and approved development partners;
• IT, website, hosting and email providers;
• payment and financial service providers;
• marketing and communications providers;
• professional advisers;
• regulatory, government or law enforcement authorities where legally required.

We only share information that is reasonably necessary for the relevant purpose.

Where third parties process personal information on our behalf, we expect appropriate confidentiality, security and data protection arrangements to be in place.

8. Professional & Third-Party Services

Part of Senator & Co’s role is to bring together the right expertise for our clients.

Some services may therefore be provided with or referred to suitably experienced third-party professionals, specialist consultants, associates or service providers.

Where appropriate, we may need to share relevant information with these parties to understand your requirements, arrange services or provide professional support.

Where a third party provides services directly to you, they may become independently responsible for how they handle your personal information and should provide their own privacy information where required.

9. Marketing Communications

We may occasionally send you information about Senator & Co services, opportunities or other relevant business information where permitted by law.

Where consent is required, we will ask for it.

You can ask us to stop sending marketing communications at any time by using the unsubscribe option provided or contacting us.

You have the right to object to the use of your personal information for direct marketing at any time.

Stopping marketing communications will not prevent us from contacting you about an existing enquiry, client relationship, service or other necessary business matter.

The right to object to direct marketing applies regardless of the lawful basis being relied upon.

10. Cookies & Website Information

Our Website may use cookies and similar technologies to:

• operate properly;
• remember your preferences;
• understand how visitors use the Website;
• improve performance and security; and
• measure communications or marketing where permitted.

Non-essential cookies will only be used where permitted by law and, where required, after you have made your cookie choice.

Please read our Cookies Policy for further information.

11. How Long We Keep Your Information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet relevant legal, accounting, contractual and professional requirements.

How long information is retained may depend on:

• the nature of our relationship with you;
• the services provided;
• legal and regulatory requirements;
• accounting and tax requirements;
• whether there is an ongoing enquiry, claim or dispute; and
• whether the information remains reasonably necessary for legitimate business purposes.

When personal information is no longer required, we will securely delete, anonymise or otherwise dispose of it as appropriate.

The UK GDPR requires organisations to tell people either the relevant retention periods or the criteria used to determine them.

12. Keeping Your Information Secure

We take reasonable and appropriate steps to protect personal information against:

• unauthorised access;
• loss;
• misuse;
• alteration;
• disclosure; and
• accidental destruction.

These measures may include appropriate technical, organisational and administrative safeguards.

Where we use third-party service providers to process information for us, we expect them to provide appropriate protection for that information.

No online system can be guaranteed to be completely secure, but we take the protection of personal information seriously.

13. International Transfers

Some of the technology and professional services used by modern businesses may involve personal information being processed or stored outside the United Kingdom.

Where personal information is transferred internationally, we will take appropriate steps to ensure that the transfer is permitted under applicable UK data protection law and that suitable safeguards are used where required.

Where applicable, you may contact us for further information about the safeguards used for relevant international transfers.

14. Your Data Protection Rights

Depending on the circumstances and the lawful basis being used, UK data protection law may give you rights including the right to:

• access personal information we hold about you;
• correct inaccurate or incomplete information;
• request deletion of your information in certain circumstances;
• restrict how your information is used in certain circumstances;
• object to certain uses of your information;
• receive or transfer certain information in a portable format;
• withdraw consent where processing is based on consent; and
• raise concerns about how your personal information is being handled.

These rights are not absolute and may depend on the circumstances and lawful basis for processing.

If you would like to exercise any of your rights, please contact:

privacy@senatorandco.co.uk

We may need to confirm your identity before dealing with certain requests.

15. Automated Decision-Making

Senator & Co does not currently use solely automated decision-making through this Website to make decisions about individuals that produce legal or similarly significant effects.

If this changes, we will update this Privacy Policy and provide appropriate information as required by law.

16. Children’s Privacy

Senator & Co’s Website and business advisory services are primarily intended for adults, businesses, charities and organisations.

We do not knowingly use the Website to collect personal information directly from children for marketing purposes.

If we become aware that personal information relating to a child has been provided where it is not reasonably necessary, we will take appropriate steps to deal with that information.

17. Your Right to Complain

If you have concerns about how Senator & Co has handled your personal information, please contact us first so that we have an opportunity to investigate and resolve the matter.

Data Protection Enquiries:
privacy@senatorandco.co.uk

You also have the right to make a complaint to the UK’s data protection regulator, the Information Commissioner’s Office (ICO).

18. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in:

• our services;
• how we use personal information;
• technology;
• our Website; or
• legal and regulatory requirements.

The latest version will always be available on our Website.

We will bring significant changes to people’s attention where appropriate.

19. Contact Us

If you have any questions about this Privacy Policy or how Senator & Co handles personal information, please contact us.

Senator & Co
Upper Floors, 18 Leonard St., Perth PH2 8ES

General enquiries: support@senatorandco.co.uk
Data protection enquiries: privacy@senatorandco.co.uk

20. Related Policies

Please also read our:

• Cookies Policy;
• Terms of Use;
• Disclaimer
• Accessibility Statement; and
• Modern Slavery Statement.

Together, these documents explain how Senator & Co operates its Website and handles important legal, privacy and accessibility matters.

Privacy Policy
UK (Scotland) Edition • Version 1.0
Effective Date: 01 September 2025