Privacy policy

Identity and contact details of the data controller

The data controller in accordance with the UK GDPR and other relevant data protection is:

Centology Group Ltd
Unit 2 Queen Street
Emsworth PO10 7BT
United Kingdom
0345 646 1055

Contact details of the Data Protection Manager

Louise Jackson
Centology Group Ltd
Unit 2 Queen Street
Emsworth PO10 7BT
United Kingdom
0345 646 1055

General information on data processing

a) Scope of processing personal data

In general, we only process the personal data of our users to the extent that it is necessary to provide a functioning website with our content and services. The data we process is directly provided by the data subjects themselves.

The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law (what is the lawful basis). Personal data processed relates directly to contacting the client to deal with their enquiry.

For these purposes we will share data to the following organisations:

Third-Party	Purpose for sharing
Options Margetts Fund Management	We share data to facilitate completion of application form data

b) Legal basis for data processing

The lawful basis for processing is consent based. Personal data processed relates directly to contacting the client to deal with their enquiry.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (1) (b) GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities, where this processing is necessary in order to enter into a contract.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (1) (c) GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (1) (d) GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) GDPR will serve as the legal basis for the processing of data.

No personal data captured is transferred to any third countries or international organisations. If the transfer of data outside of the UK was to occur, Centology will ensure that appropriate measures are in place to facilitate this transfer. We will ensure that the country either has an adequacy decision or implements appropriate safeguards to ensure the transfer is compliant with data protection law.

The categories of personal data captured are as follows:

Full name
Email address
Phone number

There is no statutory or contractual obligation to provide these details.

c) Data removal and storage duration

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if required by any statutory or regulatory obligations under the UK GDPR or other relevant legislation. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.

Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:

Right of access (Art. 15 GDPR)

You may request the data controller to confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

Purposes of processing
Categories of personal data being processed.
Recipients or categories of recipients to whom the personal data have been or will be disclosed.
Planned storage period or the criteria for determining this period.
The existence of the rights of rectification, erasure or restriction or opposition.
The existence of the right to lodge a complaint with a supervisory authority.
If applicable, origin of the data (if collected from a third party).
If applicable, existence of automated decision-making including profiling with meaningful information about the logic involved, the scope and the effects to be expected.
If applicable, transfer of personal data to a third country or international organization.
Right to rectification (Art. 16 GDPR)

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

Right to the restriction of processing (Art. 18 GDPR)

You may request the restriction of the processing of your personal data under the following conditions:

If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
If you have objected to the processing pursuant and it is not yet certain whether the legitimate interests of the data controller override your interests.

Right to erasure (“Right to be forgotten”) (Art. 17 GDPR)

If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
You withdraw your consent on which the processing is based pursuant to and where there is no other legal basis for processing the data.
You object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) GDPR.
Your personal data has been processed unlawfully.
The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

The right to deletion does not exist if the processing is necessary.

to exercise the right to freedom of speech and information.
to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
for reasons of public interest in the field of public health.
for archival purposes of public interest, scientific or historical research purposes or for statistical purposes.
to enforce, exercise or defend legal claims.

Right to data portability

You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data.

Right to object

For reasons that arise from your situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (1) (e) or 6 (1) (1) (f) GDPR; this also applies to profiling based on these provisions.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you consider that the processing of personal data concerning you infringes the GDPR. The ICO shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.

The ICO can be contacted via their main helpline (0303 123 1113), via live chat on their website or via an online form from their website. Their web address is listed below:

Information Commissioner’s Office (ICO)

Right to withdraw consent

Where consent has been relied on as a lawful basis for processing, the individual has the right to withdraw their consent at any time. They can do so by contact the Data protection Manager.

The right to complain internally

Under the Data Use and Access Act 2025, there is the new right to complain internally. This means that you should refer to us before contacting the ICO to address any issues with the handling of your data, such as storage of data or any other personal data related concerns. Following this, if you have any further complaints, we will refer you to the ICO. You can contact Louise Jackson the DPM at:

Louise Jackson
Centology Group Ltd
Unit 2 Queen Street
Emsworth PO10 7BT
United Kingdom
0345 646 1055

_____________________.

If you wish to exercise any of the above rights, please contact the Data Protection Manager.

Use of cookies

Description and scope of data processing

When you visit our website, we use technical tools for various functions, in particular cookies, which can be stored on your device. When you visit our website for the first time and at any time later, you have the choice of whether you generally permit the setting of cookies or which individual additional functions you would like to select. You can make changes in your browser settings or via our consent manager. Cookies are text files or information in a database that are stored on your hard drive and assigned to the browser you are using so that certain information can be passed to the entity that sets the cookie.

Consent is no longer required where cookies are used:

to collect information for statistical purposes about how the service is used with a view to making improvements to the service, or
to collect information for statistical purposes about how a website by means of which the service is provided is used with a view to making improvements to the website,
to enable the way the website appears or functions when displayed on, or accessed by, the terminal equipment
to adapt to the preferences of the subscriber or user, or
to otherwise enable an enhancement of the appearance or functionality of the website when displayed on, or accessed by, the terminal equipment’

The cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics report.

We use technically necessary cookies, which are required for the technical structure of the website and the website analytics. Without these cookies, our website cannot be displayed (completely correctly) or the support functions are not possible.

The following data is stored and transmitted in the technical necessary cookies:

Language settings
Functionality of the website

b) Purpose of data processing

The purpose of using technically necessary cookies is to ensure the functionality of our website and the website analytics. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.

We need technical necessary cookies for the following purposes:

Applying language settings
Functionality of the website

c) Legal basis for data processing

The Privacy and Electronic Communications Regulations (PECR) state that the storage of strictly necessary cookies does not require the consent of the data subject as these are required for the website to function. However, other cookies like analytical cookies require your consent for Centology to use these. Where we use cookies that are not necessary you will have the choice to manage your preferences at any time on your cookie banner to activate/deactivate any specific cookies.

You have the right to request deletion of your personal data. We will comply with this upon receipt of your written request, subject to the restrictions of our legal or statutory obligations and legitimate interests.

Contact form
Description and scope of data processing

A Contact form is available on our website, which can be used for electronic contact. We use an external form generator called Cognito which is used on the basis of establishing contact with the client. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored.

The following data will also be stored:

Email address
Last name
First name
Telephone / mobile phone number
IP address of the user’s device
Date and time of contact

b) Purpose of data processing

The processing of the personal data from the input mask as well as if you contact us by mail serves us exclusively for the purpose of establishing contact.

The other personal data processed during the sending process serve to prevent misuse of the Contact form and to ensure the security of our information technology systems.

c) Legal basis for data processing

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (1) (f) GDPR. Our legitimate interest is to provide you with the best possible response to the request you send to us via the contact form. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) GDPR.

d) Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the Contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

e) Objection and removal

If the user contacts us via the input mask in the contact form or via e-mail, the user can object to the storage of his or her personal data at any time.

In this case, all personal data stored while establishing contact will be deleted.

Hosting

The website is hosted on servers of a service provider commissioned by us.

Our service provider is Design Booth

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

Browser type and version
Used operating system
Referrer URL
Hostname of the accessing computer
Time and date of the server request
IP address of the user’s device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded.

The server of the website is geographically located in the United Kingdom.