PRIVACY NOTICE-LTD COMPANIES BY SLEEK

BACKGROUND:

We respect and value the privacy of everyone who visits this website and uses our services, and we will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law, namely, The UK General Data Protection Regulation 2021 (UK GDPR) and Data Protection Act 2018 (DPA 2018).

Please read this privacy policy carefully and ensure that you understand it.

1. Definitions of terms

In this policy the following terms shall have the following meanings:

2. About us

Sleek Technology Ltd trading as Ltd Companies by Sleek, Companies House approved formation agent, is wholly owned by Sleek Tech Pte Ltd (SLEEK) of 160 Robinson Road, #14-04, Singapore, company number 068914. SLEEK is committed to making the life of entrepreneurs around the world easier by providing one-stop-shop services of registering, helping to run and grow a business. Sleek Accounting Limited (company number 10262742, registered at 205 Regent Street, 4th Floor, London, W1B 4HB, UK) trading as SLEEK UK is also owned by SLEEK. With them onboard, we are now able to offer accounting services to UK customers. Unless otherwise stated, the data controller for the purpose of this notice is Sleek Technology Ltd.

3. What does this policy cover?

This privacy policy explains main data protection principles we abide by, what personal data is collected, how it is used and stored, what lawful basis we use for processing your personal data, under what circumstances your personal data may be shared with third parties, how long this information is retained for, what are your rights as data subject and how to exercise those rights.

This privacy policy applies only to your use of our site and our services. This site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. Data protection principles

We abide by the main data protection principles set by UK GDPR, which means that your data will be: a) used lawfully, fairly and in a transparent way, b) relevant to the purposes we have told you about and limited only to those purposes, c) accurate and kept up to date, d) kept only as long as necessary for the purposes we have told you about, e) kept securely.

5. What personal data do we collect, how and why do we collect it?

Depending upon your use of our site, we may collect personal data that is considered necessary for relevant purposes, which may include but is not limited to the following:

• Information you provide by completing the online order form. This information includes contact details (name, phone number, email address) of the person completing the order form, director(s)’ and shareholder(s)’ details (name, other names used in the past, nationality, country of residence, date of birth, occupation and home address) and payment data. This information is essential for us to be able to provide our service. We submit this information to Companies House in electronic format.

When you provide us with personal data about someone else, for example additional director(s) or shareholder(s), you must ensure that you are authorised to disclose that data to us and that, without us taking any further steps required by applicable data protection or privacy laws, we may collect, use and disclose such personal data for the purposes described in this policy. You must, therefore, take reasonable steps to ensure that the third party concerned is aware of and consents to the various matters detailed in this policy, including: the fact that their personal data is being collected, the purposes for which that data is being collected, the intended recipients of that data, and the third party’s right to obtain access to the data (including details of how to request access). When requested to do so, you must assist us with any requests by the third party to access or update the personal data you have collected from them and provided in connection with our services.

• Information you provide when completing an online contact form or registering for our free guides and seminars. You can use links on our site to contact us to ask questions, request information and materials, register or sign up for guides or seminars, or provide comments and suggestions. You can also request for one of our representatives to contact you personally to provide additional information about our products or services. To do so, we may request contact information from you, such as your name, email address and telephone number, to help us satisfy your request.
• KYC (Know your customer) information. As a company service provider, we are required by law to complete relevant checks to comply with AML (Anti-Money Laundering) regulations. All our services are subject to successful completion of ID checks, such as ID document verification, proof of address check and in some cases biometric verification as described in our Anti-Money Laundering Policy, Controls & Procedures 2022. Please contact us if you wish to see this document.
• Data that is collected automatically. Most of the data that we collect is provided to us by you; however, some of the data is collected automatically for example information about your visit to our site. This information helps us to make improvements to the site’s content and navigation. It may include your IP address, web browser type and version, operating system, the date, times and frequency with which you access our site and the way you use and interact with its contents. Please also see Part 13 on our use of cookies.
• Facilitating Sleek’s provision of products and services which are used by you and from time to time with newsletter, marketing or promotional materials and other information that may be relevant to you via email and/or phone and/or text message. You may also receive such material if you have opted-in to receiving such content. You will not be sent any unlawful marketing or spam. We will work to protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You can opt-out of such material by clicking the ‘unsubscribe’ button in the next marketing email you receive or alternatively you may contact our data protection officer (see Part 14).
• Communicating with you to assist you with your enquiries.
• Dealing with administrative matters relating to the product and/or services purchased and/or subscribed to by you.
• Conducting market research and customer satisfaction surveys.
• Any other purposes that we notify you of at the time of obtaining consent (collectively known as the “Purposes”).

6. What lawful basis do we use to process your personal data?

Under the UK GDPR, we must have a lawful basis for processing personal data. We use the following lawful basis to process your data:

Contract-as described in Part 5, most of the personal data we collect and process is necessary for us to provide our services (fulfil our contractual obligations) or to take steps to enter into a contract. That includes service-related communication with you (via email, phone, SMS, post, web chat facility or social media).

Consent -Where we have your consent.

Legitimate interest – Where we have a legitimate interest which is not overridden by your rights.

Legal requirement– In some circumstances, we may be legally required to share your personal data, such as if we need to comply with legal obligations, a court order, or the instructions of a government authority.

Please note that if you choose not to provide us with your Personal Data or choose not to consent to our processing of your Personal Data, we may not be able to provide some or all of our Services to you or respond to your other requests; for job applicants, we would not be able to evaluate your suitability against our employment opportunities.

7. What are your rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

• The right to be informed about the collection and use of your personal data. This privacy policy should tell you everything you need to know and you can always contact us for more information.
• The right to access the personal data we hold about you. Part 12 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to data portability, where you can ask us for an electronic copy of your personal data for use with another service or business.
• Rights relating to automated decision-making and profiling.

For more information about exercising your rights as outlined above, please contact us using the details provided in Part 14.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

8. How long will we keep your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. Data Security

We have put in place appropriate security measures to safeguard your personal data, to prevent unauthorised access, use, disclosure, modification, disposal or similar risks to personal data in our possession.

We will ensure that third parties who receive Personal Data from us process such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by us, by incorporating appropriate contractual terms in its written agreements with said third parties.

We are not responsible in any way for the security and/or management of Personal Data shared by you with third party websites accessible via links on our website.

In the event of a breach of security in respect of Customer Data, we shall promptly (but as soon as practical from a security perspective) provide you or any individual acting on behalf of you a notice of such breach, setting out details such as the extent of the breach, the affected Customer Data, and steps taken by us to remedy and limit the consequences of the breach. Notwithstanding the foregoing, where we determine that the Data Protection Law allows us not to provide notification in respect of a breach, we may not inform the Customer of such a breach immediately or at all.

10. Who we might share your information with?

We may share your personal information for following reasons:

• To provide you with services/products you’ve asked for;
• There is a public or legal duty to do so, for example, for fraud prevention;
• To send marketing communication, where you’ve given us your permission;
• Have a legitimate business reason, for example, to confirm your identity or enable another company to provide you with the service (s) you’ve asked for.
• For any other purpose (s) for which we have notified you and have obtained your consent.

We may share your information with:

Our affiliates or government agencies that supply certain services or products-your details would be passed on to the following organisations only if you have requested us to do so by ticking the relevant boxes in our online order form or if you choose the registration package that includes the named service (s). We only share the information that is necessary for these companies to provide the service/product.

• Companies House – the United Kingdom’s registrar of companies (once your company is registered, Companies House will also act as data controller).
• HMRC (Her Majesty’s Revenue and Customs)-VAT registration service (will also be acting as data controller).
• Cleartone Communications Limited – provider of a free business number offer.
• EasySpace LTD – provider of free domain name offer.
• City Company Seals LTD – provider of company seals.
• Yell Limited – provider of free basic listing, free DIY website, website services etc.
• Hold Everything (Cooper Davis Associates Limited)-provider of business address services.
• ANNA (Absolutely No Nonsense Admin Ltd) and Wise (Wise Payments Limited) – business account services.
• SLEEK UK (Sleek Accounting Limited)- provider of accounting and tax consulting services. Please note, when you sign up for an accounting service, SLEEK UK will be acting as a joint data controller.

Third party software/platforms that enable us to operate effectively and efficiently (below listed are the main ones we use) :

• SumSub (Sum and Substance Ltd) – Identity verification software.
• Stripe (Stripe Payments UK, Ltd), GoCardless Ltd, PayPal-enables us to process payments.
• Campaign Monitor Pty Ltd – email marketing software.
• Olark (Habla, Inc)-enables chat facility on our website.
• TextAnywhere -enables us to send bulk SMS.
• The HubSpot-sales CRM platform.
• Lucky Orange LLC – helps us to analyse website users’ behaviour.

11. Will your information be transferred overseas?

To deliver our products and services to you, it is sometimes necessary for us to transfer your data outside of the UK and the European Economic Area (EEA), including countries that may not have the same level of protection for personal information. This will typically occur when we use service providers located outside the UK and EEA or when our employees based overseas (e.g. in Singapore) support UK business. When we do this, we’ll ensure that your data is accorded an appropriate level of protection and that the transfer is in line with applicable legal requirements. For example, our employees are bound by the contractual obligations stated in their employment contract, and we incorporate appropriate contractual terms in agreements with our third-party service providers. We will continue to always take additional steps to make sure that your personal data is treated in line with strict standards set by the UK data protection laws.

12. How can I access my personal data?

If you want to know what personal data we have about you, you can ask us for details and for a copy of it (where any such personal data is held). This is known as a subject access request (SAR). All subject access requests should be made as per the information in Part 14. We will provide this information free of charge but in certain circumstances such as where further copies are requested we may request a payment to cover our administrative costs. We may refuse access requests if it is unjustified or excessive, and where large volumes of information about a data subject is processed, we may request you to be specific with the kind of information sought.

We will endeavour to respond to your subject access request within 30 days of receiving it.

13. Use of cookies

A cookie is a small text file that may be placed on your device when you visit our site. Cookies provide various functionalities which enable us to give you a smooth service experience. Our site uses a number of cookies, which are explained below:

There are two broad categories of cookies:

Session cookies – session cookies remain on your device until you close your browser when they are automatically deleted.

Persistent cookies – persistent cookies remain on your device until deleted manually or automatically.

Cookies we use and why we use them:

Essential cookies – These cookies are essential for the basic operation of our website and cannot be disabled because the website will not function without them. For example, these cookies enable us to provide you with the services that you have requested such as to remember the products which you wish to buy for checkout.

Analytics/Performance cookies – These allow us to recognise and count the number of visitors and to see how visitors move around our site. This helps us to improve the way our site works by enabling us to tailor our site to the way visitors use it. The information we collect from these cookies is aggregated which means that we cannot identify you from it.

Functional cookies – These cookies allow our site to remember the choices you make and to provide you with enhanced and personalised features. Information collected by functional cookies cannot track your browsing activity when you leave our site to browse other sites.

Third party cookies – are those placed by websites and/or parties other than us. These cookies are subject to the respective privacy policies of these third parties.

Your right to refuse cookies and what happens if you refuse them

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website or where relevant our system may become inaccessible or not function properly.

14. Who and how do I contact for any data protection matters?

We have appointed a person to oversee compliance with this privacy policy. To contact us about your personal data and data protection matters, including to make a data subject request, please use the following details:

Email address: [email protected]

Postal Address: 7 Hembrow, Evegate Business Park, Ashford, Kent, TN25 6SX.

Phone number: 01233 226 220; from outside UK +44 1233226220

We are supervised by the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Our ICO registration number is ZB278270. You have the right to contact ICO at any time with any data protection issues. Details of how to contact the ICO can be found on their website www.ico.org.uk.

15. Changes to this policy

This privacy policy was last updated in May 2023.

We may update this privacy policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our site. We recommend that you check this page regularly to keep up to date.