Privacy notice
This notice explains what personal information STRATEGICM LTD (“Strategic M”, “we”) collects, why we use it, and your rights. It covers this website, enquiries you send us, and the people we deal with in our work, including the owners, directors and staff of companies we work with or check.
Who we are
STRATEGICM LTD is the controller of your personal information. We are a private limited company registered in England and Wales, company number 11898133, with our registered office at 128 City Road, London, EC1V 2NX, United Kingdom.
For any question about this notice or your information, email compliance@strategicmltd.com.
What we collect, and where it comes from
- When you contact us: your name, company, email address, country, and anything you choose to tell us, including your phone number if you give it.
- When we do business together: business contact details, contract and correspondence records, invoices and payment details.
- When we check a company before working with it: details of its owners, directors, signatories and senior managers. This can include names in Latin and local scripts, dates of birth, nationality, identity document details where lawfully provided, shareholdings, and the results of sanctions, politically-exposed-person and adverse media checks. We collect this from the company itself, from public registers and official sanctions lists, from news sources, and from screening providers.
- When you visit this website: our hosting provider records technical information such as your IP address and browser type in server logs, to keep the site secure and working. We use no analytics, advertising or tracking tools, and this site sets no cookies.
Why we use it, and our lawful basis
| Purpose | Lawful basis |
|---|---|
| Replying to your enquiry and discussing possible work | Our legitimate interest in responding to people who contact us |
| Preparing, entering into and performing contracts | Performance of a contract, or steps taken at your request before one |
| Screening counterparties against sanctions lists, and preventing bribery, fraud and money laundering | Legal obligation, and our legitimate interest in preventing financial crime |
| Keeping accounting, tax and company records | Legal obligation |
| Occasional business-to-business emails about relevant opportunities | Our legitimate interest in developing our business. You can opt out at any time, and we will stop straight away |
| Establishing, exercising or defending legal claims | Our legitimate interest in protecting our rights |
Screening can sometimes reveal information about alleged or proven criminal offences. We only process this where UK data protection law allows, for example to prevent or detect unlawful acts, and we keep it secure and to the minimum needed.
Who we share it with
- Banks and payment providers, to process and evidence payments.
- Our professional advisers, including lawyers, accountants and insurers.
- The other parties to a deal you are involved in, limited to what they need and under a confidentiality agreement. For example, a buyer's legal team may receive our compliance file on a supplier.
- Service providers who process information for us under contract: Google (email and document storage) and Netlify (website hosting and contact form).
- Regulators, law enforcement and other authorities, where the law requires it.
We do not sell personal information.
International transfers
Our work connects businesses in the UK, Europe, South Asia and the Middle East, so information may be transferred outside the UK. When it is, we rely on UK adequacy regulations, the UK International Data Transfer Agreement or Addendum, or, where these are not available, the exceptions that allow a transfer that is necessary for a contract with you or made in your interest.
How long we keep it
- Enquiries that do not lead to work: up to two years after our last contact.
- Contract, compliance, screening, invoice and payment records: at least six years from the end of the relevant transaction or accounting period, or longer where the law or a contract requires.
- Website server logs: as set by our hosting provider, normally no more than 30 days.
Your rights
You have the right to ask for a copy of your personal information, and to ask us to correct it, erase it, restrict how we use it, or transfer it to you or someone else. You can object to our use of it where we rely on legitimate interests, and you can always object to direct marketing. Some rights are limited where we must keep records by law. To use any of these rights, email compliance@strategicmltd.com. We will reply within one month.
Complaints
If you are unhappy with how we have handled your information, please tell us first so we can put it right. You can also complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.
Changes to this notice
We will update this notice when our practices change, and show the date of the latest version at the top.