Privacy Policy for 3Sixty Assets Ltd.

Last Updated: June 4, 2025

1. Introduction

Welcome to 3Sixty Assets Ltd. (“we,” “us,” or “our”). We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website [Insert Your Website URL Here], use our services, or otherwise interact with us.

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is 3Sixty Assets Ltd., located at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Privacy Manager at: Email: privacy@360-assets.co.uk Address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

2. Information We Collect

We may collect and process the following types of personal data about you:

  • Personal Information You Provide to Us:

    • Identity Data: Including your first name, last name, job title, and company name.
    • Contact Data: Including your email address, telephone number, and business address.
    • Communications Data: Including information you provide when you contact us through our website contact forms, email, phone, or otherwise, including the content of your queries and our responses.
    • Subscription Data: If you subscribe to our newsletters, blog posts, or other marketing communications, we will collect your name and email address.
    • Client Data: If you engage our services, we may collect additional information necessary to provide those services and manage our contractual relationship.

  • Information We Collect Automatically When You Use Our Website:

    • Technical Data: Including your Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
    • Usage Data: Including information about how you use our website, such as the pages you visit, the time and date of your visit, the time spent on each page, referring site details, and other site navigation data. This information is typically collected through cookies and similar tracking technologies (please see Section 10 on “Cookies and Tracking Technologies” below).

  • Information We May Receive from Third Parties:

    • We may occasionally receive personal data about you from third-party sources, such as publicly available registers (e.g., Companies House), business directories, professional networking sites, or due diligence providers, as part of our service provision or business development activities.

3. How We Use Your Information

We use the information we collect for various purposes, including:

  • To provide, operate, and maintain our website and services.
  • To respond to your inquiries, requests, and provide customer support.
  • To manage our relationship with you, including fulfilling any contractual obligations if you are a client.
  • To send you newsletters, blog updates, marketing communications, and other information about our services that may be of interest to you, where you have consented to receive such information or where we have a legitimate interest to do so (and you have not opted out).
  • To improve our website, services, marketing, and client relationships by analysing website usage and feedback.
  • To comply with our legal and regulatory obligations.
  • For internal record keeping, administrative, and business purposes.
  • To ensure the security of our website and IT systems and to prevent fraud.

4. Legal Basis for Processing Your Information

We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Consent: Where you have given us clear consent to process your personal data for a specific purpose (e.g., for sending you direct marketing emails, or for using non-essential cookies).
  • Contract: Where processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (e.g., if you engage our services).
  • Legal Obligation: Where processing is necessary for compliance with a legal or regulatory obligation to which we are subject.
  • Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests. Our legitimate interests include responding to your business inquiries, administering and improving our website and services, conducting direct B2B marketing to business contacts for services we believe would be of interest, and ensuring our operations are conducted in an efficient and secure manner.

5. How We Share Your Information

We do not sell your personal data to third parties. We may share your personal data with the following categories of third parties for the purposes set out in this policy:

  • Service Providers: Third-party vendors and other service providers that perform services on our behalf, such as IT hosting, website analytics providers (e.g., Google Analytics), CRM system providers, email marketing services, and cloud storage providers. These providers will only have access to your personal data to the extent necessary to perform their functions and are contractually obligated to protect your data.
  • Professional Advisors: Our lawyers, accountants, auditors, and insurers, on a need-to-know basis, where necessary in the course of the professional services that they provide to us.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii.c) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the website or the public, or (iv) protect against legal liability.
  • Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. We will take steps to ensure the privacy of your personal information is protected in such an event.
  • With Your Explicit Consent: We may share your information with other third parties when we have your explicit consent to do so.

6. Data Security

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. These measures include, but are not limited to, data encryption where appropriate, access controls, and secure server environments.

While we strive to use commercially acceptable means to protect your personal data, we acknowledge that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

7. Data Retention

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.

8. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of the United Kingdom or the European Economic Area (EEA) where the data protection laws may differ.

If we do transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • The country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data by the UK Government or European Commission.
  • We use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (such as the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

9. Your Data Protection Rights

Under UK data protection law, you have certain rights regarding your personal data. These include the right to:

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data (‘right to be forgotten’).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party).
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party (data portability).
  • Withdraw consent at any time where we are relying on consent to process your personal data.

To exercise any of these rights, please contact us at privacy@360-assets.co.uk. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

10. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to distinguish you from other users of our website, to provide certain functionalities, and to help us analyse how our website is used.

Cookies are small text files that are placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

We use the following types of cookies:

  • Strictly Necessary Cookies: These are required for the operation of our website.
  • Analytical/Performance Cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.
  • Functionality Cookies: These are used to recognise you when you return to our website and enable us to personalise our content for you.
  • Marketing/Targeting Cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and the advertising displayed on it more relevant to your interests.

You can manage your cookie preferences at any time through our website’s cookie consent banner or by adjusting your browser settings. Please note that disabling certain cookies may affect the functionality of our website. For more detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy [Insert Link to Cookie Policy if separate, otherwise remove this sentence or integrate full cookie details here].

11. Links to Other Websites

Our website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. Children’s Privacy

Our website and services are not intended for individuals under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. How to Contact Us

If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us:

By email: privacy@360-assets.co.uk By post: 3Sixty Assets Ltd. Attn: Data Privacy Manager 71-75 Shelton Street Covent Garden London, United Kingdom WC2H 9JQ

15. Right to Complain

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.