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Privacy Policy V2 2026:

Cheltenham Capital Management Limited

 

Last updated: 29 June 2026

 

Cheltenham Capital Management Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use and protect personal information when you visit our website, contact us, submit an enquiry, subscribe to our newsletter, or otherwise deal with us.

 

1. Who we are

 

Cheltenham Capital Management Limited is a UK-based business providing auction, liquidation, surplus asset, valuation, resale, stock management and related commercial services.

 

Company name: Cheltenham Capital Management Limited

Company number: 14883041

Registered office: Franciscan House, 51 Princes Street, 3rd/4th Floor, Suffolk, Ipswich, England, IP1 1UR

Website: cheltenhamcapital.co.uk

Trading/contact address: 16 King St, London WC2E 8JF

Email: accounts@cheltenhamcapital.co.uk

Phone: 01473 937000

 

For the purposes of UK data protection law, Cheltenham Capital Management Limited is the “controller” of the personal data we collect and use.

 

2. Personal data we collect

 

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

 

Information you provide to us

 

This may include:

 

your name;

company name;

job title;

email address;

telephone number;

postal, registered or business address;

details of your enquiry;

information submitted through our contact forms, consignment forms or newsletter forms;

information about assets, stock, inventory, equipment, liquidation, resale, auction, valuation, insolvency, debt recovery, enforcement or other commercial opportunities;

photographs, videos, documents, spreadsheets, manifests, invoices, asset lists or other files you choose to send us;

correspondence between you and us, including emails, calls, messages and meeting notes.

Information collected automatically through our website

 

This may include:

 

IP address;

browser type and version;

device information;

operating system;

pages visited;

time and date of visit;

referral source;

cookie and analytics data, where applicable.

Information from third parties or public sources

 

We may also receive or collect information from:

 

company websites;

Companies House;

LinkedIn or other business directories;

auction houses;

resale partners;

logistics providers;

professional advisers;

suppliers, vendors, buyers, introducers or commercial partners;

publicly available commercial sources relevant to our services.

3. How we use your personal data

 

We may use your personal data to:

 

respond to enquiries submitted through our website;

communicate with potential clients, suppliers, vendors, buyers, partners and introducers;

assess assets, stock, inventory, equipment or commercial opportunities;

arrange valuations, auctions, sales, purchases, inspections, collections, transport, storage, marketing or resale services;

prepare proposals, contracts, consignment terms, purchase offers, invoices and other commercial documents;

manage client, supplier, vendor and buyer relationships;

maintain internal business records;

carry out accounting, tax, audit and compliance obligations;

conduct reasonable due diligence, fraud prevention and risk checks;

improve our website, services, systems and customer experience;

send relevant business communications, updates or marketing where permitted by law;

manage newsletter subscriptions;

protect our legal rights, recover debts, resolve disputes and enforce agreements.

4. Lawful basis for processing

 

We only use your personal data where we have a lawful basis to do so. Depending on the circumstances, we may rely on the following lawful bases.

 

Purpose Personal data used Lawful basis

Responding to website enquiries Name, company name, email, phone number, message details Legitimate interests / steps before entering into a contract

Assessing assets, stock or commercial opportunities Contact details, company details, asset information, photographs, documents, correspondence Legitimate interests / contract

Providing services or managing a commercial relationship Contact details, company details, transaction details, correspondence, invoices, payment records Contract / legitimate interests

Arranging auctions, resale, logistics, collections or valuations Contact details, asset details, location details, transaction information Contract / legitimate interests

Accounting, tax and business records Contact details, invoices, payment records, transaction records Legal obligation / legitimate interests

Fraud prevention, compliance and due diligence Contact details, company information, transaction details, public records Legal obligation / legitimate interests

Business development and B2B marketing Name, company name, job title, business email, phone number, sector, previous dealings Legitimate interests / consent where required

Newsletter subscriptions Name and email address Consent / legitimate interests, depending on how the subscription was obtained

Website analytics and improvement IP address, browser data, device data, website usage data Consent where required / legitimate interests for essential or limited analytics

Legal claims and dispute management Relevant correspondence, transaction records, contracts, invoices and supporting documents Legitimate interests / legal obligation

 

The ICO states that privacy information should explain who you are, why you use personal data, your lawful basis, who you share data with, retention information and individual rights.

 

5. Legitimate interests

 

Where we rely on legitimate interests, our interests may include:

 

running and growing our business;

responding to business enquiries;

managing commercial relationships;

assessing potential asset, stock, auction, liquidation or resale opportunities;

maintaining appropriate business records;

protecting our business from fraud, legal risk or non-payment;

marketing our services to relevant business contacts;

improving our website and services.

 

We will not rely on legitimate interests where your rights and freedoms override our interests.

 

6. Marketing communications

 

We may contact business contacts about services, opportunities or updates that we believe may be relevant to them.

 

You can opt out of marketing communications at any time by contacting us at:

 

accounts@cheltenhamcapital.co.uk

 

Where required by law, we will only send marketing communications with your consent.

 

We do not sell personal data to third parties.

 

7. Cookies and analytics

 

Our website may use cookies and similar technologies to:

 

make the website work properly;

remember your preferences;

understand how visitors use our website;

improve website performance;

support analytics or marketing activity.

 

Some cookies are essential. Non-essential cookies, such as analytics or advertising cookies, will only be used where permitted by law and, where required, with your consent.

 

You can control cookies through your browser settings and, where available, through our website cookie banner or cookie settings tool.

 

8. Who we share personal data with

 

We may share personal data where necessary with:

 

auction houses and resale partners;

buyers, suppliers, vendors, clients and commercial partners;

logistics, freight, storage and collection providers;

valuers, agents, consultants and contractors;

professional advisers, including accountants, solicitors, insurers and auditors;

IT providers, website hosts, CRM providers, email platforms and cloud software providers;

payment providers, banks and finance providers;

debt recovery, enforcement, insolvency, asset recovery or legal parties where relevant;

HMRC, regulators, courts, law enforcement agencies or other authorities where required.

 

We only share personal data where there is a genuine business, legal or operational reason to do so.

 

9. International transfers

 

Some of our service providers, systems, partners or commercial contacts may be based outside the UK.

 

Where personal data is transferred outside the UK, we will take appropriate steps to protect it in accordance with applicable data protection law. This may include using countries recognised as providing adequate protection or using appropriate contractual safeguards.

 

10. How long we keep personal data

 

We keep personal data only for as long as necessary for the purposes for which it was collected.

 

Typical retention periods are:

 

Type of data Typical retention period

Website enquiries that do not progress Up to 24 months

Enquiries that lead to a commercial relationship Up to 6 years after the relationship or transaction ends

Client, supplier, vendor and buyer records Up to 6 years, or longer where required for legal, tax or accounting reasons

Contracts, invoices and transaction documents Usually 6 years after the relevant financial year or transaction

Marketing contacts Until you opt out, unsubscribe, or we decide the contact is no longer relevant

Newsletter subscription data Until you unsubscribe or withdraw consent

Website analytics data In line with the retention period set by the analytics provider or our cookie settings

Legal dispute or claim records As long as necessary to establish, exercise or defend legal claims

 

We may keep data for longer where required by law or where necessary for legal claims, regulatory matters, fraud prevention or dispute resolution.

 

11. How we protect your data

 

We use reasonable technical and organisational measures to protect personal data from unauthorised access, loss, misuse, alteration or disclosure.

 

These measures may include:

 

access controls;

secure systems and passwords;

staff procedures;

supplier checks;

data minimisation;

secure storage;

appropriate confidentiality arrangements.

 

No website, email system or electronic communication method is completely secure, so we cannot guarantee absolute security.

 

12. Your rights

 

Under UK data protection law, you may have the right to:

 

request access to your personal data;

request correction of inaccurate or incomplete personal data;

request deletion of your personal data;

object to processing based on legitimate interests;

object to direct marketing at any time;

request restriction of processing;

request transfer of your data, where applicable;

withdraw consent where processing is based on consent;

complain to the Information Commissioner’s Office.

 

The ICO confirms that individuals have rights including access, rectification, erasure, restriction, objection and data portability, although some rights only apply in certain circumstances.

 

To exercise your rights, contact us at:

 

accounts@cheltenhamcapital.co.uk

 

You also have the right to complain to the UK Information Commissioner’s Office if you are unhappy with how we handle your personal data.

 

13. Third-party links

 

Our website may contain links to third-party websites, platforms or services. We are not responsible for the privacy practices, content or security of those third-party websites. You should read their privacy policies before providing them with personal data.

 

14. Changes to this Privacy Policy

 

We may update this Privacy Policy from time to time. Any updated version will be posted on this page with a new “Last updated” date.

 

15. Contact us

 

For questions about this Privacy Policy or how we handle personal data, please contact:

 

Cheltenham Capital Management Limited

Franciscan House, 51 Princes Street, 3rd/4th Floor, Suffolk, Ipswich, England, IP1 1UR

 

Trading/contact address:

16 King St, London WC2E 8JF

 

Email: accounts@cheltenhamcapital.co.uk

Phone: 01473 937000

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