LCBSG Limited and all of its subsidiaries and affiliates comprising of  Leonard Curtis (UK) Limited, LC Debt Solutions Limited, LC Risk Management Limited, Leonard Curtis Legal Limited, Leonard Curtis Offshore Limited, Leonard Curtis C.I. Limited, Leonard Curtis Jersey Limited, Leonard Curtis Funding Limited, Reach Commercial Finance Limited, Newsource Commercial Finance Limited, Leonard Curtis Property & Construction Advisory Limited and VirtualNonExecs Limited, are committed to complying with all applicable data privacy laws including, but not limited to, the EU General Data Protection Regulation 2016/679 (GDPR) and the Data Protection Act 2018 (DPA) (collectively Data Protection Laws). For the purposes of this Privacy policy (Policy), all companies will be collectively referred to as LCBSG.

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What is Personal Data?

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Personal data is defined as “any information relating to an identified or identifiable natural person (Data Subject); and identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity or that natural person”.

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Responsibilities

LCBSG is the data controller of the personal data we process and therefore is responsible for ensuring our systems, processes, suppliers and staff comply with Data Protection Laws in relation to the information we handle.

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All LCBSG staff must abide by this Policy when handling personal data and must take part in any required data protection training. Any breach will be taken seriously and may result in disciplinary action. LCBSG has a Privacy Manager who oversees compliance with Data Protection Laws and this Policy and provides guidance and advice to the firm and its staff as required.  The Privacy Manager can be contacted at the following email address: privacy@leonardcurtis.co.uk

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In addition, specifically in relation to Leonard Curtis Legal Limited (LC Legal), LC Legal’s Compliance Officer for Legal Practice (COLP) also oversees compliance with LC Legal’s professional responsibilities and the reporting of any failures to comply with legislative requirements, including Data Protection Laws.

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Data we collect

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LCBSG collects the following categories of personal data for (i) marketing and business development purposes, (ii) in order to deliver its professional services and (iii) in relation to formal appointments as office-holders pursuant to the Insolvency Act 1986 (Office-holder) and/or as fixed charge receivers (Receiver), to discharge their functions as such.

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1. Contact details – We may collect information about data subjects such as name and contact details, email, phone number, etc. in order to communicate and facilitate the provision of our services with our clients or potential clients (and in relation to appointments as Office-holder and/or Receiver, the stakeholders of the entity, individual or property over which they have  been appointed). This may include contact details of individuals who work for or on behalf of the clients or such stakeholders.
2. Services details – Personal data may be provided to us by clients and/or stakeholders to the extent required to perform our services. LCBSG may also acquire personal data from a third party at the direction of our client as required to perform some of our services.
3. Marketing information – LCBSG may collect information to respond to inquiries regarding our products and services or to provide you with information, reports, or updates.
4. Website visitor information – when you visit our website, we may collect information about your visit such as your IP address and the pages you visited and when you use our services we may collect information on how you use those services. Please see our Website Use and Cookies Policy for additional information.

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Clients and other third parties who provide personal information to LCBSG must do so in compliance with all applicable Data Protection Laws.

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Processing of personal data

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We collect personal data to offer and administer our services and products.

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The data you provide to us will be processed in accordance with the purposes specified in this notice, namely:

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• To provide the products or perform the services requested by clients and individuals pursuant to a letter of engagement, statement of work, or similar,  or alternatively in discharging the functions of an Office-holder and/or Receiver (where the processing is necessary for our legitimate business interests in conducting and managing our business).
• To provide the products or perform the services requested by clients and individuals using our website or web applications where the processing is necessary for our legitimate business interests in conducting, managing and developing our business.
• For complying with obligations provided by laws, current regulations and legislation where processing is based on a legal obligation.
• For legitimate business purposes to advise you through email, phone call, or post, in the framework of our ordinary commercial relationship, about other products or services similar to the products or services we have provided to you and that we think will be of interest to you where the processing is necessary for our legitimate business interests.
• For marketing purposes. Your details are stored in LCBSG’s client and contacts database. You will receive communications including updates, newsletters and event invitations, which we think are relevant to your interests. Your details will not be given to third parties unless for instance, we run a joint seminar and you book onto it. In all communications, you will be provided with a link to unsubscribe and you are able to unsubscribe at any time. Additionally, you may send a request to unsubscribe to privacy@leonardcurtis.co.uk. When we send you email communications, we use a technology which enables us to track who opens particular articles or emails. This helps us to understand which issues are of most interest and helps us improve our service to you by ensuring you continue to receive useful information. It also helps us comply with data protection law, to ensure that the information we hold about you is correct.
• For operating and improving LCBSG’s website and your customer experience. For example, we may collect and analyse data on your use of our website and process it for the purpose of improving our online experience. Please see our Website Use and Cookies Policy for additional information.
• For security purposes. For example, we may use your data to protect LCBSG and its third parties against security breaches and to prevent fraud and violation of Leonard Curtis’ applicable agreements where the processing is necessary for our legitimate business interests.

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Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under Data Protection Laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law. You have the right to object to this processing if you wish.

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How data is processed

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Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorised LCBSG employees and third-party processors to have access to your information. Such employees and third-party processors are appropriately designated and trained to process data only according to the instructions we provide them.

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Storage of personal data

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LCBSG will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information.  For the avoidance of doubt, this includes retaining personal data for a period of time after an engagement and/or an appointment as Office-holder or Receiver has been concluded, so as to ensure that we are able to deal with any queries which may subsequently arise.  

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Disclosure/sharing of personal data

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We only share your personal data with your consent or in accordance with this policy. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this Policy.

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• We share personal data among LCBSG controlled affiliates and subsidiaries who act for the Group for the purposes set out in this Policy.
• LCBSG may share your information with external third parties, such as vendors, consultants and other service providers who are performing certain services on behalf of the Group. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable service contract, and not for any other purpose LCBSG requires these third parties to undertake security measures consistent with the protections specified in this Policy.
• LCBSG may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
• If LCBSG enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.

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Your rights

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As a Data Subject you have the following rights concerning your data processed by LCBSG:

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• You have the right to access personal information that LCBSG holds about you.
• You have the right to ask us to rectify information that LCBSG holds about you if it is inaccurate or not complete.
• You can request that LCBSG erase your personal data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.
• You have the right to ask LCBSG to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.
• Where processing is based on legitimate interests, you have the right to object to LCBSG processing your data. LCBSG will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.
• You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain circumstances

Please contact privacy@leonardcurtis.co.uk to request access, rectification, or erasure, or to restrict processing, to object to processing, to request data portability.

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Providing Information to LCBSG

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If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services to you and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our website(s).

If at any point you believe retained information is incorrect you can request to see this information and even have it corrected and possibly deleted. Providing you with this information is free of charge, but charges may apply for excessive requests.

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Your right to complain

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If you wish to raise a complaint about how your personal data has been handled, you can contact us at privacy@leonardcurtis.co.uk and we will investigate the matter, alternatively you can write to us at Leonard Curtis, Riverside House, Irwell Street, Manchester M3 5EN.

Where relevant and in certain circumstances, you have the right to withdraw consent and object at any time and this means that we cannot process your data provided without your consent.

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More information about your rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk/.

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If you are not satisfied with our response or believe we are not processing your personal data in accordance with Data Protection Laws you can complain to the ICO who can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire SK6 5AF or on 0303 123 1113.

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Identity and contact details of the Data controller and Privacy Manager

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• LCBSG Limited, Leonard Curtis (UK) Limited, LC Debt Solutions Limited, LC Risk Management Limited, Leonard Curtis Legal Limited, Leonard Curtis Offshore Limited, Leonard Curtis C.I. Limited, Leonard Curtis Jersey Limited, Leonard Curtis Funding Limited, Reach Commercial Finance Limited, Newsource Commercial Finance Limited, Leonard Curtis Property & Construction Advisory Limited and VirtualNonExecs Limited is the controller and processor of data for the purposes of the DPA.
• If you have any questions relating to the processing of your Personal Data, please write to our Privacy Manager at Leonard Curtis, Riverside House, Irwell Street, Manchester M3 5EN. Alternatively, they can be contacted by email: privacy@leonardcurtis.co.uk

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Date of last review: 23 February 2026

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