Privacy policy | Saguni Ltd

1. Who we are

Saguni Ltd (company number 16511146), 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom, is the data controller for the personal data described in this policy. Contact us at contact@saguniltd.com or +44 7418 604187.

Where we process personal data on a client's instructions as part of an engagement, we act as that client's processor and the client is the controller. This policy describes our own processing as controller.

2. Personal data we collect

Enquiries: name, business name, email address, telephone number and the content of your message.
Clients and their staff: contact details, role, correspondence, and the identity and ownership documents we need for verification.
Contractors and suppliers: name, contact details, address, invoice details, bank or payment account details, tax or business registration numbers, and identity documents.
Platform sellers, where we operate a platform for a client: onboarding and verification data, and transaction and payout records held with the payment provider.
Website visitors: our web host records standard server log data such as IP address, browser type and pages requested, for security and reliability.

3. Why we use it, and our lawful basis

To respond to enquiries: legitimate interests in dealing with people who contact us.
To provide our services and make payments: performance of a contract, or steps taken before entering one.
To verify counterparties and prevent fraud and financial crime: legal obligation and legitimate interests.
To keep accounting, tax and company records: legal obligation.
To establish, exercise or defend legal claims: legitimate interests.

We do not use personal data for advertising, and we do not sell it.

4. Cookies and analytics

This website does not set advertising or analytics cookies and does not track visitors across sites. Fonts are loaded from Google Fonts, which receives your IP address in order to serve the font files. Standard server logs are kept by our hosting provider for security purposes.

5. Who we share it with

Payment providers, banks and payment institutions used to make or receive payments.
Our accountants, auditors and professional advisers.
Software providers that host our records, email and documents.
Clients, in respect of the contractors and suppliers engaged on their behalf.
HMRC, Companies House, regulators, or law enforcement where we are legally required to do so.

We do not sell personal data or share it for third-party marketing.

6. International transfers

Our clients and their group companies are based outside the UK, including in the European Union and the United Arab Emirates, and some of our service providers process data outside the UK. Where personal data is transferred outside the UK we rely on UK adequacy regulations or the International Data Transfer Agreement or Addendum, together with appropriate safeguards.

7. How long we keep it

Enquiries that do not become engagements: up to 12 months.
Client, contractor and supplier records, including invoices and payment records: at least 6 years from the end of the relevant financial year, to meet UK accounting and tax requirements.
Verification and anti-fraud records: 5 years from the end of the relationship.

8. Your rights

Under UK data protection law you may ask us to give you access to your personal data, correct it, delete it, restrict or object to how we use it, or provide it in a portable form. Where we rely on legitimate interests, you may object to that processing. To make a request, email contact@saguniltd.com. We will respond within one month. We may ask you to verify your identity first.

Some rights are limited where we must keep records to comply with legal obligations.

9. Security

We use access controls, multi-factor authentication, encrypted storage and reputable service providers to protect personal data, and we limit access to what each person needs to do their job.

10. Complaints

If you are unhappy with how we have handled your personal data, please tell us first at contact@saguniltd.com. You also have the right to complain to the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, or at ico.org.uk.

11. Changes

We may update this policy. The current version is always published on this page with the date it was last updated.