Privacy Policy

REYBACH Group takes the privacy and security of personal information seriously.
This Privacy Policy explains how we collect, use, disclose, retain and protect
personal information when you visit our website, contact us, submit a business
requirement, approach us regarding a tender or commercial opportunity,
communicate with us as a supplier or prospective supplier, or otherwise
interact with REYBACH Group.

1. Who we are

REYBACH Group is the trading name of
REYBACH Group Limited, a company registered in England and
Wales under company number 17475431.

Registered office:
167–169 Great Portland Street
5th Floor
London
W1W 5PF
United Kingdom

For the purposes of UK data protection law, including the UK General Data
Protection Regulation, the Data Protection Act 2018 and applicable subsequent
legislation, REYBACH Group Limited is the controller of the personal information
described in this Privacy Policy unless otherwise stated.

Privacy enquiries, data protection requests and complaints may be sent to:
enquiries@reybachgroup.com.

2. When this Privacy Policy applies

This Privacy Policy applies when you interact with REYBACH Group through our
website at reybachgroup.com, website
enquiry forms, email, telephone, business correspondence, tender and quotation
processes, supplier onboarding, sourcing activities, meetings, introductions,
procurement platforms or other legitimate business channels.

It may apply to representatives of clients and prospective clients, contracting
authorities, suppliers and prospective suppliers, subcontractors, professional
advisers, business partners, website visitors and other professional contacts.

3. Personal information we collect

Website enquiries

When you submit an enquiry through our website, we may collect information such
as your name, organisation, email address, telephone number, enquiry type,
description of your requirement, required delivery or completion date, delivery
location and any other information you choose to provide.

Where our website allows supporting documents to be uploaded, we may also
receive and process information contained within those files.

Email and direct communications

When you contact REYBACH Group through an email address published on our
website, we may collect your name, email address, telephone number, job title,
organisation and the content and metadata of your communications with us.

Our current business contact channels include:

• General Enquiries:
  enquiries@reybachgroup.com
• Commercial Opportunities and Tenders:
  tenders@reybachgroup.com
• Sourcing:
  sourcing@reybachgroup.com

Clients and prospective clients

Where you approach REYBACH Group about a procurement, sourcing, supply or other
commercial requirement, we may process information concerning your organisation,
relevant representatives, specifications, project requirements, delivery
requirements, tender documents, quotations, correspondence and contractual
information.

Suppliers, subcontractors and prospective suppliers

Where you supply or propose to supply goods or services to REYBACH Group, our
clients or projects coordinated by us, we may process information about your
organisation and relevant representatives.

This may include:

• names and professional contact details;
• job titles and roles;
• company and trading information;
• quotations and pricing;
• product and service information;
• supplier capability information;
• insurance details;
• certifications and accreditations;
• policies and compliance documentation;
• references;
• contractual documentation;
• delivery information;
• payment information where required; and
• other information reasonably necessary to assess or manage the relationship.

Tender and procurement information

In connection with public or private procurement exercises, requests for
quotation, tender submissions and contract opportunities, we may receive or
generate information relating to representatives of contracting authorities,
clients, suppliers, subcontractors, professional advisers and other organisations
involved in the opportunity.

Information obtained from other sources

We may obtain professional or business contact information from sources other
than the individual concerned where appropriate for legitimate business
purposes.

These sources may include:

• your employer or organisation;
• clients, suppliers and subcontractors;
• procurement and tender platforms;
• official registers;
• government or public authority websites;
• company websites;
• professional directories; and
• publicly accessible professional sources.

Website and technical information

When you visit our website, technical information may be generated or collected
as part of operating, securing and maintaining the website.

This may include:

• IP address;
• browser and device information;
• operating system;
• date and time of access;
• referring pages;
• pages requested or visited;
• website interaction data;
• security information; and
• server logs.

Additional information may be collected by analytics, embedded content or
similar technologies where these are enabled in accordance with our Cookie
Policy and applicable consent requirements.

4. Sensitive personal information

REYBACH Group does not ordinarily require special category personal information
through its general website or business enquiry channels.

Please do not send unnecessary information concerning health, racial or ethnic
origin, political opinions, religious or philosophical beliefs, trade union
membership, genetic or biometric information, sex life or sexual orientation.

You should also avoid sending identification documents, payment card details or
other highly sensitive personal information unless requested by us and there is
a legitimate reason and appropriate method for providing it.

5. How and why we use personal information

We process personal information only where we have an appropriate lawful basis
under applicable data protection law.

Responding to enquiries

We use information submitted to us to receive, understand, assess and respond to
enquiries, procurement requirements, requests for quotation, sourcing enquiries,
tender opportunities, supplier introductions and other business communications.

Depending on the circumstances, we may rely on our legitimate interests in
operating our business and communicating with organisations and their
representatives, or on taking steps at your request before entering into a
contract.

Procurement, sourcing and tendering

We may process information to:

• assess procurement and tender opportunities;
• identify and assess suppliers;
• communicate with suppliers and clients;
• obtain, compare and evaluate quotations;
• source goods, materials, equipment and services;
• prepare quotations and tender submissions;
• coordinate supply chains;
• conduct supplier due diligence;
• manage negotiations;
• coordinate delivery and fulfilment; and
• administer commercial opportunities and contracts.

Our lawful bases may include legitimate interests, contractual necessity,
pre-contractual steps and compliance with legal obligations.

Managing commercial relationships

Where a commercial relationship is established, we may process information to
administer contracts, process orders, communicate with representatives,
coordinate delivery, maintain records, issue or process invoices, manage
supplier and client relationships, resolve queries and protect our contractual
and legal rights.

Website operation and security

We may use technical information to operate, secure and maintain our website,
detect malicious or fraudulent activity, prevent misuse, investigate technical
problems and improve website performance.

Legal and regulatory obligations

We may process information where necessary to:

• comply with applicable laws and regulatory requirements;
• maintain financial and accounting records;
• respond to lawful requests from public authorities;
• prevent or investigate fraud;
• establish, exercise or defend legal claims; and
• protect the rights, property or safety of REYBACH Group or others.

Business-to-business communications

We may use professional contact information to maintain legitimate business
relationships and communicate with organisations and business contacts regarding
our services, capabilities or relevant commercial opportunities where permitted
by law.

Where consent is required by law for a particular electronic marketing activity,
we will seek appropriate consent.

You may object to direct marketing at any time.

6. What happens when you contact us

When you voluntarily contact REYBACH Group, we use the information you provide
to understand, administer and respond to your enquiry.

Where your enquiry relates to a possible transaction, procurement requirement,
tender, quotation, sourcing requirement, supply opportunity or other commercial
relationship, we may also use the information to assess and progress that
opportunity.

Submitting an enquiry does not constitute blanket consent for REYBACH Group to
use your personal information for unrelated purposes or unrelated marketing.

7. Website forms and document uploads

Our website may use forms to allow visitors to contact REYBACH Group and submit
business requirements.

Information entered into a form is transmitted through our website
infrastructure and delivered to the appropriate REYBACH Group business channel
for review and response.

Where a form allows supporting documents to be uploaded, information contained
within those documents will also be processed for the purpose for which the
documents were supplied.

Please ensure that you are authorised to provide any personal information
concerning another individual contained within an uploaded document.

We may use technical and security measures to prevent spam, malicious
submissions and misuse of our website.

8. Information about other people

If you provide REYBACH Group with personal information about another person,
such as an employee, colleague, client representative, supplier representative,
subcontractor or referee, you should ensure that you have an appropriate basis
for doing so.

9. Who we share personal information with

REYBACH Group does not sell personal information.

Where reasonably necessary for the purposes described in this Privacy Policy,
information may be shared with:

• website hosting and technology providers;
• email and communications providers;
• IT, cybersecurity and website-support providers;
• professional advisers, including lawyers, accountants and insurers;
• banks and payment service providers;
• suppliers and subcontractors involved in an applicable requirement;
• clients and contracting authorities where appropriate;
• logistics and delivery providers;
• procurement and tender platforms;
• government, regulatory or law-enforcement bodies where required or permitted by law; and
• parties involved in a proposed restructuring, financing, acquisition or sale of the business where appropriate safeguards apply.

Where another organisation processes personal information solely on our behalf,
we require appropriate data-protection arrangements where required by law.

10. Sharing information during procurement and sourcing

REYBACH Group operates in procurement, sourcing and supply coordination.
Information supplied to us may therefore need to be shared with relevant
participants in a commercial requirement.

For example, details of a client requirement may need to be communicated to
prospective suppliers in order to obtain quotations, while relevant supplier
information may need to be included within a tender, quotation, supply-chain
assessment or contract-delivery process.

We seek to limit disclosures to information reasonably necessary for the
relevant purpose.

11. International transfers

Some of our technology, hosting, email, communications or cloud service
providers may process information outside the United Kingdom.

Where personal information is transferred internationally, we will use an
appropriate transfer mechanism recognised under UK data protection law where
required.

Depending on the circumstances, this may include UK adequacy regulations,
recognised contractual safeguards or another lawful transfer mechanism.

12. How long we retain information

We retain personal information only for as long as reasonably necessary for the
purpose for which it was collected and for applicable legal, accounting,
contractual and evidential purposes.

General enquiries: normally retained for no longer than
24 months after the last meaningful interaction where no continuing relationship
develops.

Supplier introductions and unsuccessful commercial opportunities:
normally reviewed for deletion after 24 months unless there is a genuine
continuing business reason to retain them.

Tenders, contracts and commercial relationships:
relevant records may normally be retained for up to six years after completion
or termination where necessary for contractual, legal, tax, accounting or
evidential purposes.

Financial records: retained for the period required by
applicable law.

Website security and technical logs: retained for periods
proportionate to their operational and security purpose.

Where litigation, investigation, a complaint or regulatory matter is ongoing or
reasonably anticipated, relevant information may be retained for longer.

When information is no longer required, it will be deleted, securely destroyed
or anonymised as appropriate.

13. Security

We use reasonable technical and organisational measures designed to protect
personal information against accidental or unlawful destruction, loss,
alteration, unauthorised disclosure or unauthorised access.

No method of internet transmission or electronic storage can be guaranteed to
be completely secure.

You should therefore avoid sending unnecessary highly sensitive information
through general website or email channels.

14. Marketing and professional communications

REYBACH Group primarily operates in a business-to-business environment.

We may communicate with organisations and professional contacts where permitted
under applicable data protection and electronic communications law.

Where personal information is processed for direct marketing, individuals have
the right to object at any time.

15. Cookies and similar technologies

Our website uses or may use cookies and other storage or access technologies.

Some technologies are necessary for the website to operate, remain secure or
remember privacy preferences. Other technologies may be used for analytics,
embedded content, functionality or marketing.

Where consent is required by law, non-essential technologies will not be used
until an appropriate choice has been made.

Further information is available in our
Cookie Policy and through the Cookie Settings
control available on our website.

16. Your data protection rights

Depending on the circumstances and applicable law, you may have the right to:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• request restriction of processing;
• object to certain processing;
• request certain information in a portable format;
• withdraw consent where processing is based on consent; and
• make a complaint regarding our use of your information.

You have the right to object at any time to the use of your personal
information for direct marketing.

Requests may be sent to
enquiries@reybachgroup.com.

We may request information reasonably necessary to verify your identity or
authority before responding.

17. Data protection complaints

If you believe REYBACH Group has not handled your personal information
appropriately, you may make a data protection complaint to us.

Email
enquiries@reybachgroup.com
and identify the communication as a
Data Protection Complaint.

We will acknowledge and investigate complaints in accordance with applicable
data protection law and communicate the outcome of our investigation.

You may also raise concerns with the
Information Commissioner’s Office (ICO), the United Kingdom’s
independent data protection regulator.

18. Automated decision-making

We do not currently use information submitted through the REYBACH Group website
to make solely automated decisions about individuals that produce legal or
similarly significant effects.

19. Children

REYBACH Group provides business-to-business procurement, sourcing and supply
services. Our website is intended for organisations and professional or
commercial users and is not directed towards children.

20. Third-party websites

Our website may contain links to external websites or services operated by third
parties.

Those third parties operate under their own terms and privacy practices.
REYBACH Group is not responsible for their privacy or security practices merely
because we provide a link to them.

21. Changes to this Privacy Policy

We may update this Privacy Policy where our activities, website, technology,
service providers or legal obligations change.

The latest version will be published on this website together with an updated
revision date.

22. Contact us

For privacy enquiries, data protection rights requests or data protection
complaints, contact:

REYBACH Group Limited
167–169 Great Portland Street
5th Floor
London
W1W 5PF
United Kingdom

Email:
enquiries@reybachgroup.com
Company number: 17475431
Registered in: England and Wales