Privacy Policy

Information we collect

We may collect your name and contact details; information contained in enquiries and communications; details about the assets or services in which you are interested; your requirements, preferences, budget or proposed transaction; and documents or attachments you choose to provide.

Where relevant, we may also receive identity documents, proof of funds, banking information, KYC or due-diligence information, details about representatives or beneficial owners, contracts, transaction records, professional correspondence and accounting records.

Please avoid sending identity documents, banking information or other sensitive material until it is genuinely required and an appropriate method of transmission has been agreed.

We do not normally request information about health, religion, ethnicity, political opinions, sexual life or criminal records. Please do not provide this information unless it is directly relevant and specifically requested. Unnecessary information of this nature will be deleted where reasonably possible.

Information received from others

We may receive information from representatives, family offices, brokers, sellers, professional advisers, introducers, public records or other people involved in a proposed engagement or transaction.

Where required, we will provide affected individuals with relevant privacy information within the applicable legal timeframe, unless a legal exception applies.

Website information

When you visit our website, our hosting and security providers may process your IP address, browser and device information, pages and files requested, request times, security and fraud-prevention signals, and technical logs needed to operate and protect the website.

The website does not currently use Google Analytics, advertising trackers or behavioural advertising technology.

Our security infrastructure may place the __cf_bm cookie on your device for bot detection and website security. It normally expires after approximately 30 minutes of inactivity and is used only where necessary to protect and operate the website.

Browser caching and service-worker technology may store website files on your device to improve performance. These files are not used to create a profile of your browsing behaviour.

Contact links and external services

The website does not contain a contact form or file-upload facility. Email, telephone and WhatsApp links open the relevant service selected by you.

Links to WhatsApp and Google Maps take you to external services that operate under their own privacy policies.

How and why we use information

Responding to enquiries. We use contact details and enquiry information to respond, communicate and consider whether we can assist. The lawful basis is taking steps at your request before entering a contract and our legitimate interest in responding to genuine business enquiries.

Providing services. We use relevant information to provide agreed acquisition, advisory or related services, administer engagements and communicate with representatives and counterparties. The lawful basis is taking steps before entering a contract, performing a contract and our legitimate interest in properly managing an engagement.

Identity and due-diligence checks. Where relevant, we may use identity documents, proof of funds and related information to conduct identity, source-of-funds, fraud-prevention, sanctions, KYC or due-diligence checks. The lawful basis is compliance with a legal obligation where one applies and our legitimate interests in preventing fraud, assessing engagements and protecting the business and people involved in a transaction.

Business and legal administration. We may use and retain information to maintain financial, tax, contractual and business records, protect our legal interests, resolve disputes and establish, exercise or defend legal claims. The lawful basis is compliance with legal obligations and our legitimate interests in administering and protecting the business.

Website operation and security. We use limited technical information to deliver, maintain and secure the website, prevent misuse and investigate security incidents. The lawful basis is our legitimate interest in operating a secure and reliable website.

Where consent is the appropriate lawful basis, we will request it clearly. You may withdraw consent at any time by contacting us. Withdrawal does not affect processing that occurred before consent was withdrawn.

Information you must provide

You are not generally required to provide personal information merely to visit the website or make an initial enquiry.

However, certain information may be necessary to evaluate or proceed with an engagement, perform an agreement, conduct appropriate due diligence or comply with legal requirements. If required information is not provided, we may be unable to proceed with an enquiry, engagement or transaction.

Marketing and automated decisions

We do not send promotional emails or promotional WhatsApp messages. We do not sell personal information or share it for behavioural advertising.

We do not use personal information to make decisions about clients solely through automated processing or artificial intelligence where those decisions would have legal or similarly significant effects.

How long we keep information

Enquiries that do not result in an engagement are normally kept for up to 24 months after the last meaningful communication. Client, contractual and transaction records are normally kept for up to six years after the relationship or transaction ends.

Financial, tax, compliance or legally required records are kept for the applicable legal retention period. Information relevant to a dispute or legal claim may be kept until the matter and any relevant limitation period have ended. Technical and security information is kept according to the relevant provider’s operational and security requirements, and backups remain until overwritten through the normal backup cycle.

Information may be kept longer where a legal obligation, regulatory requirement, dispute, investigation or other documented justification applies. When it is no longer needed, we will take reasonable steps to delete or anonymise it.

Sharing information

Where necessary, we may share relevant information with brokers, sellers, agents, introducers and transaction counterparties; solicitors, accountants, tax advisers and other professional advisers; identity, due-diligence, fraud-prevention or compliance providers; website hosting, security, email, communications, cloud-storage and IT providers; payment, banking or accounting providers; insurers, auditors or business-support providers; courts, regulators, tax authorities or law-enforcement bodies; and a prospective purchaser or successor if the business or its assets are transferred.

For data-protection purposes, Trophy Assets is a trading name operated by Eli Neumann, who is the controller responsible for the personal information described in this policy.

We share only information reasonably necessary for the relevant purpose. Recipients may act as service providers processing information on our behalf or as independent controllers responsible for their own use of the information.

International processing

Some service providers, professional advisers, counterparties or other recipients may process personal information outside the United Kingdom.

Where UK data-protection law requires a safeguard, we will rely on an applicable UK adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses or another legally permitted transfer mechanism.

You may contact us for further information about the safeguard relevant to your information and, where available, how to obtain a copy.

Security

We take reasonable technical and organisational measures to protect personal information against unauthorised access, misuse, alteration, loss or disclosure.

Access is normally limited to the operator of Trophy Assets and other people who require the information for a legitimate enquiry, engagement, transaction or legal purpose.

However, no internet transmission, email system, messaging service or electronic-storage method can be guaranteed completely secure. Please use an appropriately secure method before sending highly sensitive documents.

Your rights

Depending on the applicable law, lawful basis and circumstances, you may have the right to request access to your personal information; ask us to correct inaccurate or incomplete information; request deletion; ask us to restrict processing; request a portable copy of certain information; withdraw consent where processing relies on consent; and complain to a data-protection authority.

Your right to object. You may object to processing based on legitimate interests. If you object, we will stop that processing unless we have compelling legitimate grounds to continue or the information is required for legal claims.

To exercise a right, contact enquiries@privatetrophyassets.com. We may request information reasonably necessary to confirm your identity and protect information from unauthorised disclosure.

If you are in the United Kingdom, you may complain to the Information Commissioner’s Office through ico.org.uk. We would appreciate the opportunity to address your concern first.

Individuals in other countries may have additional rights under local law. We will respect those rights where the relevant law applies to our processing.

Children

Our services are intended for people aged 18 and over. We do not knowingly provide services directly to children.

Where an enquiry concerns someone under 18, we will communicate with their parent, guardian or authorised representative. If you believe a child has provided information to us directly, please contact us so we can review and, where appropriate, delete it.

Changes to this policy

We may update this policy when our services, providers, legal obligations or information-handling practices change. The effective date at the top will show when it was most recently updated. Material changes will be communicated where required by law.

Contact

For privacy enquiries, complaints or requests concerning your information, contact: