Privacy Policy

Issued: 2 June 2026

Introduction

This privacy policy sets out how MCS uses and protects your personal data. The privacy policy contains the following sections:

1. Important information and who we are
2. Types of personal data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Contact details
11. Complaints
12. Changes to the privacy policy and your duty to inform us of changes
13. Third party links

1. Important information and who we are

This privacy policy gives you information about how MCS collects and uses your personal data through your use of this website, including any data you may provide when you use our site.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller. Maxwell Commercial Solutions Limited is the controller and responsible for your personal data (collectively referred to as "MCS", "Company", "we", "us" or "our" in this privacy policy). Maxwell Commercial Solutions Limited is registered in England and Wales under company number 17246830 and has its registered office at 20 Wenlock Road, London N1 7GU.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the information set out in the Contact details section below.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy below for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data is collected from analytics providers such as Google based outside the UK; and search information providers based inside or outside the UK.
  • Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. How we use your personal data

Legal basis. The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data. The principal purposes for which we use the categories of personal data described above, together with the legal bases on which we rely, are:

• To register you as a new customer — using Identity and Contact Data, on the basis of performance of a contract with you. We will retain this data for any period imposed upon us by English law or by any party that regulates us.
• To process and deliver your order, manage payments, fees and charges and collect and recover money owed to us — using Identity, Contact, Financial, Transaction and Marketing and Communications Data, on the basis of performance of a contract with you and our legitimate interests (to recover debts due to us). We will retain this data until our contract with you has come to an end or until we have received payment in full of money owed to us, whichever is the later.
• To manage our relationship with you, including notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey — using Identity, Contact, Profile and Marketing and Communications Data, on the basis of performance of a contract with you, our legal obligations and our legitimate interests (to keep our records updated and to study how customers use our services).
• To administer and protect our business and this website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data — using Identity, Contact and Technical Data, on the basis of our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and our legal obligations.
• To send you relevant marketing communications and make personalised suggestions and recommendations about goods or services that may be of interest to you based on your Profile Data — using Identity, Contact, Technical, Usage, Profile and Marketing and Communications Data, on the basis of our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) having obtained your prior consent to receiving direct marketing communications where required.

Direct marketing

Following the registration process on our website you will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view on which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at david@maxwellservices.co.uk.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to contract issues, appointment confirmations, updates to our Terms and Conditions or checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookies Policy below.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in section 4 above:

• Internal third parties within our group;
• External third parties such as our professional advisers, service providers, regulators and authorities;
• Specific third parties listed in connection with the purposes for which we use your personal data;
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for? Details of retention periods for different aspects of your personal data are set out in section 4 above.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the Contact details below.

No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO:

• Email: david@maxwellservices.co.uk
• Postal address: Maxwell Commercial Solutions Limited, 20 Wenlock Road, London N1 7GU
• Phone: +44 (0) 7405 752291

11. Complaints

You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can make your complaint to David Middleburgh using the contact details in paragraph 10 above.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was issued on 2 June 2026. Historic versions will be retained by us and can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

13. Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.