Version: 1.1 (Last updated: 27 January 2026)

This statement describes who we are, why we collect your information, and how we will use it.

Contents

• Who We Are
• The Data We Collect About You
• How Your Data Is Collected
• How We Use Your Information and Lawful Basis
• International Transfers
• Your Rights
• Retention and Security
• Complaints
• Cookie Policy

1. Who We Are

• Sargent Electrical Services Limited, Unit 39 Tokenspire Business Park, Hull Road, Beverley, HU17 0TB
• Main office: 01482 881655
• ICO Registration No: Z1612581
• Companies House: 3316790 | VAT No: GB599043404

2. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you:

• Identity Data: first name, last name, username, title, date of birth, address, holiday home or leisure vehicle identification details, and location/GPS data relating to the holiday home or leisure vehicle
• Contact Data: billing address, delivery address, email address, and telephone numbers
• Financial Data: membership status, bank account details, invoices, and transactions
• Technical Data: application software, IP address, login data, time zone, and location
• Usage Data: how you use our services, products purchased, and history of sales or technical support contact
• Aggregated Data: statistical or demographic data which does not directly reveal your identity
• Special Categories of Data: we do not intentionally collect sensitive personal data (such as race, health, or religious beliefs). GPS location data for your leisure vehicle or holiday home is required to provide tracking and recovery services and may be shared with law enforcement or legal bodies if legally required.

3. How Your Data Is Collected

• Directly from you: when you contact us or use our web application
• Third parties: from dealerships acting on your behalf or financial credit agencies
• Public authorities: law enforcement or government organisations (where applicable)

4. How We Use Your Information and Lawful Basis

We process your personal data under the following legal grounds:

• Performance of a contract: to manage your subscriptions, provide the app/website services, fulfill product orders, and operate the Sargent Tracking system (including real-time GPS data to recover your vehicle in the event of theft and provide monitoring services)
• Legal obligation: to comply with law enforcement requests or financial regulations
• Legitimate interests: to run our business, keep records updated, and perform software diagnostics. We also monitor the vehicle's health (such as battery voltage) to ensure the tracking device has power and is ready to work if a theft occurs, balancing these interests against your privacy rights.

If you fail to provide data, we may be unable to perform our contract with you (for example, provide services) and may have to cancel your account.

5. International Transfers

We share your personal data within Sargent Electrical Services Limited (UK-based). Most data remains in the UK or EEA. Where data is transferred outside these areas (for example, via payment processors), we ensure a similar degree of protection by using safeguards approved by the UK Government or the ICO, such as Standard Contractual Clauses (SCCs) or the UK Extension to the EU-US Data Privacy Framework.

6. Your Rights

Under the UK GDPR and the Data Protection Act, you can exercise these rights free of charge:

• Right to access: ask for a copy of the personal information we hold about you (a Subject Access Request). We will conduct reasonable and proportionate searches to fulfill this.
• Right to rectification: ask us to update or correct out-of-date or incorrect information.
• Right to erasure (Right to be Forgotten): we will erase your information unless we must retain it for legal or regulatory reasons (for example, HMRC).
• Right to restrict processing: ask us to pause use of your data, for example if you are contesting its accuracy.
• Right to data portability: request your data in a structured, machine-readable format to move to another service.
• Right to object: object to processing where we rely on legitimate interests.
• Automated decision-making: you can challenge decisions made solely by automated systems. Sargent Electrical Services Limited does not use automated decision-making.

To exercise these rights, contact Kelly McCorkindale at kelly@sargentltd.co.uk.

7. Retention and Security

• Retention: business relationship data is retained for up to six years. Application usage data is stored for a maximum of six months.
• Security: we use firewalls, encryption, and restricted physical access to protect your data. Personnel undergo regular data protection training.

8. Complaints

You can complain directly to us or to the Information Commissioner's Office (ICO) at www.ico.org.uk. We would appreciate the chance to resolve concerns with you directly first.

• EU Representative (Article 27): BizLegal Limited (trading as EU Rep), 27 Cork Road, Middleton Co. Cork, Ireland
• Email: privacy@eurep.ie

9. Cookie Policy

We use cookies to ensure our website and app function securely and efficiently.

• What are cookies? Small text files placed on your device that help us remember your session and provide requested services.
• Our use of cookies: we only use strictly necessary cookies. Because these are essential for the service (for example, logging you in or preventing fraud), UK law does not require us to ask for your consent to set them. We do not use cookies for marketing, analytics, or tracking.

Managing cookies: you can block cookies via your browser settings, but doing so will prevent you from logging in or making payments on our site.