1. INTRODUCTION

1.1 Who We Are

This Privacy Policy explains how Unusual Consulting Limited (trading as "Succeed") collects, uses, shares, and protects personal information obtained through our website and services.

Data Controller:

Unusual Consulting Limited

Company Number: 16719193

Registered Office: 124 City Road, London, Greater London, United Kingdom, EC1V 2NX

Email: hello@unusualgroup.com

1.2 Our Commitment

We are committed to protecting your privacy and complying with:

  • General Data Protection Regulation (GDPR)
  • Data Protection Act 2018
  • Privacy and Electronic Communications Regulations 2003

1.3 Scope

This policy applies to personal data collected through:

  • Our website at [www.succeed.com]
  • Email, telephone, and other communications
  • Business development activities and advisory services
  • Active listings and transaction processes

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Contact and Enquiry Information:

  • Name, job title, company name
  • Email address, telephone number
  • Business address and location
  • Areas of interest or specific enquiries
  • Information about your business or investment criteria

Client Engagement Information:

  • Financial data and business performance metrics
  • Ownership structure and shareholder information
  • Strategic objectives and growth plans
  • Due diligence documentation
  • Transaction history and preferences

Active Listings Information (Sellers):

  • Business financial performance
  • Operational details and structure
  • Asking price and deal terms
  • Reasons for sale
  • Management team information

Active Listings Information (Buyers/Investors):

  • Investment criteria and budget
  • Sector preferences and experience
  • Transaction structure preferences
  • Funding sources and financial capacity

2.2 Information We Collect Automatically

Technical Information:

  • IP address and location data
  • Browser type and version
  • Device type and operating system
  • Pages visited and time spent on pages
  • Referring website or search terms
  • Date and time of access

Cookies and Tracking:

  • Session cookies for website functionality
  • Analytics cookies to understand user behaviour
  • Marketing cookies (with your consent)
  • See our Cookie Policy for full details

2.3 Information from Third Parties

We may receive information about you from:

  • Professional advisers (lawyers, accountants) in transaction contexts
  • Business partners and referral sources
  • Publicly available sources (Companies House, industry databases, LinkedIn, press)
  • Credit reference agencies (for financial due diligence)

3. HOW WE USE YOUR INFORMATION

3.1 Lawful Bases for Processing

We process personal data under the following legal bases:

Consent:

  • Marketing communications (where you have opted in)
  • Non-essential cookies and tracking
  • Sharing your information with transaction counterparties

Legitimate Interests:

  • Business development and relationship management
  • Improving our website and services
  • Fraud prevention and security
  • Internal administration and operations

Contractual Necessity:

  • Providing advisory services you have engaged us for
  • Processing transactions and managing client relationships

Legal Obligation:

  • Compliance with financial regulations
  • Tax reporting and accounting requirements
  • Responding to legal requests

3.2 Purposes of Processing

Service Delivery:

  • Responding to enquiries and providing information
  • Assessing suitability for advisory services
  • Managing client engagements and transactions
  • Coordinating with professional advisers

Business Development:

  • Identifying potential clients and opportunities
  • Maintaining relationships with market participants
  • Networking and industry engagement

Marketing:

  • Sending newsletters and updates about our services
  • Inviting you to events or webinars
  • Sharing relevant market insights and case studies
  • Only where you have consented or we have legitimate interest

Active Listings:

  • Matching buyers with suitable acquisition opportunities
  • Facilitating confidential introductions
  • Managing non-disclosure agreements and information access

Website Improvement:

  • Understanding how users interact with our website
  • Identifying technical issues and improving performance
  • Developing new features and content

Legal and Regulatory:

  • Complying with anti-money laundering obligations
  • Maintaining records for regulatory purposes
  • Defending legal claims or responding to investigations

4. HOW WE SHARE YOUR INFORMATION

4.1 Service Providers

We share data with trusted service providers who process data on our behalf:

Technology Providers:

  • Website hosting and cloud storage
  • Email and communication platforms
  • Customer relationship management (CRM) systems
  • Analytics and performance monitoring tools
  • AI and machine learning platforms

Professional Advisers:

  • Legal counsel for complex transactions
  • Accountants for financial analysis
  • Tax advisers for structuring guidance
  • Industry specialists and consultants

Administrative Support:

  • Payment processors and banking services
  • Document management systems
  • Virtual data room providers
  • Background checking services

All service providers are bound by confidentiality obligations and process data only as instructed.

4.2 Transaction Parties

In the context of M&A transactions:

With Your Consent:

  • Potential buyers or sellers (after NDA execution)
  • Investors or funding sources
  • Strategic partners

Information Shared:

  • Initially: Anonymised business summaries
  • After NDA: Detailed financial and operational data
  • During due diligence: Comprehensive business information

4.3 Legal Requirements

We may disclose information where required by law:

  • Court orders or legal proceedings
  • Regulatory investigations or requests
  • Law enforcement or tax authorities
  • Protection of our legal rights

4.4 Business Transfers

If Succeed or Unusual Consulting Limited is sold, merged, or restructured, personal data may be transferred to the successor entity, subject to this privacy policy.

4.5 What We Don't Do

We do not:

  • Sell personal data to third parties
  • Share client information without consent (except where legally required)
  • Use personal data for purposes incompatible with the original collection purpose

5. INTERNATIONAL DATA TRANSFERS

5.1 Why We Transfer Data Internationally

We provide services globally and use service providers in various countries. This may require transferring personal data outside the UK and European Economic Area (EEA).

5.2 Countries We Transfer To

Data may be transferred to:

  • United States (service providers, cloud infrastructure)
  • European Union countries
  • Other jurisdictions where clients or transaction parties are located

5.3 Safeguards

We ensure appropriate protection through:

Adequacy Decisions:

  • Transfers to countries recognised as having adequate data protection by the UK Government or European Commission

Standard Contractual Clauses (SCCs):

  • EU Commission approved contract terms with recipients
  • Additional safeguards where legal protection is uncertain

Explicit Consent:

  • Where you have agreed to specific international transfers

Contractual Necessity:

  • Where essential to perform services you have requested

6. DATA SECURITY

6.1 Security Measures

We implement appropriate technical and organisational measures:

Technical Security:

  • Encryption of data in transit (SSL/TLS)
  • Secure cloud storage with access controls
  • Regular security updates and patches
  • Firewall and intrusion detection systems
  • Multi-factor authentication for systems access

Organisational Security:

  • Staff training on data protection
  • Access restrictions on a need-to-know basis
  • Confidentiality agreements with employees and contractors
  • Regular security audits and reviews
  • Incident response procedures

6.2 Limitations

No internet transmission is completely secure. We cannot guarantee absolute security but take reasonable precautions to protect your data.

6.3 Your Responsibility

You should:

  • Keep login credentials confidential
  • Use secure internet connections for sensitive communications
  • Report suspected security breaches immediately
  • Consider using encrypted email for highly confidential information

7. DATA RETENTION

7.1 Retention Periods

Enquiries and Prospects:

  • 24 months from last contact
  • Deleted if you request removal or opt out of communications

Client Relationships:

  • 7 years from end of engagement (for legal and regulatory compliance)
  • Financial records retained per accounting and tax requirements

Active Listings:

  • Seller information retained until sale completes or listing is withdrawn plus 12 months
  • Buyer profiles retained for 24 months or until you request deletion

Marketing Consents:

  • Until you withdraw consent or for duration of legitimate interest (typically 3 years)

Website Analytics:

  • 26 months maximum

7.2 Reasons for Retention

We retain data to:

  • Comply with legal and regulatory obligations
  • Defend potential legal claims (statute of limitations periods)
  • Maintain transaction records for audit purposes
  • Provide continuity if you re-engage our services

7.3 Secure Disposal

When no longer needed, data is securely deleted or anonymised beyond recovery.

8. YOUR RIGHTS

8.1 Access Rights

Right to Access: You can request:

  • Confirmation of whether we process your personal data
  • Copies of your personal data
  • Information about how we use your data

We will respond within one month (extendable by two months for complex requests).

8.2 Correction and Deletion

Right to Rectification: Request correction of inaccurate or incomplete data.

Right to Erasure ("Right to be Forgotten"): Request deletion where:

  • Data is no longer necessary for the original purpose
  • You withdraw consent and we have no other legal basis
  • You object and we have no overriding legitimate interest
  • Data has been unlawfully processed

We may retain data where required by law or for legitimate interests (e.g. defending legal claims).

8.3 Restriction and Objection

Right to Restriction: Request we limit processing while disputes are resolved or data accuracy is verified.

Right to Object: Object to processing based on legitimate interests or for direct marketing purposes. We will stop unless we demonstrate compelling legitimate grounds.

8.4 Data Portability

Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.

Applies where processing is based on consent or contract and carried out by automated means.

8.5 Automated Decision-Making

Right to Human Intervention: You have the right not to be subject to solely automated decisions that produce legal or similarly significant effects, including:

  • Right to obtain human intervention
  • Right to express your point of view
  • Right to contest the decision

We do not currently use fully automated decision-making for significant decisions but employ AI-assisted tools subject to human oversight (see Section 11).

8.6 Exercising Your Rights

To exercise any rights, contact us:

  • Email: hello@unusualgroup.com
  • Subject line: "Data Subject Request"
  • Include: Your name, contact details, and specific request

We may request identification to verify requests.

8.7 Right to Complain

If dissatisfied with our handling of your data, you can lodge a complaint with:

Information Commissioner's Office (ICO)
Website: www.ico.org.uk
Helpline: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

9. COOKIES AND TRACKING

9.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. They help us provide functionality, remember preferences, and understand how you use the site.

9.2 Types of Cookies We Use

Essential Cookies:

  • Required for website functionality
  • Session management and security
  • Cannot be disabled without affecting site performance

Analytics Cookies:

  • Google Analytics or similar tools
  • Understanding visitor behaviour and site performance
  • Anonymised where possible

Marketing Cookies:

  • Tracking effectiveness of campaigns
  • Retargeting and personalised advertising
  • Require your consent

9.3 Managing Cookies

You can control cookies through:

  • Our cookie consent banner (on first visit)
  • Browser settings to block or delete cookies
  • Opt-out tools for specific advertising networks

Note: Blocking essential cookies may impair website functionality.

9.4 Full Cookie Policy

For detailed information, see our separate Cookie Policy available at [link].

10. CHILDREN'S PRIVACY

Our services are not directed at individuals under 18. We do not knowingly collect personal data from children.

If you believe we have collected information from a child, please contact us immediately for deletion.

11. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING

11.1 AI Usage

We use artificial intelligence tools to enhance our services, including:

  • Content generation and document drafting
  • Data analysis and financial modelling
  • Matching buyers with suitable opportunities
  • Website personalisation and chatbot functionality

11.2 Human Oversight

All material AI outputs are reviewed by qualified professionals before use. We do not make significant decisions based solely on automated processing without human intervention.

11.3 AI and Your Data

When AI tools process your personal data:

  • We use reputable providers with appropriate security measures
  • Data processing complies with GDPR requirements
  • We contractually restrict AI providers from using client data for model training (where possible)
  • You can request human review of AI-generated analysis

11.4 Transparency

We will disclose AI usage upon request and ensure you understand when AI has materially contributed to content or analysis.

For full details, see Section 15 of our Website Terms and Conditions.

12. CHANGES TO THIS POLICY

12.1 Updates

We may update this policy to reflect:

  • Changes in law or regulation
  • New technologies or processing activities
  • Improvements to our privacy practices

12.2 Notification

Material changes will be notified via:

  • Prominent notice on our website
  • Email to clients and subscribers
  • Updated "Last Updated" date at the top of this policy

12.3 Continued Use

Your continued use of our website or services after changes are posted constitutes acceptance of the updated policy.

13. CONTACT US

13.1 Privacy Questions

For questions about this Privacy Policy or our data practices:

Email: hello@unusualgroup.com

Subject: Privacy Enquiry

Address: 124 City Road, London, Greater London, United Kingdom, EC1V 2NX

13.2 Data Subject Requests

To exercise your rights under GDPR:

Email: hello@unusualgroup.com

Subject: Data Subject Request

Please include your name, contact details, and specific request.

13.3 Complaints

To report a data protection concern:

Succeed: hello@unusualgroup.com

Information Commissioner's Office:

Website: www.ico.org.uk

Telephone: 0303 123 1113

Succeed is a trading name of Unusual Consulting Limited

Company Number: 16719193

Registered in England and Wales

© 2026 Unusual Consulting Limited. All rights reserved.

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