GDPR Policy

Last updated: Monday 20th July 2026

Vortex Circular Solutions Ltd ("VCS", "we", "us", "our") is committed to protecting your personal data and respecting your privacy. This policy explains what personal data we collect when you use our website or get in touch with us, why we collect it, how we use and protect it, and the rights you have over it.

This policy is written to comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Where we process the personal data of individuals in the European Union, the EU GDPR may also apply.

1. Who we are

Vortex Circular Solutions Ltd is the data controller responsible for the personal data described in this policy. This means we decide how and why your data is processed.

Our details:

  • Company: Vortex Circular Solutions Ltd

  • Registered/trading address: Unit 4 Power Business Park, Towers Business Park, Rugeley, Staffordshire, WS15 1UZ

  • Email:enquiries@vortexcircularsolutions.com

  • Phone: +44 (0) 7738 167 357

  • ICO registration number: ZC192264

2. What this policy covers

This policy covers personal data we collect through:

  • Visits to our website (www.vortexcircularsolutions.com)

  • Enquiries you make by email, phone, or through any form on our website

  • Any subscription to updates or content (for example via our Knowledge Hub)

  • Business relationships with clients, suppliers, and partners

It does not cover personal data that we process on behalf of our clients when delivering IT Asset Disposition (ITAD) or data destruction services. See Section 11 for how that is handled.

3. The personal data we collect

Depending on how you interact with us, we may collect:

When you visit our website

  • Technical data: IP address, browser type and version, device information, operating system

  • Usage data: pages you view, the pages you visited before arriving, time spent on the site

  • Cookie data (see Section 8)

Our website is hosted by Squarespace, which collects this technical and usage data to run, secure, and improve the site.‍ ‍

When you contact us or make an enquiry

  • Your name

  • Your email address

  • Your phone number (if you provide it)

  • Your company name and role (if provided)

  • The content of your message and any information you choose to share

If you subscribe to updates or Knowledge Hub content

  • Your name and email address

  • Your subscription preferences

In the course of a business relationship‍ ‍

  • Business contact details

  • Correspondence and records relating to services, quotes, and contracts

We do not intentionally collect any special category data (such as health, ethnicity, or political views) through our website, and we ask that you do not send us such data through our enquiry channels.

4. How we collect your data

We collect personal data:

  • Directly from you — when you email us, call us, complete a form, or subscribe to updates.

  • Automatically — when you use our website, through Squarespace and cookies (see Section 8).

  • From third parties or public sources — occasionally, in a business-to-business context, we may obtain business contact details from public sources (such as a company website or LinkedIn) for legitimate marketing or partnership purposes.

5. Why we use your data and our lawful bases

Under UK GDPR we must have a lawful basis for processing your personal data. We rely on the following:

What we use your data forLawful basisResponding to your enquiries and providing information you requestLegitimate interests / steps prior to entering a contractProviding our services and managing our contract with youPerformance of a contractRunning, securing, and improving our websiteLegitimate interestsSending you marketing or Knowledge Hub updatesConsent (or legitimate interests for existing business contacts, where permitted)Meeting legal, accounting, and regulatory obligationsLegal obligationEstablishing, exercising, or defending legal claimsLegitimate interests

Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights and freedoms. Where we rely on consent, you can withdraw it at any time (see Section 12).

6. Marketing communications

If you have subscribed to updates or are an existing business contact, we may send you information about our services and content that may be relevant to you.

You can opt out at any time by using the unsubscribe link in any email we send, or by contacting us at enquiries@vortexcircularsolutions.com. We will never sell your personal data to third parties for their own marketing.

7. Who we share your data with

We do not sell your personal data. We share it only where necessary, with:

  • Squarespace — our website host and, where applicable, form and email provider.

  • Service providers — such as email, IT, and analytics providers who process data on our behalf under contract. [List specific tools, e.g. Google Analytics, an email marketing platform, if used.]

  • Professional advisers — such as accountants and legal advisers, where required.

  • Regulators, law enforcement, or other authorities — where we are legally required to do so. ‍

All third parties who process data on our behalf are required to keep it secure and use it only for the purposes we specify.

8. Cookies

Our website uses cookies and similar technologies. Cookies are small text files placed on your device that help the site function and help us understand how it is used.

We use:

  • Strictly necessary cookies — required for the website to work.

  • Analytics/performance cookies — to understand how visitors use the site so we can improve it.

  • Functional cookies — set by Squarespace to remember your preferences.

You can manage or disable cookies through your browser settings. Blocking some cookies may affect how the website functions

9. International transfers ‍

Some of our service providers — including Squarespace — are based in, or store data in, the United States or other countries outside the UK.

Where personal data is transferred outside the UK, we ensure it is protected by an appropriate safeguard, such as the UK's adequacy regulations, the UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses. Squarespace provides these safeguards as part of its service.

10. How long we keep your data

We keep personal data only for as long as necessary for the purposes set out in this policy, including to satisfy any legal, accounting, or reporting requirements.

As a general guide:

  • Enquiries that do not become clients: [e.g. up to 24 months] from your last contact.

  • Client and contractual records: for the duration of the relationship and up to [e.g. 6–7 years] afterwards, to meet legal and tax obligations.

  • Marketing data: until you unsubscribe or ask us to stop

11. Data we process on behalf of clients (ITAD and data destruction)

When we provide IT Asset Disposition, data destruction, refurbishment, or recycling services, the equipment we handle may contain personal data belonging to your organisation or its data subjects. ‍

In these situations, VCS acts as a data processor and your organisation remains the data controller. Our handling of that data — including secure erasure, destruction, chain of custody, and certification — is governed by the data processing terms in our service agreement with you, not by this website privacy policy.

If you would like a copy of our data processing terms or information about our data destruction standards and certifications, please contact us at enquiries@vortexcircularsolutions.com.

12. Your rights

Under UK GDPR you have the right to:

  • Be informed about how we use your data (this policy).

  • Access the personal data we hold about you.

  • Rectification of inaccurate or incomplete data.

  • Erasure of your data in certain circumstances ("right to be forgotten").

  • Restrict processing in certain circumstances.

  • Data portability — to receive your data in a portable format.

  • Object to processing based on legitimate interests or for direct marketing.

  • Withdraw consent at any time, where we rely on consent.

To exercise any of these rights, contact us at enquiries@vortexcircularsolutions.com. We will respond within one month. There is normally no charge, and we may need to verify your identity before acting on a request.

13. How we protect your data

We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. These include secure hosting, access controls, and staff awareness. While no online transmission is ever completely secure, we take reasonable steps to safeguard the data you share with us.

14. Complaints

‍If you have any concern about how we handle your personal data, please contact us first so we can try to resolve it.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator for data protection: ‍

  • Website: ico.org.uk

  • Helpline: 0303 123 1113

15. Changes to this policy

We may update this policy from time to time. The latest version will always be published on this page, with the "Last updated" date revised accordingly. We encourage you to review it periodically.

16. Contact us

If you have any questions about this policy or how we handle your personal data, please contact:

Vortex Circular Solutions Ltd Unit 4 Power Business Park, Towers Business Park, Rugeley, Staffordshire, WS15 1UZ
Email: enquiries@vortexcircularsolutions.com
Phone: +44 (0) 7738 167 357

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