Privacy Policy - New Path Advisory Ltd.

Please read the following to learn more about our privacy policy.

This privacy policy (Policy) explains how we collect, process and secure your personal data as well as explaining the various rights you have.

We are registered with the Information Commissioner’s Office (ICO). Our registration covers the uses of personal data set out below.

At NEW PATH we take the privacy and security of personal data very seriously. We want to ensure you are fully informed about your rights and how NEW PATH will use your personal data. We will also detail which legal basis allows us to use the personal data that we have collected.

Our site may, from time to time, contain links to and from the websites of third parties (for example, Twitter). If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

We may review and update this Policy from time to time in order to ensure that it properly reflects our use of your personal data so please check regularly for any updates. The date this Policy was last updated can be found at the top of this page. We may also advise you of any amendments to this Policy by email. If you have any further questions after reading this Policy then please get in contact with us:


  1. How do we use your personal data?

  2. What is our legal basis for using your personal data?

  3. When do we share your personal data with third parties?

  4. How is your personal data protected?

  5. How long do we keep your personal data?

  6. What are your rights?

  7. Complaints and queries

  8. NEW PATH’s contact information

  9. When do we collect your personal data?

1. When do we collect your personal data?

         We will collect and process personal data when:

  • you visit our website and fill in any of the available enquiry forms;

  • we speak to you on the telephone;

  • you engage with our services and submit contractual documents;

  • you engage with us on social media;

  • you book any kind of appointment;

  • you contact us by email with queries, complaints, etc.;

  • you create an online account with us;

  • we collect information from publicly available sources, such as companies house;

  • information has been made public as a matter of law.

2. What personal data do we collect?

It is important that you understand what personal data we collect about you. We collect the following:

  • contact information (such as email address, telephone number and both business and correspondence addresses);

  • non-personal information (such as business contact information, business accounts, sector / business descriptions and registered company number);

  • details of your visits to our group websites gathered through the use of cookies in your web browser (should you consent to this).

  • details of conversations, requests for information and documents supplied to us during the course of discussions;

  • payment card information. This is not stored on our systems and is used at the point of payment only. Payment details are not obtained on a recorded telephone line and any   written information is securely destroyed upon submission of the payment; and

3. How do we use your personal data?

Administration and the provision of services

  • We will use your personal data to process any enquiries submitted via our website, on social media, by email, or over the telephone. We will also process your personal data when you book an appointment with us.

  • We will process your personal data for day to day business operations, such as facilitating a company sale transaction. Your personal data will be processed when you engage with our services, submit any contractual documentation, or process payments.

  • We will process your personal data during telephone conversations with us as these may be recorded for our internal training and customer service purposes.

  • We also use your personal data to enable us to contact you, respond to any queries, complaints or comments that you have and to make sure that these are appropriately dealt with.


  • We will use your contact information to send you marketing where you have signed up to receive marketing from us or where we are able to lawfully market to you without requiring your express consent.

  • For instance, we will send you marketing to: (1) advise you of services or an acquisition opportunity that might be relevant to you or your business; or (2) provide you with information about the potential sale value of your business, about selling your company, or any promotions and industry updates.

  • You can opt out of receiving marketing at any time by either following the instructions to unsubscribe in any of our marketing communications. It may take up to 7 days for your change in preference to take effect and the change will not affect any marketing communications which have already been scheduled to be sent to you during that time.

  • If you opt out of marketing, we will still need to send you communications by  email from time to time such as those relating to your online account (if any). Please also note that if you opt out of marketing, we will retain your contact information in a suppression list. This ensures that we do not send you marketing communications again.


We may process your personal data to protect our business and any online account you hold from fraud. We may also monitor your web browsing history (through the use of cookies) to check for any website problems. We do this to protect the integrity of our websites and your online account. We will work to rectify any issues immediately and advise you if your account requires any maintenance.

4. What is our legal basis for using your personal data?

Current data protection law states that there are a number of legal reasons why a company might collect and process personal data. NEW PATH has undertaken a full review of its policies and procedures to determine the most relevant legal basis and this section tells you what the legal basis is in relation to each of the purposes identified under Section 3 above:


Legal basis

Account management

It is necessary for us to process your personal data in order to set up and manage your online account, together with meeting any contractual obligations that we may have in respect of the same.

Administration and the provision of services

It is in our and your legitimate interest to process your personal data for day to day business operations such as to maintain contact with you to progress a deal, processing payments, etc. It is in our legitimate interest to record telephone calls as we may need to refer to them in order to clarify the details of our conversation, deal with a complaint and for our internal training purposes to help us deliver quality services. It is a contractual necessity to process your personal data in instances where we are providing you with services, for example we cannot progress a deal without your personal data.


In order to make our communications relevant, it is important that we use your personal data to inform you of services which might be relevant to you. It is in our legitimate interest to contact you with tailored information, such as communications regarding company sale transactions that are relevant to your needs/interests. It is also in our legitimate interest to maintain suppression lists where you opt out of marketing so that we can ensure we comply with your request not to be marketed to in the future. Where we are unable to rely on our legitimate interests to market to you, we will obtain your prior consent.


It is in our legitimate interests to process your data and account activity in order to protect our business, and any online account you may hold, from fraud. If we detect any issues, we are then able to deal with them promptly.

5. When do we share your personal data with third parties?

Subject to the details set out below, we will not pass on your personal data to any third party without your consent.

We do not transfer your personal data outside of the EEA.

In some circumstances, we need to share personal data with third parties and this includes:

  • where we are legally required to disclose the personal data. This includes sharing the personal data with tax authorities and law enforcement agencies in their legitimate interests, for the purposes of the prevention and detection of crime;

  • where we need to disclose the personal data for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights, where this is in our or a third party’s legitimate interests;

  • disclosure is required to protect our interests, or someone else’s interests (for example, to prevent fraud);

  • disclosure is necessary to protect your vital interests (for example, if you are unwell at our premises, we may need to seek medical assistance);

  • where you request details of a specific business and we need to advise our client of your interest;

  • to any prospective purchaser of our business assets or organisation.

6. How is your personal data protected?

NEW PATH take the security of personal data very seriously and conduct regular reviews to ensure that the protection is adequate for the information that is stored. We have taken the following steps internally in order to ensure that our systems adequately protect your personal data:

  • we use an online business system that is password protected. It also uses SSL encryption technology;

  • NEW PATH employees are fully trained in data protection and know their responsibilities in relation to securing your personal data;

  • our systems and infrastructure ensure that only the relevant employees have access to your personal data. Personal data that is not relevant to their role is not accessible;

  • our servers are protected with the latest firewalls and virus protection software.

7. How long do we keep your personal data?

As a general rule, we keep your personal data for a maximum period of three years from the point at which it is collected or obtained by us. However, where we have statutory obligations to keep personal data for a longer period or where we may need your personal data for a longer period in case of a legal claim, then the retention period may be longer.

8. Your Rights

You have a number of rights in respect of your personal data and this Section explains a bit more about those rights that are applicable to what we do with your personal data and when you can exercise them. If you would like more information about any of your rights, please contact us on the details set out in  below. Unless stated otherwise below, please allow us up to one month to process your request.

Opting out from receiving marketing

If you no longer wish to receive any marketing or communications from us, please send your request in writing to us by email or post on the contact details set out in  below.

Please allow us up to 7 calendar days to process your request and remove you from our mailing list. We will retain your information in a separate suppression list to ensure we do not accidentally contact you for marketing purposes again.

Accessing your personal data

We want you to fully understand and be comfortable with how we use your personal data. You can contact us at any time to ask whether we process any personal data about you. If we do hold or use your personal data in any way, you have the right to access that personal data. All we ask is that:

  • you make your request to access in writing to the contact details below;

  • you verify your identity; and

  • you are fair and reasonable with how often you make this kind of request; otherwise we reserve the right to change an administration fee for dealing with such requests.

Please allow us up to one month from receipt of your request in order to provide a response. However, if your request is particularly complicated, we may need to extend our response time by a further month. If we anticipate that we need this longer period, we will let you know as soon as practicable and before our original response time expires.

Requesting more information

We hope that you can understand that it is very difficult to cover all the possible ways in which we collect and use personal data. We have tried to be as clear and as open as we can and will continue to update this Policy as our use of personal data develops. However, if you have any questions regarding our use of your personal data, we will be happy to give you peace of mind by answering any questions or providing any additional information that we can. If you do have any specific questions, or need anything explaining, please get in touch on the contact details set out in  below.

Additional rights

You also have some additional rights that you may exercise as set out here. In each instance we may ask you to make your request in writing by email or post to the contact details set out in  below and provide verification of your identity.

  • You have the right to request that we rectify any inaccuracy about you that we may hold, in which case we may ask you to verify the corrected information (for example, we may ask for a recent utility bill for proof of change of address).

  • You have the right to request that we erase your personal data. Please be aware that we can only comply with such a request if:

(a) your personal data is no longer required for the purposes it was collected for (for example, we need your personal data to respond to a communication);

(b) the collection, storage or use of the personal data by us is prevented by law;

(c) your personal data is not required for the purposes of establishing, exercising or defending a legal claim such as in the conduct of legal proceedings.

  • You have the right to request that we restrict or refrain from processing your personal data:

(a) for the time it takes us to verify the accuracy of your personal data where you have disputed its accuracy;

(b) where the collection, storage or use of the personal data by us is unlawful but you decide not to ask for erasure;

(c) where, we no longer need your personal data but you need them for the purposes of establishing, exercising or defending a legal claim;

(d) for the time it takes to determine whether we have an overriding legitimate ground to continue to process your personal data, where you have exercised your right to object to processing.

  • You have the right to data portability in respect of personal data we have collected from you based on consent or for the reason of entering into a contract. If you exercise this right, we will transfer a copy of the information that you have provided to us at your request.

  • You have the right to object to our use of your personal data:

(a) where we are using your personal data based on our legitimate interests, and where we do not have compelling overriding grounds to continue to use your personal data; or

(b) at any time, where we use your personal data to send you any type of direct marketing, in which case it will no longer be used for that purpose, but may be used for another lawful purpose.

9. Complaints and queries

We have high standards when it comes to collecting and using personal data. For this reason, we take any complaints we receive from you about our use of your personal data very seriously and request that you bring any issues to our attention.

Where you are communicating with us for the purpose of making a complaint, we will only use your personal data to handle, investigate and respond to the complaint and to check on the level of service we provide. Where the complaint is about a member of our team, we may have to disclose your identity to whoever the complaint is about. You may let us know that you don’t want information that identifies you to be disclosed and we will try to respect your request; however, it may not be always possible to handle a complaint on an anonymous basis.

If you have any complaints or queries in relation to how we collect or use your personal data, please contact us using the details set out below.

If you are unhappy with how we handle your complaint or query, you can also contact the Information Commissioner’s Office (ICO) to make a complaint directly.  Please visit for details.