TOUGE ADVISORY PRIVACY POLICY
Effective Date: [13.06.2026]
Last Updated: [05.07.2026]
This Privacy Policy explains how Tougeimports Ltd, trading as Touge Advisory ("Touge Advisory", "we", "us" or "our"), collects, uses, stores, protects and shares your personal information.
We are committed to respecting your privacy and protecting your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and all other applicable UK privacy legislation.
By using our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.
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1. WHO WE ARE
Touge Advisory is the trading name of Tougeimports Ltd, a private limited company incorporated in Wales.
Tougeimports Ltd Trading as Touge Advisory
Company Number: 16751157
Email:
Website:
For the purposes of UK data protection legislation, Tougeimports Ltd is the Data Controller of the personal data collected through our website and professional services.
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2. DATA PROTECTION REGISTRATION
Tougeimports Ltd trading as Touge Advisory is committed to protecting the privacy and security of personal data.
We are registered with the Information Commissioner's Office (ICO), the United Kingdom's independent authority responsible for upholding information rights and enforcing data protection legislation.
ICO Registration Number: ZC058742
We process personal data in accordance with:
UK General Data Protection Regulation (UK GDPR)
Data Protection Act 2018
Privacy and Electronic Communications Regulations (PECR), where applicable
Other applicable UK data protection legislation
We are committed to ensuring personal data is processed lawfully, fairly and transparently.
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3. CONFIDENTIALITY AND DATA SECURITY
Given the nature of our services, Touge Advisory may receive information that is confidential, commercially sensitive or personal.
This may include information relating to:
Clients and prospective clients
Vehicle ownership histories
Provenance documentation
Acquisition strategies
Transaction-related information
Vehicle documentation
Identification and contact information
Correspondence
Engagement records
Due diligence reports
We take appropriate technical and organisational measures designed to safeguard personal data against accidental loss, unauthorised access, misuse, disclosure, alteration or destruction.
Our security measures may include:
Secure cloud-based systems
Password-protected devices and accounts
Multi-factor authentication where appropriate
Access controls
Encryption where appropriate
Secure data backup procedures
Confidentiality obligations on personnel and professional advisers
Regular review of security procedures
Whilst every reasonable effort is made to protect personal data, no electronic storage or transmission system can be guaranteed to be completely secure.
Where we become aware of a personal data breach that presents a risk to individuals, we will respond in accordance with applicable legislation, including notifying the ICO and affected individuals where legally required.
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4. PERSONAL DATA WE COLLECT
Depending upon your interaction with Touge Advisory, we may collect:
Identity Information
Name
Title
Company name
Position
Contact Information
Email address
Telephone number
Postal address
Client Information
Consultation notes
Engagement details
Instructions
Correspondence
Billing information
Vehicle Information
Registration numbers
VIN/Chassis numbers
Ownership history
Service history
Provenance documentation
Specification information
Technical Information
When you visit our website we may collect:
IP address
Browser type
Device information
Website usage information
Cookie data
Marketing Information
Newsletter subscriptions
Communication preferences
Marketing consent records
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5. HOW WE COLLECT YOUR INFORMATION
We may collect information:
Directly from you
Through our website
Through enquiry forms
Through consultation bookings
Through email correspondence
Through telephone conversations
During client engagements
Through publicly available information
Through vehicle research
Through third-party referrals where appropriate
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6. HOW WE USE YOUR INFORMATION
We may process personal information to:
Respond to enquiries
Deliver our advisory services
Prepare reports
Carry out provenance research
Conduct due diligence
Arrange consultations
Manage our client relationships
Process payments
Maintain business records
Improve our website
Prevent fraud
Comply with legal obligations
Send newsletters or market insights where you have consented or where permitted by law
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7. OUR LAWFUL BASIS FOR PROCESSING
We process personal data under one or more of the following lawful bases:
Contract
Where processing is necessary to provide services requested by you.
Legitimate Interests
Including:
Operating Touge Advisory
Managing client relationships
Improving services
Maintaining records
Protecting our legal interests
Preventing fraud
Consent
Where required for:
Marketing communications
Optional newsletters
Certain cookies
You may withdraw consent at any time.
Legal Obligation
Where processing is required by law.
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8. SHARING YOUR INFORMATION
We may share information with:
Professional advisers
Accountants
Solicitors
Insurers
IT service providers
Cloud service providers
Website hosting providers
Payment processors
Where requested by you or necessary to provide our services, we may also share limited information with:
Dealers
Brokers
Auction houses
Vehicle specialists
Inspectors
Storage providers
Transport providers
We do not sell personal data.
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9. INTERNATIONAL TRANSFERS
Some of our technology providers may process personal data outside the United Kingdom.
Where this occurs, we will ensure appropriate safeguards are in place in accordance with UK data protection legislation.
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10. DATA RETENTION
We retain personal information only for as long as reasonably necessary.
Typical retention periods include:
Client engagement records: Up to 7 years after completion.
Accounting records: Up to 7 years.
Marketing records: Until consent is withdrawn or no longer required.
Website analytics: As determined by our analytics providers.
Where required by law or to protect legal rights, information may be retained for longer.
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11. YOUR RIGHTS
Under UK data protection law you may have the right to:
Request access to your personal data
Request correction of inaccurate information
Request deletion of personal data
Restrict processing
Object to processing
Request portability of your data
Withdraw consent where processing relies upon consent
Requests may be submitted using the contact details below.
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12. MARKETING COMMUNICATIONS
If you choose to subscribe to newsletters, download resources or request updates, we may occasionally send you:
Market insights
Articles
News
Service updates
Event invitations
You may unsubscribe at any time using the unsubscribe link included within our emails or by contacting us directly.
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13. COOKIES
Our website uses cookies and similar technologies.
Details of the cookies we use and how you can manage them are available in our Cookie Policy.
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14. THIRD-PARTY WEBSITES
Our website may contain links to external websites.
We are not responsible for the privacy practices or content of third-party websites.
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15. CHILDREN
Our services are intended for adults.
We do not knowingly collect personal information from anyone under the age of 18.
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16. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time.
The latest version will always be published on our website.
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17. COMPLAINTS
If you have any questions or concerns regarding how we handle your personal data, please contact us first.
If you remain dissatisfied, you have the right to lodge a complaint with the:
Information Commissioner's Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk
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18. CONTACT US
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact:
Tougeimports Ltd Trading as Touge Advisory
Company Number: 16751157
ICO Registration Number: ZC058742
Email: enquiries@tougeadvisory.com
Website: www.tougeadvisory.com
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Touge Advisory is committed to protecting the privacy, confidentiality and security of the information entrusted to us. We continually review our practices to ensure they remain appropriate, effective and compliant with applicable UK data protection legislation.
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