1. Introduction
This Privacy Policy explains how Somah Group ("we", "us", "our") collects, uses and protects personal data when you visit our website, contact us or engage with our institutional services. We are committed to handling your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Data We Collect
We may collect the following categories of personal data:
- Contact details — name, email address, phone number, company name and job title provided when you contact us.
- Business information — details about your company, requirements, transaction volumes and counterparties relevant to a service enquiry.
- Technical data — IP address, browser type, device information and pages visited, collected via standard server logs.
- Correspondence — records of emails, calls and meetings related to our engagement.
3. How We Use Personal Data
We process personal data to:
- Respond to enquiries and provide requested information or services.
- Conduct due diligence and onboarding via our authorised third-party partners.
- Manage and develop our client and partner relationships.
- Comply with legal, regulatory and contractual obligations.
- Improve and secure our website and services.
4. Legal Basis for Processing
We rely on one or more of the following lawful bases under UK GDPR:
- Consent — where you have explicitly agreed to a specific use, such as receiving marketing communications.
- Contract — where processing is necessary to take steps prior to entering into, or perform, a contract with you.
- Legitimate interests — for running our business, including responding to enquiries, network introductions and security.
- Legal obligation — where required by law or regulation (for example, anti-money-laundering requirements).
5. Sharing Your Information
We may share personal data with:
- FCA-regulated payment institutions and lenders within our network where you have requested an introduction or onboarding.
- Professional advisers, auditors and IT service providers who support our operations under appropriate confidentiality obligations.
- Regulators, law enforcement or other authorities where required by law.
We do not sell personal data.
6. International Transfers
Where personal data is transferred outside the United Kingdom or European Economic Area, we put in place appropriate safeguards (such as Standard Contractual Clauses) to ensure your data remains protected.
7. Data Retention
We retain personal data only for as long as necessary for the purposes outlined above, including to comply with legal, accounting and reporting requirements. Records related to financial introductions are typically retained in line with the relevant regulator’s requirements.
8. Your Rights
Subject to certain conditions, you have the right to:
- Request access to your personal data.
- Request correction of inaccurate or incomplete data.
- Request erasure of your data ("right to be forgotten").
- Restrict or object to certain processing.
- Request data portability.
- Withdraw consent at any time, where consent is the lawful basis.
To exercise any of these rights, please contact us at [email protected]. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk.
9. Cookies and Analytics
Our website uses a minimal set of essential cookies required for site functionality. We may use anonymised analytics to understand site usage; these do not personally identify visitors. You can control cookie behaviour through your browser settings.
10. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction. However, no method of transmission over the internet is fully secure, and we cannot guarantee absolute security.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be highlighted on this page. Please check back periodically for the latest version.
12. Contact Us
If you have any questions about this Privacy Policy or how we handle your data, please contact us:
Somah Group
59 Lavender Place, Ilford
United Kingdom, IG1 2BG
Email: [email protected]
Phone: +44 203 932 2199
