We specialise in the succesful restoration of pubs that are either closed, failing due to poor management or simply a lack of investment. With decades of experience and a vast knowledge of all aspects of pub management you can trust us to help restore your pub to it’s former glory.

365 Management Solutions Ltd Privacy Policy
Last Updated: 4 June 2026

1. Introduction

365 Management Solutions Ltd ("365MSL", "we", "our", "us") is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you interact with us, use our services, visit our website, apply for employment or business opportunities, enter into agreements with us, or otherwise provide personal information.

We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection legislation.

2. Who We Are

Data Controller:
365 Management Solutions Ltd

Trading Address:
365 Management Solutions Ltd
Head Office
Widnes
Cheshire
WA8 0SZ

Data Protection Contact:
Steven Hawthorne
Managing Director

Email:steve@365msl.co.uk

For any questions regarding this Privacy Policy or your personal data, please contact us using the details above.

3. Information We Collect

We may collect and process the following categories of personal information:

Identity Information

• Name
• Date of birth
• Driving licence details
• Passport details
• Personal licence details
• Proof of address documentation

Contact Information

• Residential address
• Business address
• Email address
• Telephone number

Business Information

• Company details
• Director information
• Shareholder information
• VAT and company registration information
• Business banking details

Financial Information

• Creditworthiness information
• Personal guarantee information
• Payment history
• Banking information

Employment and Recruitment Information

• CVs and employment history
• References
• Qualifications
• Right to work information

Technical Information

• IP addresses
• Browser information
• Device information
• Website usage information
• Cookies and analytics data

4. How We Use Personal Information

We may use personal information to:

• Assess applications from prospective operators, contractors and employees.
• Manage operator agreements and contractual relationships.
• Verify identity and prevent fraud.
• Conduct due diligence and compliance checks.
• Assess financial suitability and affordability.
• Manage supplier and customer relationships.
• Process payments and maintain accounting records.
• Comply with legal and regulatory obligations.
• Protect our business and assets.
• Improve our services and website.

5. Credit Reference and Affordability Checks

To help us assess applications, prevent fraud, and meet our legal and regulatory obligations, we may obtain information about you from credit reference agencies (CRAs).

We obtain this information via Creditsafe, which uses its data partner TransUnion to supply consumer credit and identity data.

Creditsafe Business Solutions Limitedis authorised and regulated by the Financial Conduct Authority.
FCA Firm Reference Number: 742313

TransUnion International UK Limitedis authorised and regulated by the Financial Conduct Authority.
FCA Firm Reference Number: 737740

The information we receive may include data relating to your identity, credit commitments, payment history and public record information.

This data is used solely for legitimate business purposes, including:

• Creditworthiness assessments
• Identity verification
• Fraud prevention
• Due diligence checks
• Assessment of prospective operators, contractors and guarantors
• Risk management and compliance activities

Further information about how Creditsafe and TransUnion process personal data can be found here:

Creditsafe Transparency Notice:
https://www.creditsafe.com/gb/en/legal/transparency-notice-customer-supplier.html

TransUnion Credit Reference Agency Information Notice (CRAIN):
https://www.transunion.co.uk/legal/privacy-centre/pc-credit-reference

TransUnion Bureau Privacy Notice:
https://www.transunion.co.uk/legal/privacy-centre/pc-bureau

6. Lawful Basis for Processing

We process personal information under one or more of the following lawful bases:

• Performance of a contract.
• Legitimate interests.
• Compliance with legal obligations.
• Consent (where required).
• Establishment, exercise or defence of legal claims.

7. Sharing Personal Information

We may share information with:

• Credit Reference Agencies.
• Fraud prevention agencies.
• Professional advisers.
• Insurers.
• Regulatory authorities.
• Government bodies.
• Software providers and cloud service providers.
• Compliance and audit providers.
• Banking and payment providers.

We do not sell personal data to third parties.

8. International Data Transfers

We may transfer personal data to recipients or service providers located outside the United Kingdom and/or European Economic Area (EEA).

Where such transfers take place, we ensure appropriate safeguards are in place to protect personal data in accordance with applicable data protection laws.

These safeguards may include:

• International Data Transfer Agreements (IDTAs).
• Standard Contractual Clauses (SCCs).
• Transfers to countries recognised as providing an adequate level of protection.

9. Data Security

We take appropriate technical and organisational measures to protect personal information, including:

• Password-protected systems.
• Multi-factor authentication where available.
• Antivirus and endpoint protection software.
• Secure cloud-based storage systems.
• Restricted user access.
• Regular software updates and patch management.
• Staff awareness and security procedures.

Access to personal information is restricted to authorised personnel who require access for legitimate business purposes.

10. Provision of Personal Data
Is the provision of personal data statutory or contractual?

The provision of certain personal data is primarily contractual and, in some circumstances, required to meet legal and regulatory obligations.

Personal data may be required to:

• Enter into and perform contracts with customers, operators, suppliers and contractors.
• Process applications and manage business relationships.
• Verify identity and prevent fraud.
• Conduct due diligence and financial assessments.
• Comply with legal, accounting, taxation and regulatory obligations.

What are the consequences of not providing personal data?

If you choose not to provide personal data requested by us:

• We may be unable to enter into a contract with you.
• We may be unable to provide services.
• We may be unable to undertake compliance or fraud prevention checks.
• Applications or agreements may be delayed, restricted or declined.

Where information is requested solely for marketing purposes, providing such information is voluntary and consent may be withdrawn at any time.

11. Non-Automated Decision Making and Profiling

We may use automated systems and tools to support certain business processes, such as risk assessment, fraud prevention, affordability checks, identity verification and record management.

These tools may analyse personal data using predefined criteria or rules to generate indicators, scores or recommendations.

However, we do not make decisions that have a legal or similarly significant effect on individuals based solely on automated processing. Any such decisions are subject to meaningful human review.

The use of these tools may influence the speed or level of review applied to an application or request, but individuals will not be subject to automatic rejection or adverse decisions without human involvement.

12. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, taxation and contractual obligations.

Retention periods will vary depending upon the type of information held and the purpose for which it was collected.

13. Your Rights

Under UK GDPR, you may have the right to:

• Access your personal information.
• Correct inaccurate information.
• Request deletion of your information.
• Restrict processing.
• Object to processing.
• Request transfer of your information.
• Withdraw consent where processing is based on consent.

Requests should be made to:

steve@365msl.co.uk

14. Complaints

If you have concerns about how we process your personal information, please contact us first.

You also have the right to complain to the Information Commissioner's Office (ICO).

Information Commissioner's Office
https://ico.org.uk

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect legal, regulatory or operational changes.

The most recent version will always be available on our website and will show the date of the latest revision.

www.creditsafe.com