Privacy Policy
Searlco Ltd · Last updated 6 August 2026
Who we are
Searlco Ltd ("Searlco", "we", "us", "our") is committed to protecting your personal data and respecting your privacy.
This policy explains what personal data we collect, how we use it, who we share it with, how long we keep it and what rights you have. It applies to www.searlco.com and its subdomains and sections, including Searlco University, and to our wider business activities as an affiliate and influencer marketing agency.
Data controller: Searlco Ltd, a company registered in England and Wales under company number [COMPANY NUMBER], registered office [REGISTERED OFFICE ADDRESS].
Contact for data protection matters: [DATA PROTECTION CONTACT EMAIL] General contact: team@searlco.net · +44 (0)20 3287 2232
We are registered with the Information Commissioner's Office (ICO) under registration number [ICO REGISTRATION NUMBER].
When we are a controller and when we are a processor
We act as a data controller — deciding why and how personal data is processed — in relation to visitors to our website, business enquiries, prospective and current client contacts, publishers and creators we recruit or work with, suppliers and job applicants.
We act as a data processor — processing personal data on a client's instructions — when we manage a client's affiliate or influencer programme on their behalf, or when a client uses one of our platforms and we process data belonging to that client's programme. In those cases the client is the controller, our processing is governed by the data processing terms in our agreement with them, and you should refer to that client's own privacy policy.
The personal data we collect
Website visitors and enquiries
- Identity and contact data: name, job title, company name, email address, telephone number.
- Enquiry content: the message, brief, programme details or questions you send us via a contact form, email or a booked discovery call.
- Booking data: where you book a call through our scheduling provider, your name, email address, chosen time zone and any details you enter.
- Technical data: IP address, browser type and version, device type, operating system, approximate location derived from IP.
- Usage data: pages viewed, referring URL, time on page, links clicked, and how you navigate the site — including which Searlco University guides you read.
- Marketing preferences: your consent status and any preferences you set.
Publishers, affiliates and creators
Where we carry out publisher recruitment or influencer outreach for our own business or on a client's behalf, we may collect and process:
- business contact details, including name, role, business email address and telephone number;
- publicly available information about the website, channel, audience, content niche, geography and traffic profile;
- correspondence with us and application or onboarding details; and
- where relevant to payment, bank or payment-service details and tax information.
Much of this is collected from publicly available business sources, network directories, professional platforms and the publisher's own website or channel.
Affiliate tracking data
Where we or our platforms operate tracking for an affiliate programme, we may process click identifiers, referral identifiers, timestamps, IP address, device and browser information, referring URL, and transaction reference and value.
This data is used to attribute a sale to the correct partner, to calculate commission and to detect fraud or non-compliant activity. It is generally processed on behalf of the merchant operating the programme, who is the controller for that data.
Client contacts
Business contact details, role, correspondence, contractual and billing information, and records of the services provided.
What we do not knowingly collect
Our website and services are directed at businesses and professionals. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us and we will delete it.
We do not seek to collect special category data (such as data revealing health, racial or ethnic origin, religious beliefs, political opinions, trade union membership, sex life or sexual orientation) or criminal offence data. Please do not send such information to us unless we have specifically asked for it.
Why we use your data, and our lawful basis
| Purpose | Lawful basis |
|---|---|
| Responding to enquiries and arranging discovery calls | Legitimate interests (responding to a request made to us); steps prior to entering a contract |
| Providing our services and managing the client relationship | Performance of a contract |
| Publisher, affiliate and influencer recruitment and outreach | Legitimate interests (business development, partner recruitment) |
| Operating affiliate tracking, attribution and commission calculation | Performance of a contract; legitimate interests (accurate attribution and payment) |
| Fraud detection, compliance monitoring and brand protection | Legitimate interests (preventing fraud and protecting our clients' revenue); legal obligation |
| Sending marketing communications about our services | Consent, or legitimate interests where permitted for existing business contacts |
| Analytics, site improvement and non-essential cookies | Consent |
| Essential site operation and security | Legitimate interests (running a secure, functioning website) |
| Invoicing, accounting and tax records | Legal obligation |
| Establishing, exercising or defending legal claims | Legitimate interests; legal obligation |
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You can ask us for details of that assessment, and you have the right to object (see section 9).
Marketing communications
We may send you information about our services where you have consented, or where you are an existing business contact and the communication relates to services similar to those you have already enquired about or received.
Every marketing email includes an unsubscribe link. You can also opt out at any time by contacting [DATA PROTECTION CONTACT EMAIL]. Opting out of marketing will not stop service-related or contractual communications.
Where we conduct business-to-business outreach to publishers, creators and prospective clients, we do so in accordance with UK GDPR and the Privacy and Electronic Communications Regulations, and we tell you in that first message who we are, why we are contacting you and how to opt out.
Cookies and similar technologies
We use cookies and similar technologies on our website. These fall into the following categories:
- Strictly necessary — required for the site to function and to keep it secure. These do not require consent.
- Analytics and performance — help us understand how the site is used so we can improve it.
- Functionality — remember your preferences.
- Marketing and tracking — used to measure campaign effectiveness and, in the affiliate context, to attribute referrals.
Non-essential cookies are only set where you have given consent through our cookie banner. You can change or withdraw your consent at any time via [COOKIE SETTINGS LINK], and you can control cookies through your browser settings, although blocking some cookies may affect how the site works.
Full details of the specific cookies we use, their purpose and their duration are set out in our Cookie Policy at [COOKIE POLICY URL].
Who we share your data with
We do not sell your personal data. We may share it with:
- Service providers acting as processors on our behalf — including website and application hosting, email and productivity platforms, CRM and outreach tools, meeting scheduling, analytics, cloud storage, and payment and accounting providers. Each is bound by a written contract requiring them to process data only on our instructions and to keep it secure.
- Clients, where we recruit publishers or manage a programme on their behalf and it is necessary to share partner or performance data with them.
- Affiliate networks and tracking platforms, where a programme runs on a third-party network.
- Professional advisers, including lawyers, accountants, insurers and auditors.
- Regulators and law enforcement, where we are legally required to disclose information.
- A purchaser or successor, in the event of a sale, merger or reorganisation of our business.
Where we use AI or automated tools to assist with research, drafting or analysis, we do so under terms that prohibit the provider from using submitted data to train their models, and we take care not to submit personal data where it is not necessary.
International transfers
Some of our service providers are based outside the UK. Where we transfer personal data outside the UK, we ensure an appropriate safeguard is in place, which will be one of:
- a UK adequacy decision covering the destination country;
- the International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses; or
- another mechanism permitted under UK data protection law.
You can request details of the safeguards applied to a specific transfer by contacting us.
How long we keep your data
We keep personal data only as long as necessary for the purpose it was collected for, including to satisfy legal, accounting or reporting requirements.
As a general guide:
- Website enquiries that do not progress: up to 24 months from last contact.
- Client records: for the duration of the relationship and 6 years after it ends, for contractual and tax purposes.
- Publisher and partner records: for the duration of the partnership and up to 6 years afterwards where commission, tax or dispute records apply.
- Affiliate tracking data: in line with the merchant's instructions and the commission validation and reversal period, typically no more than 24 months.
- Marketing contacts: until you opt out, or after 24 months of no engagement.
- Analytics data: typically no more than 26 months.
Where data is no longer needed, we delete it or anonymise it so it can no longer be linked to you.
Your rights
Under UK data protection law 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;
- restrict processing in certain circumstances;
- data portability — receive data you provided in a structured, commonly used, machine-readable format;
- object to processing based on legitimate interests, and to object at any time to direct marketing; and
- withdraw consent at any time, where we rely on consent. This does not affect the lawfulness of processing before withdrawal.
We do not carry out automated decision-making that produces legal or similarly significant effects on individuals. Where our platforms apply automated scoring or flagging to affiliate traffic for fraud and compliance purposes, a member of our team reviews any decision that would materially affect a partner.
To exercise any right, contact [DATA PROTECTION CONTACT EMAIL]. We will respond within one month. There is no fee, although we may charge a reasonable fee or refuse a request that is manifestly unfounded or excessive. We may need to verify your identity first.
Security
We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration. These include access controls, encryption in transit, restricting access to those who need it, supplier due diligence and staff confidentiality obligations.
We have procedures to deal with any suspected personal data breach and will notify the ICO, and you where required, in line with our legal obligations.
No transmission over the internet is completely secure, and any transmission is at your own risk.
Complaints
If you have a concern about how we handle your personal data, please contact us first at [DATA PROTECTION CONTACT EMAIL] so we can try to resolve it.
You also have the right to complain to the Information Commissioner's Office:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Helpline: 0303 123 1113 · www.ico.org.uk
Changes to this policy
We may update this policy from time to time. The "last updated" date at the top shows when it was last revised. Where changes are significant, we will notify you directly or through a prominent notice on our website.