Toshakhana Limited

1. Introduction
Toshakhana Limited (“we”, “us”, or “our”) is committed to protecting the privacy and security of your personal and professional data. This policy outlines our practices regarding the collection, use, and safeguarding of information in accordance with the UK GDPR and the Data Protection Act 2018.

2. The Types of Data We Collect
We collect data to provide our wholesale and bespoke jewellery services and to meet our regulatory obligations. This includes:
Identity Data: Names, titles, and copies of government-issued ID where required for high-value transactions.
Contact Information: Professional or residential addresses, email addresses, and telephone numbers.
Financial Data: Bank account details for electronic settlement.
Compliance Documentation: Information required for Anti-Money Laundering (AML) and Know Your Customer (KYC) due diligence.

3. Legal Basis for Processing
We only process data where there is a legal basis:
Contractual Necessity: To perform our obligations under trade agreements.
Legal Obligation: To comply with UK AML/CTF regulations and the Proceeds of Crime Act 2002.
Legitimate Interests: For the prevention of fraud and maintaining professional business records.

4. Data Sharing and Third Parties
We do not sell or trade your data. We only share information with:
Regulatory & Legal Authorities: HMRC or law enforcement bodies when required by law.
Professional Partners: Verified trade counterparties or secure logistics providers where necessary to complete a transaction.
Service Providers: Professional advisors including auditors, bankers, and insurers.

5. Data Retention and Security
We employ rigorous technical measures to protect your data. In accordance with UK financial regulations, we are legally required to retain KYC and transaction records for a minimum of five years after the conclusion of a business relationship.

6. Your Legal Rights
You have the right to request access to your data, correction of inaccuracies, or erasure of your information, subject to certain legal overrides (such as our statutory requirement to maintain AML records).

7. Contact Information
For any enquiries regarding this policy, please contact:
Data Compliance Officer | info@toshakhana.uk
Toshakhana Limited, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ