General Privacy Policy

Last updated: June 2025

This “Privacy Policy” explains how https://sghotbi.com/ (“we” or “us”) collects, uses, discloses, retains, and protects the user’s (“you”,“your”) Personal Data.

This Privacy Policy applies to any website, application, product or service (“Services”) which links to this policy. Please be aware that certain types of Services or target regions (like California) may have separate, more specific privacy policies in place. You are encouraged to read through the specific privacy policies before using those Services.

By continuing to access the Services, you acknowledge that you had the chance to review and read through this Privacy Policy and your continued usage shall be taken as your consenting to the terms and conditions mentioned in this Privacy Policy in its entirety.

You have certain privacy rights which are described under Section 10 of this Privacy Policy. You can exercise those at any time by contacting us.

We reserve the right to modify this Privacy Policy at any time without any prior notification and as such users are advised to refer to the Privacy Policy from time to time so that your usage of our website is in sync with the privacy practices that are prevailing at that time.

1. Definitions

“Affiliates” means third-party companies that participate in our affiliate program and generate website traffic or Data for us.

“Customers” means individuals who request a quotation or quotations.

“Controller” means an organization that determines the purposes and means of processing Personal Data. In some jurisdictions also referred to as “Organization”, “Data User” or “Business”.

“Data Protection Laws” means all applicable laws relating to the processing of Personal Data.

“Business Partners” means companies, partnerships and sole traders who have registered or partnered with us on the website or in any other form; our Business Partners can be Affiliates Registered Traders or Marketplace Providers.

“Marketplace Providers” means companies that own, operate or control electronic marketplace websites and facilitate the sale of products and services of traders.

“Registered Traders” means providers who can offer quotations for the selected products or services shown on our websites.

“Processor” means an organization that processes Personal Data on behalf of and in accordance with the instructions of a Controller. In some jurisdictions also referred to as “Supplier”, “Contractor”, “Service Provider” or “Data Intermediary”.

“Personal Data” (“Data”) has the meaning as used in information security and privacy laws that is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Also known as “Personally Identifiable Information” or “Personal Information”.

2. Who we are

This Privacy Policy applies to all Services offered by “https://sghotbi.com/”.

We have offices that are functioning as ‘Controller’ in relation to your Data:

For the UK: SOHEIL GHOTBI NEZHAD., a office incorporated in London and anther office in Irvine California

3. Our Services

We inform individuals (“Customers”) who are looking to purchase our products by providing a price list that we can offer for the products.

As a Customer: To receive Quotes or more information for the product or services shown on the website, you must fill out the webform (“Quote Form”) with your contact details.
As a Business Partner: To register with our Services, you must complete and submit our published registration form or get registered by us.

4. What Data we collect and how

This section describes how we may collect Data from you directly or automatically:

4.1. CONTACT

You can contact us by telephone, fax, SMS, email, post, chat app or other channels such as social medial portals. We may process your contact Data such as name, email address and phone number. We also may process information provided voluntarily by you (Information Requests).

4.2. OUR SERVICES

4.2.1. FOR CUSTOMERS

To use our services as a customer for purchases above £100,000, you can submit a quote on our website. We may ask you to fill up a Quote Form which may include your name, address, email address, and telephone number (Quotes).

Additionally, we may also ask you to provide additional information about product preferences or requirements (such as what type of home you live in) for reasons of qualification (Qualification). Sometimes we also share IP addresses with Registered Traders or Marketplace Providers to enable them to verify the request.

After your Quote request, our team may follow up via phone to talk you through the Quote options (Follow-Up). For this we may process communications data that may include content and metadata. This Data may be processed for the purposes of communicating with you, call recording and record-keeping, for example, for quality control.

To use our services as a customer for purchases below 100,000 British pounds, you can place an order on our website via the store page.

4.2.2. FOR BUSINESS PARTNERS

You can register with us to use our website or Service as Business Partner. We may ask you to fill up the registration form (Registration) with your company details and other information that may be necessary (like insurance coverage), to create a business account (Accounts) for which you receive also log-in and password. The account may be processed for providing our Services, operating our Affiliate programme, ensuring the security of our website and Services, maintaining back-ups of our databases and communication with you.

We also process billing Data including purchase transactions of our Services (Payments). We process this Data to provide our Services, making Affiliate payments, and keeping proper records of transactions.

We may publish business information on our website, including business listings (Listings).

4.3. MARKETING, ANALYTICS AND WEBSITE ACTIVITIES

You can sign up to receive Our newsletter or other marketing messages or activities (Newsletter).

We may also collect Data from your devices automatically (including mobile devices) that you may use to access our website.

4.4. Additional Disclosures for Specific Jurisdictions

4.4.1 California (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including:

The right to know what personal information we collect and how we use it
The right to request deletion of your data
The right to opt out of the sale or sharing of your personal data
We do not sell your data for monetary compensation, but we may share it with service providers as described above. To exercise your rights, contact us at [sghotbinezhad@gmail.com].

Our Services are not directed to children under 13 (or 16 in the EEA). We do not knowingly collect personal data from minors. If you believe we have collected such data, please contact us immediately and we will delete it.

4.5. Automated Decision-Making and Profiling

We may use limited forms of profiling to offer personalized experiences or price estimates. These profiles are based on your provided data such as location, business type, or energy usage.
However, no decisions with legal or similarly significant effects are made solely by automated means. You always have the right to:

Request human intervention
Express your opinion
Challenge the decision

To exercise these rights, please contact us via [sghotbinezhad@gmail.com].

5. How we use your Data

This section of the Privacy Policy explains how we use the collected Data from you:

5.1 CONTACT

We respond to you (Information Request): When you wish to receive information or advice from us, you can contact us. We use this Data only to respond to your request and provide you with the requested information or advice.

5.2. OUR SERVICES

5.2.1. FOR CUSTOMERS

We may occasionally contact you to participate in surveys to hear more about your experience with us and our Business Partners. The survey may ask for some Data (like gender, age, location), service or product-related questions (like if you made a purchase after a Quote request), or general opinions (like what you think about government schemes). We do this to improve our Service and for market research (including marketing). You can always unsubscribe (object) from receiving those emails (Survey).

5.2.2. FOR BUSINESS PARTNERS

We connect with the relevant Customers (Service): In order to register as Registered Trader or Affiliate, you must complete and submit our registration form or get registered by us. After an account is created, you will have access to our Services. As Marketplace Provider you need to have a contract with us in place.

5.3. FOR MARKETING, ANALYTICS AND WEBSITE ACTIVITIES

We may message you about other Offers (Newsletter): When you use our website, we would like to contact you via email, SMS or telephone about similar products or services to the one you have shown interest in and we think you might like. You can always unsubscribe (withdraw) from receiving those emails, SMS or telephone calls and we will no longer contact you.

We may create custom and lookalike/similar audiences (Custom Audiences): We work with Facebook, Google, and other platforms (“Platforms”) to reach out to you with ads from other offers or to create similar audiences or custom audiences. Data is aggregated and pseudonymized by the Platforms and you can always object to this activity by contacting us.

We may use automated-decision making and profiling (Profiling): We may analyze your Data to build individual profiles, which also includes collection and (statistical) analysis of the Data. Individual profiling is used to predict future interests and provide you with offers that are relevant and interesting for you. Profiling is based on the Data you have provided to us through the contact form and on your behavior when surfing the Internet. You have the right to object to profiling by contacting us.

We may use Technical Data (Website Operations and Analytics): We collect this Data to tune our Services to your needs and to better align structure, navigation and content of the website. This will, for example, facilitate your browsing, store your preferences and make the interaction between you and the website faster and easier.

We may use Listings and Reviews (Listings and Reviews): We may process Data that you post for publication on our website or through our Services, including business listings and reviews. The information may be processed for the purposes of enabling such publication and administering our website and Services.

6. With whom do we share your Data

We share your Data in the following way:

Our Offices: We may share your data with our Revolut Bank. Revolut Bank only plays the role of a payer, but if it asks us for information about your personal data, we are legally obligated to provide it.
Authorities and Courts: We may share your Data if we are obliged to do so by statutory law or instructions from a public authority or court. We may let you know in advance in line with Data Protection Laws.
Corporate Mergers and Acquisition Activity: In the event that https://sghotbi.com/ or its affiliates acquires or is acquired by another business operation, or in the event of a reorganization, merger, or other similar event, your Data may be shared with the acquiring, acquired, or resulting entities.

7. International Transfers of your Data

We comply with UK data protection laws and our certification details are as follows:

Data Protection
Registration Certificate
Sghotbi Ltd
71-75 Shelton Street
Covent Garden
London
WC2H 9JQ
Registration reference: ZB904612
Date registered: 28 May 2025
Registration expires: 27 May 2026

8. Storing and Retention of your Data

We will retain your Data for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with https://sghotbi.com/’s Data Retention Policy, or as otherwise permitted by applicable Data Protection Laws. We generally store non-qualified enquiries for 2 years and qualified enquiries for 7 years subject to exceptions where local retention laws require something else. Where we no longer need your Data, we will delete it in a secure manner (without further notice to you).

9. Security

We implement reasonable security measures to protect Data from loss, misuse, alteration, or destruction. However, since no method of transmission over the Internet, or method of electronic storage is 100% secure, there might be a very small chance that the Data collected by us may be compromised. If you believe that any Data has been compromised, please contact us. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with the provisions of the applicable law.

10. Legal grounds for processing

For Europe: Under the (UK) GDPR, ‘Controllers’ are obligated to have a valid lawful basis for each processing activity that they undertake. The table below sets out our lawful basis for each processing activity.

Legal Grounds of https://sghotbi.com/

Information Requests: Article 6 (1) (b) – Performance of Contract
Provision of Service: Article 6 (1) (b) – Performance of Contract. For example, we transfer your Data and connecting you with Business Partners so you can receive the requested Quotes.
Review and Customer Satisfaction: Article 6 (1)(b) – Performance of contract.
Survey: Article 6 (1) (f) – Legitimate Interest.
Marketing (like newsletter): Article 6 (1) (a) – Consent
To create custom and similar audiences: Article 6 (1) (f) – Legitimate Interest
Automated decisions and profiling: Article 6 (1)(a) or (f) – Consent or Legitimate Interest
Listings and Reviews: Article 6 (1) (a) – Consent
Usage of technical information (Website Operations and Analytics): Article 6 (1)(a) or (f) – Consent or Legitimate Interest
Compliance with legal obligation: Article 6 (1) (c)- Legal Obligation

Legal Grounds of Business Partners

After receiving your Data, Business Partners act as independent ‘Controllers’ of your Data. To continuously process your Data after transfer of sghotbi.com (for example contacting you by telephone, text/SMS or email based on your Quote request) they also need a legal ground. This may be Consent, Contract or Legitimate Interest based on their own choice. You will find more information about how Business Partners process your Data in their Privacy Policy and Terms. For example, HomeLogic responds to a Quote as received by sghotbi.com on the basis of as explained in their own privacy policy: https://www.homelogic.co.uk/privacy

11. Your privacy rights

If you are based within the UK, EEA or within another jurisdiction having similar Data Protection Laws, in certain circumstances you have the following rights:

Right of access: The right to be told how we use your Data and obtain access to your Data;

Right to rectification: The right to have your Data corrected. If we hold any Data about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date;

Right to deletion and restriction: The right to have your Data deleted or place restrictions on processing your Data;

Right to data portability: The right to have any Data you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible;

Right to object: The right to object to the processing of your Data e.g., for direct marketing purposes;

Right to withdraw consent: Where the processing of your Data is based on your consent, the right to withdraw that consent. If you withdraw your consent to the use of your Data for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our websites and Service;

Right in Relation to Automated Decision-making and Profiling: The right to object to any decisions based on the automated processing of your Data, including profiling;

Right to lodge complaint: The right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g., in the UK, the Information Commissioner’s Office). You can find a good overview of EU data protection authorities via the website of the European Data Protection Board. Many US states have their own data and security laws that are overseen by state attorney general or other authorities.

12. Contact

For further information about our Privacy Policy or our processing of Data about you or if you have any queries about your rights under local law, how to update your records, or how to obtain a copy of the Data that we hold about you, or to exercise any other rights given to users under applicable Data Protection Laws please contact us:

sghotbi.com
Legal Department
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

Our location:

167 Elkhorn Irvine CA United States 92618

Online:

You can contact us via:

support@sghotbi.com

sghotbinezhad@gmail.com

If you like to contact one of our local offices via phone, you can do so via https://sghotbi.com/