Privacy Policy

Evolution One Ltd (“Evolution One”, “we”, “us”) is committed to protecting your privacy. This policy explains what personal data we collect, how we use it, who we share it with, and the rights you have under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Please read it carefully.

1. Who We Are

Evolution One Ltd is the data controller responsible for your personal data. We are registered in England and Wales (company number 17103954). Our registered office is Depleach Hall, Wilmslow Road, Cheadle, England, SK8 1DR. Our VAT number is GB 518016806.

We are registered with the Information Commissioner’s Office (ICO) under registration number [ICO REGISTRATION NUMBER].

For any privacy matter, you can contact us at privacy@evolutionone.co.uk, or by writing to us at our registered office address.

2. The Personal Data We Collect

Depending on how you interact with us, we may collect:

• Identity and contact data: your name, delivery and billing address, email address, and phone number.
• Order and transaction data: details of the Strutt-branded product, accessory, spare part or service you ordered, including the Strutt EV1C where applicable, payments made, deposit and balance records, and delivery information.
• After-sales, warranty and technical support data: proof of purchase, order details, serial numbers, photographs, videos, diagnostic information, product condition, usage history, mileage, power-on time, service history, repair notes, fault reports, replacement part details and communications needed to assess or resolve support issues.
• VAT Relief and health-related data: where you claim VAT Relief for an eligible product or service, we collect the information needed to confirm that you are chronically sick or disabled and that the purchase is for your own personal or domestic use, as required by HMRC. This may include special category data and we handle it with particular care.
• Communications data: records of your contact with us, including emails, calls, messages, test-drive enquiries, support requests and aftercare correspondence.
• Marketing data: your preferences for receiving marketing from us, and your engagement with our communications.
• Technical data (website): your IP address, browser type, and how you use our website, collected through cookies (see our Cookie Policy).

3. How We Use Your Data and Our Legal Basis

Under UK GDPR, we must have a lawful basis for using your personal data. We use your data as follows:

• To process and fulfil your order, arrange delivery, and provide aftercare – lawful basis: performance of a contract with you.
• To handle warranty claims, diagnose support issues, coordinate repairs, replacement parts, technical inspections and manufacturer after-sales support with Strutt or authorised service partners – lawful basis: performance of a contract and our legitimate interests.
• To assess and process VAT Relief claims and meet our tax obligations – lawful basis: legal obligation and, where special category data is involved, substantial public interest in meeting HMRC VAT Relief requirements.
• To take payment and prevent fraud – lawful basis: performance of a contract and our legitimate interests.
• To send you marketing communications – lawful basis: your consent, which you can withdraw at any time.
• To keep records and comply with legal, regulatory, tax, safety and accounting requirements – lawful basis: legal obligation.

4. Special Category Data (Health Information)

When you claim VAT Relief, we may collect information about your health, disability or chronic sickness. This is “special category data” under UK GDPR and receives extra protection.

We collect only what is necessary to assess and evidence the VAT Relief claim. We store it securely, restrict access to it, and retain it only for as long as required for tax and accounting purposes, including HMRC record-keeping requirements.

We do not use your health information for marketing or any purpose other than assessing and processing your VAT Relief claim, keeping required records, and meeting our legal obligations.

5. Who We Share Your Data With

We share your data only where necessary, and only with organisations that are required to keep it secure. These include:

• Strutt, as the company, brand owner and manufacturer: for warranty claims, technical support, repairs, replacement parts, product updates, product safety, service coordination and manufacturer after-sales support.
• Authorised service partners or repair providers: where needed to inspect, diagnose, repair, replace or service a Product.
• Delivery partners, such as FedEx and other couriers: to deliver your products, handle collections, returns or warranty logistics.
• Payment providers, such as Stripe and PayPal: to process payments securely. We do not store your full card details ourselves.
• Software and IT providers: including Odoo (our customer and order management system) and Microsoft (our email and office systems), who process data on our behalf as our processors.
• Professional advisers and authorities: such as our accountants, HMRC, the ICO, Trading Standards, product-safety authorities, insurers, or other regulators where we are legally required or reasonably required to share data.

We never sell your personal data. We do not share your data with third parties for their own marketing purposes.

6. Marketing

Where you have agreed, we may send you marketing communications by email or SMS about our products, offers, events, test-drive opportunities and news.

You can opt out at any time. Every marketing email includes an unsubscribe link, every marketing SMS includes opt-out instructions, and you can also email us at privacy@evolutionone.co.uk to be removed from our marketing lists.

Opting out of marketing will not stop us sending you essential communications about an order you have placed, such as delivery updates, invoices, warranty information, repair updates or safety-related communications.

7. International Transfers

We aim to keep your personal data within the UK or European Economic Area (EEA). Where any of our service providers process data outside the UK or EEA, we ensure appropriate safeguards are in place, such as the UK’s International Data Transfer Agreement or other approved mechanisms, so your data remains protected.

8. How Long We Keep Your Data

We keep your personal data only as long as necessary:

• Order, transaction and accounting records: six years after the end of the relevant tax year, to meet HMRC and accounting requirements.
• VAT Relief declarations and related evidence: six years, or any longer period required by HMRC.
• Warranty, aftercare, repair, diagnostic, technical support and product safety records: for the duration of the applicable warranty period, plus a reasonable period afterwards so we can handle claims, service history, regulatory queries and safety matters.
• Marketing data: until you opt out, or after a period of inactivity.

When data is no longer needed, we securely delete or anonymise it.

9. Your Rights

Under UK GDPR, you have the following rights:

• The right to be informed about how we use your data.
• The right of access – to request a copy of the data we hold about you.
• The right to rectification – to have inaccurate data corrected.
• The right to erasure – to ask us to delete your data, where there is no overriding legal reason for us to keep it.
• The right to restrict processing – to ask us to limit how we use your data in certain circumstances.
• The right to data portability – to receive your data in a portable format.
• The right to object – to object to certain processing, including direct marketing.
• Rights relating to automated decision-making – we do not make decisions about you based solely on automated processing.

To exercise any of these rights, contact us at privacy@evolutionone.co.uk. We will respond within one month. There is usually no charge.

10. Cookies

Our website uses cookies to help it function and to understand how visitors use it. You can control cookies through your browser settings and through any cookie banner shown on our website. Full details are set out in our Cookie Policy, available on our website.

11. Data Security

We take appropriate technical and organisational measures to keep your data secure, including restricted access, secure systems and encryption where appropriate. While no system can be guaranteed completely secure, we work to protect your data and to notify you and the ICO of any serious data breach where we are legally required to do so.

12. Complaints

If you have any concerns about how we handle your personal data, please contact us first at privacy@evolutionone.co.uk so we can try to resolve the matter.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection, at www.ico.org.uk or by calling 0303 123 1113.

13. Changes to This Policy

We may update this privacy policy from time to time. The latest version will always be available on our website, with the effective date shown below.

 

Version 1.2 – effective May 2026.

Evolution One Ltd is registered in England and Wales (company number 17103954). Registered office: Depleach Hall, Wilmslow Road, Cheadle, England, SK8 1DR. VAT number GB 518016806. Authorised UK retailer of Strutt-branded mobility products.