1. Who we are
In this policy, "we", "us" and "our" refer to Westerly Digital.
We are the data controller for the personal information described in this policy, except where we process information on behalf of our clients (see section 5).
If you have any questions about this policy or how we handle your information, please contact us at hello@westerlydigital.co.uk.
2. Information we collect
Information you give us
We collect information you provide when you contact us, request a quote or free review, become a client or otherwise communicate with us. This may include:
- your name, business name and job title;
- contact details such as your email address, phone number and postal address;
- your website address and details about your project, business or enquiry;
- billing information such as invoicing address and payment records (we do not store full card details);
- the content of emails, messages, calls and meeting notes;
- any other information you choose to share with us.
Information collected automatically
When you visit our website, our hosting provider automatically records limited technical information in server logs, such as your IP address, browser type, the pages requested and the date and time of your visit. This is used to keep the website secure and working properly.
If you accept analytics cookies, we also collect information about how you use our website through Google Analytics, such as the pages you visit, how long you spend on them, how you arrived at our site, your approximate location (city or region) and the type of device you use. See section 10 and our cookie policy.
Information from other sources
We may receive information about you from publicly available sources, such as Companies House or your business website, or from people who refer you to us.
3. How we use your information
We use personal information to:
- respond to enquiries, provide quotes and carry out free website reviews you request;
- provide our services, including designing, building, hosting, maintaining and optimising websites;
- manage our relationship with clients, including communication, invoicing and payments;
- provide support and respond to requests;
- keep our website and services secure, and prevent fraud and spam;
- understand how our website is used so we can improve it (only with your consent);
- send occasional updates or marketing where you have agreed or where the law otherwise permits (see section 12);
- comply with legal, tax and accounting obligations;
- establish, exercise or defend legal claims.
4. Our lawful bases
Under the UK General Data Protection Regulation (UK GDPR), we must have a lawful basis for using personal information. We rely on:
- Contract: where we need to use your information to provide services you have asked for, or to take steps at your request before entering into a contract (for example, preparing a quote).
- Legitimate interests: where we use information to run and grow our business, respond to enquiries, keep our systems secure and maintain business records, provided this does not override your rights and interests.
- Consent: for analytics and marketing cookies, and for certain marketing communications. You can withdraw consent at any time.
- Legal obligation: where we must keep or share information to comply with the law, such as tax and accounting rules.
5. Clients and client data
When we host, maintain or develop websites for clients, we may have access to personal information about our clients' own customers, for example enquiries submitted through a client's contact form. In these cases, our client is the data controller and we act as a data processor, processing that information only on our client's documented instructions and in line with our terms of business, which include data processing terms. If you have questions about how one of our clients uses your information, please contact that business directly.
6. Who we share information with
We do not sell your personal information. We share it only where necessary with trusted service providers who help us run our business, including:
- Hosting providers that host our website and our clients' websites;
- Email and productivity providers that we use to communicate and store documents;
- Google, for analytics (only where you have consented) and business tools;
- Accounting, invoicing and payment providers;
- Professional advisers such as accountants, insurers and legal advisers;
- Subcontractors or specialists, such as photographers, where needed for your project and agreed with you.
These providers may only use your information to provide services to us and must keep it secure. We may also share information if required by law, to protect our rights, or as part of a sale or restructure of our business.
7. International transfers
Some of our service providers are based outside the UK or may process information outside the UK, for example in the European Economic Area or the United States. Where this happens, we make sure appropriate safeguards are in place, such as UK adequacy regulations, the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, or the UK Extension to the EU-US Data Privacy Framework.
8. How long we keep information
We keep personal information only for as long as we need it for the purposes described in this policy:
- Enquiries that don't lead to work: up to 24 months after our last contact, so we can refer back to previous conversations.
- Client records and contracts: for the duration of our relationship and up to 6 years afterwards, in line with limitation periods for legal claims.
- Financial and tax records: at least 6 years from the end of the financial year they relate to, as required by HMRC.
- Analytics data: up to 14 months in Google Analytics.
- Server logs: typically up to 30 days, depending on our hosting provider.
- Marketing preferences: until you unsubscribe, after which we keep a suppression record so we don't contact you again.
9. Keeping information secure
We use appropriate technical and organisational measures to protect personal information, including encrypted connections (HTTPS), secure hosting, strong passwords and two-factor authentication, access controls, regular software updates and backups. No method of transmission over the internet is completely secure, but we work hard to protect your information and will notify you and the ICO of any breach where we are legally required to do so.
10. Cookies and analytics
Our website uses essential storage to remember your cookie choices. With your consent, we use Google Analytics to understand how visitors use our site. Analytics does not run until you accept analytics cookies, and you can change your choice at any time using the "Cookie settings" link in our website footer. Full details are in our cookie policy.
11. Your rights
Under UK data protection law, you have the right to:
- Access the personal information we hold about you;
- Rectification: ask us to correct inaccurate or incomplete information;
- Erasure: ask us to delete your information in certain circumstances;
- Restriction: ask us to limit how we use your information in certain circumstances;
- Object to our use of your information based on legitimate interests, and to direct marketing at any time;
- Data portability: receive information you gave us in a portable format, in certain circumstances;
- Withdraw consent at any time, where we rely on consent;
- not be subject to decisions based solely on automated processing that significantly affect you (we do not make such decisions).
To exercise any of these rights, contact us at hello@westerlydigital.co.uk. We will respond within one month. There is usually no charge. We may need to ask for proof of identity before responding.
12. Marketing
We may occasionally send existing clients and people who have asked to hear from us updates about our services, useful guides or offers. We will only send electronic marketing where you have consented or where you are an existing client and we are promoting similar services, as permitted by the Privacy and Electronic Communications Regulations (PECR). Every marketing email includes a simple way to unsubscribe, and you can opt out at any time by contacting us.
13. Children
Our website and services are intended for businesses and adults. We do not knowingly collect personal information from children under 13.
14. Other websites
Our website contains links to other websites, including client websites in our portfolio. We are not responsible for the privacy practices of other websites, so please read their privacy policies.
15. Complaints
If you have concerns about how we handle your personal information, please contact us first so we can try to put things right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk/make-a-complaint or by calling 0303 123 1113.
16. Changes to this policy
We may update this policy from time to time, for example if our services or the law change. The latest version will always be on this page, with the date it was last updated shown at the top.