Privacy policy

Witsberry Ltd ("we", "us", or "our") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Controller: Witsberry Ltd is the controller and responsible for your personal data.
Company registration number: 13858949 (England & Wales)
Registered office: 128 City Road, London, EC1V 2NX, United Kingdom

We may collect, use, store and transfer different kinds of personal data about you, grouped as follows:

• Identity data: includes first name, last name, username or similar identifier.
• Contact data: includes billing address, delivery address, email address and telephone numbers.
• Technical data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage data: includes information about how you use our website, products and services, collected in aggregate via Vercel Analytics.
• Financial data: if you become a client, invoicing and payment details, processed by our payment processor. We do not store full card numbers ourselves.
• Project data: if you become a client, information you provide about your business and product needed to scope and deliver the work, handled under the confidentiality terms in our Terms of Service.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, for example understanding how the website is used so we can improve it.
• Where we need to comply with a legal or regulatory obligation.

We do not sell your personal data, and we do not use it for automated decision-making that produces legal or similarly significant effects on you.

The website uses Vercel Analytics to understand aggregate usage, which pages, roughly how many visitors, not to build an individual advertising profile of you. We do not run third-party ad-tracking pixels. If this changes, this policy will be updated first.

We share personal data with a small number of service providers who process it on our behalf, under contract, and only for the purpose we specify:

• Our CMS provider, for blog and review content.
• Our hosting provider, to run the website and applications we build.
• Our payment processor, for client invoicing.
• Our email and calendar tools, to respond to enquiries and book calls.

Some of these providers may process data outside the UK/EEA. Where they do, we rely on appropriate safeguards, such as Standard Contractual Clauses, to ensure your data stays protected to UK standards. We do not otherwise sell or rent your personal data to third parties.

We keep enquiry and marketing data for as long as you remain subscribed or for up to 3 years of inactivity, whichever is shorter, then delete or anonymize it. Client project and invoicing data is kept for 7 years after the engagement ends, to meet our UK tax and accounting obligations, then deleted.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. In the event of a data breach affecting your personal data, we will notify affected individuals and the ICO without undue delay, as required by UK GDPR.

Under UK data protection law, you have rights in relation to your personal data, including the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ico.org.uk) if you believe we have not handled your data properly, though we'd appreciate the chance to put it right first.

Our services are directed at businesses and professionals, not children. We do not knowingly collect personal data from anyone under 16.