01Who we are
This privacy notice explains how COULLWORKS collects and uses personal data through coullworks.com. COULLWORKS is the trading name of DC, a sole trader based in North Wales, United Kingdom. DC is the data controller for the personal data described here.
Contact for anything in this notice: privacy@coullworks.com. There is no data protection officer; as a sole trader, DC handles privacy requests personally.
02The personal data we collect
- Identity and contact data: your name and email address
- Enquiry data: what you tell us about your business or project when you book a call or send a message
- Booking data: the date and time of a call and the answers you give in the booking form
- Usage data: pages viewed, approximate location by country, device and browser type, and how you arrived, only if you accept analytics
- Technical data: IP address, browser and time of request, kept briefly in server logs
We do not collect special category data (such as health or ethnicity) and we do not knowingly collect data from children.
03How we collect it
- Directly from you: when you book a call, use a contact form or email us
- Automatically: through server logs, and through Google Analytics cookies only after you accept them
- From third parties: from Calendly when you book a call through it
04Why we use it, and our lawful basis
| Purpose | Lawful basis (UK GDPR Article 6) |
|---|
| Replying to enquiries and arranging a call | Legitimate interests: responding to people who contact the business; or steps you ask us to take before entering a contract |
| Providing services you hire us for, and invoicing | Performance of a contract |
| Keeping records for tax and accounts | Legal obligation |
| Measuring how the site is used (Google Analytics) | Consent, which you can withdraw at any time |
| Keeping the site secure and working | Legitimate interests: operating a safe website |
05Who we share it with
We share personal data only with the service providers who run the site and bookings on our behalf, under contracts that require them to protect it:
| Recipient | What for |
|---|
| Vercel Inc. | Hosting the website and its server logs |
| Calendly LLC | Taking call bookings |
| Google LLC | Analytics, only if you accept |
| Our email provider | Receiving and replying to messages |
We do not sell personal data or share it with anyone for their own marketing.
06International transfers
Some of these providers process data outside the UK, including in the United States. Where they do, the transfer is protected by UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework for certified companies) or by the International Data Transfer Addendum to the EU standard contractual clauses.
07How long we keep it
| Data | Retention |
|---|
| Enquiries that do not become work | Up to 12 months, then deleted |
| Client and invoicing records | Six years after the end of the financial year they relate to, as UK tax law requires |
| Analytics data | According to the retention period set in Google Analytics |
| Server logs | Short-lived, as set by the hosting provider |
08Your rights
Under UK data protection law you have the right to:
- Be informed: about how your data is used, which is what this notice does
- Access: a copy of the personal data we hold about you
- Rectification: have inaccurate data corrected
- Erasure: have your data deleted where there is no reason to keep it
- Restrict processing: ask us to limit how we use your data
- Data portability: receive data you gave us in a common format
- Object: to processing based on legitimate interests
- Withdraw consent: for analytics at any time, using Cookie settings at the foot of every page
To use any of these rights, email privacy@coullworks.com. We will respond within one month, and there is no charge in most cases. We may ask you to confirm your identity first.
09Automated decision-making
We do not make decisions about you by automated means, and we do not profile you.
10Do you have to give us your data?
No. You can read the site without giving any personal data. If you want to book a call or send a message, we need your name and email to reply.
11Cookies
The site sets one optional analytics cookie, only after you accept it. The full detail is in the cookie policy at /cookies.
12How to complain
If you are unhappy with how we have handled your data, please tell us first at privacy@coullworks.com so we can put it right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator: ico.org.uk/make-a-complaint, or 0303 123 1113.
13Changes to this notice
We review this notice when the way we use personal data changes. The date at the top of the page shows when it was last updated.