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Privacy Policy

Draft — for legal review. This policy is written to be aware of the UK GDPR and the Data Protection Act 2018, but it has not been reviewed by a solicitor. Resolve every [PLACEHOLDER] and have it checked before relying on it.

Last updated: [PLACEHOLDER-date]

1. Who we are

Penolta Ltd ("we", "us", "our") is the data controller for personal data processed through this website. We are registered in england & wales under company number 17289483, with our registered office at 128 City Road, London, EC1V 2NX, United Kingdom.

For any privacy question, or to exercise your rights, contact us at [PLACEHOLDER-email].

2. Scope

This policy covers personal data we process in connection with this website and direct enquiries to us. Our products (including Breaker) are governed by their own privacy notices.

3. What we collect, and why

This is a static, informational website. It sets no cookies, runs no third-party analytics or advertising, and self-hosts its fonts, so simply browsing it does not send your data to third parties.

  • Email correspondence. If you email us, we process the contents of your message and your contact details to respond and keep a record of the exchange. Lawful basis: our legitimate interests in handling enquiries, and steps toward a contract where relevant.
  • Server and security logs. Our web server records technical information such as IP address, browser/user-agent, requested pages and timestamps, to operate the site and protect it against abuse. Lawful basis: our legitimate interests in security and reliability.

4. Who we share data with

We do not sell your personal data. We may share it with service providers who process data on our behalf (for example, our hosting and email providers), and with authorities where we are legally required to.

5. International transfers

[PLACEHOLDER]: state whether any processor transfers data outside the UK, and the safeguard relied on (e.g. UK adequacy regulations or the International Data Transfer Agreement).

6. How long we keep it

We keep personal data only as long as necessary for the purpose it was collected. Email correspondence is retained for [PLACEHOLDER: e.g. 24 months] unless a longer period is required. Server logs are retained for [PLACEHOLDER: e.g. 90 days].

7. Your rights

Under the UK GDPR you have the right to access your personal data, and to request its rectification or erasure, the restriction of or objection to processing, and data portability where applicable. You can also withdraw consent where processing relies on it.

To exercise any of these, email [PLACEHOLDER-email]. We will respond within one month. If you are unhappy with how we handle your data, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk.

8. Changes to this policy

We may update this policy from time to time. The current version is always the one published here, with the date shown above.