SITEPHOENIX PRIVACY NOTICE

Clear aboutyour information.

This notice explains what personal information SitePhoenix uses, where it comes from, why we use it and the choices available to you.

PLAIN-ENGLISH PRIVACY INFORMATION

We use the information needed to run SitePhoenix, work with clients and make proportionate business contact.

SitePhoenix is a business-to-business website transformation service operated by Tom Kinnaird as a sole trader. This notice covers information relating to business contacts, prospects, enquiries, clients, website visitors and people making payments.

We do not sell personal information. If you tell us not to use your information for direct marketing, we will stop and may keep only the minimum record needed to respect that choice.
01

Who is responsible for your information

Tom Kinnaird trading as SitePhoenix is the data controller for the personal information described in this notice. You can contact SitePhoenix at hello@sitephoenix.co.uk.

02

Information we may use

Depending on how we interact with you, we may use your name, business name, job role, business email address, business telephone number, website address, public business profile information, correspondence, project requirements, feedback, payment status and transaction references.

When you visit the website, hosting and security systems may also process limited technical information such as IP address, browser or device information, requested pages, timestamps and security logs.

We do not need or intentionally collect special-category personal information for normal SitePhoenix work.

03

Where the information comes from

Some information comes directly from you when you email us, reply to SitePhoenix, become a client, provide project material or make a payment.

For business prospecting, we may also use information that businesses or business contacts have made publicly available through company websites, search results, business directories, review platforms and public business social-media profiles. We may record enough information to verify the business, understand whether our service appears relevant and avoid repeatedly researching the same company.

04

Why we use information and our lawful bases

We use personal information to answer enquiries, discuss and agree project scope, carry out website work, administer payments, keep appropriate business records, protect the website and systems, resolve questions or disputes, and manage relevant business-to-business outreach.

Depending on the activity, our lawful basis may be taking steps at your request before entering a contract, performing a contract, complying with a legal obligation, or our legitimate interests in operating and growing SitePhoenix, maintaining security, keeping proportionate business records and contacting relevant business prospects.

Where we rely on legitimate interests, we consider whether the use is necessary and proportionate and balance our interests against the individual’s rights and reasonable expectations.

05

Business-to-business prospecting and direct marketing

SitePhoenix may identify established UK businesses whose public website appears not to reflect the strength of the business and may contact an appropriate business contact about our service.

Personal information used for direct marketing remains subject to UK data-protection law even when it is used in a business context. We rely on legitimate interests only where that is appropriate, and we also consider the Privacy and Electronic Communications Regulations (PECR). Where PECR requires consent for a particular type of electronic marketing, we will not use legitimate interests to bypass that requirement.

If we obtain a named business contact’s personal information from public sources rather than directly from that person, we provide or make available appropriate privacy information within the period required by law, normally by linking to this notice in or around our contact.

You can object to direct marketing at any time by replying to the message or emailing hello@sitephoenix.co.uk. We will stop direct marketing to you. We may retain a minimal suppression record so that we do not contact you again by mistake.

06

Payments

SitePhoenix uses Stripe to process card and other supported electronic payments. Stripe may collect payment information directly from you under its own privacy terms. SitePhoenix normally receives confirmation of the payment, customer and business details supplied at checkout, transaction references and limited payment information rather than your full card number.

We use payment information to administer the project, reconcile payments, issue or support receipts and refunds, prevent fraud and maintain accounting records.

07

Who we share information with

We may use trusted service providers where necessary to operate the business, including email and productivity services, website hosting and security infrastructure, payment processing, domain or hosting providers involved in an agreed client project, and professional advisers where genuinely needed.

We disclose only the information reasonably needed for the relevant purpose. We may also disclose information where required by law, regulation, court order or to establish, exercise or defend legal rights.

08

International processing

Some technology providers used by SitePhoenix operate internationally. Where personal information is transferred outside the United Kingdom, we expect the relevant provider or transfer to use an appropriate UK data-protection safeguard where the law requires one.

09

How long we keep information

We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, including project delivery, business administration, legal or tax obligations, security, dispute resolution and the establishment or defence of legal claims.

Prospecting information is reviewed and should not be kept indefinitely where it is no longer relevant. A minimal record may be retained after an objection or opt-out so that the preference continues to be respected.

10

Your data-protection rights

Depending on the circumstances, you may have rights to ask for access to your personal information, correction, deletion, restriction of use, portability, or to object to certain processing. Where processing is based on consent, you can withdraw that consent.

You have an absolute right to object to the use of your personal information for direct marketing. To exercise a right, email hello@sitephoenix.co.uk. We may need to verify your identity before acting on a request.

11

Cookies and website technical data

SitePhoenix does not currently use advertising or behavioural-tracking cookies on this website. Our hosting and security infrastructure may process limited technical data needed to deliver, protect and troubleshoot the site.

If we introduce optional analytics, advertising or other non-essential tracking in future, we will update this notice and use consent where required.

12

Security

We take reasonable organisational and technical steps to protect personal information, including limiting access to information and using established providers for core business, hosting, email and payment functions. No internet or storage system can be guaranteed completely secure.

13

Questions and complaints

Please contact SitePhoenix first at hello@sitephoenix.co.uk if you have a privacy question or concern and we will try to resolve it.

You also have the right to complain to the UK Information Commissioner’s Office (ICO). Information about making a complaint is available at ico.org.uk/make-a-complaint.

14

Changes to this notice

We may update this privacy notice when SitePhoenix changes its systems, providers or ways of using information, or when legal requirements change. The current version and effective date will be shown on this page.

VERSION 1.0 · 3 SEPTEMBER 2026

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