Privacy Policy

About this policy

This policy explains how Pontiro Ltd processes personal data through the pontiro.com website. Pontiro Ltd is the data controller for personal data collected through this site. This policy does not cover data processing performed under separate client engagements, which is governed by the relevant data processing agreement.

Who we are

Pontiro Ltd, a company incorporated in England and Wales.
Registered office: Alacrity House, Newport NP20 1HG, United Kingdom.
Contact: [email protected]

What we collect and why

Information you provide via the contact form

When you submit our contact form, we collect the name, email address, organisation, area of interest, and message you provide. We use this information to respond to your enquiry and follow up where appropriate.

Analytics data (only with your consent)

If you accept analytics cookies, we use Google Analytics 4 to understand how visitors use the site so we can improve it. This collects information including pages visited, approximate location (derived from your IP, which is anonymised), device and browser type, and how you arrived at the site. Without consent, no analytics data is collected.

Server logs

Like most websites, our hosting infrastructure records standard request information including IP address, request time, and user agent. These logs are used for security and operational reliability and are retained for a limited period.

Lawful basis for processing

• Contact form data: processed on the basis of your consent (UK GDPR Article 6(1)(a)) when you submit the form, with our legitimate interest (Article 6(1)(f)) in operating and improving our services.
• Analytics data: processed only on the basis of your consent (UK GDPR Article 6(1)(a)). Refusing or revoking consent stops this processing.
• Server logs: processed on the basis of our legitimate interest (Article 6(1)(f)) in maintaining a secure and reliable website.

Who we share data with

We use a small number of trusted third-party processors to operate the site:

• Google LLC (Google Analytics 4): processes analytics data on our behalf when you accept analytics cookies. Data may be transferred to the United States under Google's standard contractual clauses and the EU-US Data Privacy Framework.
• Discord Inc.: contact form submissions are delivered to a private Pontiro channel via webhook, which means form contents pass through Discord's infrastructure. Discord is based in the United States.
• Our hosting provider: serves the website and processes server logs as described above.

We do not sell personal data and do not share it for advertising purposes.

International transfers

Some of the processors above are located outside the UK. Where personal data is transferred outside the UK, we rely on appropriate safeguards including the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the UK extension to the EU-US Data Privacy Framework, depending on the processor.

How long we keep data

• Contact form submissions: retained for up to 24 months after the last contact, then deleted unless we have an ongoing commercial relationship.
• Analytics data: retained according to Google Analytics' default retention setting, currently 14 months.
• Server logs: retained for a limited period (typically up to 30 days) for security and operational purposes.

Your rights

Under UK GDPR, you have the following rights in relation to your personal data:

• Access: request a copy of the personal data we hold about you.
• Rectification: ask us to correct inaccurate or incomplete data.
• Erasure: ask us to delete your data, where applicable.
• Restriction: ask us to limit how we use your data.
• Objection: object to processing based on legitimate interest.
• Portability: receive your data in a machine-readable format.
• Withdraw consent: where processing is based on consent, you can withdraw it at any time.

To exercise any of these rights, email [email protected]. We will respond within one month.

Cookies

Details of the cookies we use, and how to change your preferences, are in our cookie policy.

Complaints

If you have a concern about how we have handled your personal data, please contact us first so we can try to resolve it. You also have the right to lodge a complaint with the UK Information Commissioner's Office at ico.org.uk.

Changes to this policy

We may update this policy from time to time. The date at the top reflects the most recent version.