Last updated: [PLACEHOLDER: date]
1. Introduction and Controller Identity
This Privacy Policy explains how [PLACEHOLDER: Spray Foam Removal Company Ltd, Company Number XXXXXXXX, Registered Address: TBD] (“we”, “us”, “our”) collects, uses, stores and shares your personal data when you visit or use our website at sprayfoamremovalcompany.co.uk (the “Website”).
We are the data controller for the personal data you provide to us through the Website. This means we are responsible for deciding how and why your personal data is processed.
We process your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
If you have any questions about this policy or about how we handle your personal data, please contact us at [PLACEHOLDER: hello@sprayfoamremovalcompany.co.uk].
2. What Personal Data We Collect
Depending on how you interact with our Website, we may collect the following categories of personal data:
- Contact information: name, email address, telephone number and postcode
- Property information: property type, approximate loft area, type of spray foam insulation (if known)
- Enquiry information: your reason for enquiry (for example, mortgage problem, equity release, property sale, general research), your level of urgency, and any additional information you choose to provide in the free-text field of the enquiry form
- Technical data: IP address, browser type and version, operating system, referring URL, pages visited, and time and date of your visit — collected automatically when you browse the Website
- Cookie data: see Section 10 (Cookies) below
We do not collect special category data (such as health information, financial account details or government identification numbers) through our Website forms.
3. How We Collect Your Data
We collect personal data through the following means:
- Enquiry and contact forms on the Website — when you submit a request for a quote, request a callback, or send us a message
- Telephone calls — when you call us directly; calls may be recorded for training and quality purposes [PLACEHOLDER: confirm call recording policy and notify callers accordingly]
- Cookies and analytics tools — collected automatically when you visit the Website; see Section 10 for details
4. Lawful Basis for Processing
We rely on the following lawful bases under UK GDPR to process your personal data:
- (a) Consent (Article 6(1)(a) UK GDPR) — where you have ticked the consent checkbox on our enquiry or callback form to consent to us contacting you and, where applicable, sharing your details with vetted partner contractors for the purpose of providing removal quotes. You may withdraw your consent at any time by contacting us at [PLACEHOLDER: hello@sprayfoamremovalcompany.co.uk]. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.
- (b) Legitimate interests (Article 6(1)(f) UK GDPR) — we process certain technical and usage data on the basis of our legitimate interests in operating, improving and securing the Website, and in understanding how our content is used, where this does not override your rights and interests.
5. How We Use Your Data
We use the personal data we collect for the following purposes:
- To respond to your enquiry, question or callback request
- To match you with vetted specialist spray foam removal contractors operating in your area who can provide a quote for your project
- To send you information about our services that is relevant to your enquiry, where you have consented to receive it
- To improve the content and functionality of the Website through analysis of aggregated, anonymised usage data
- To comply with our legal and regulatory obligations
We will not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.
6. Sharing Your Data
We share your personal data with the following categories of third party, only where necessary and proportionate:
- Vetted partner spray foam removal specialists — where you have submitted an enquiry or requested a quote, we share the relevant details (name, contact information, postcode and property information) with one or more vetted contractors in our partner network who operate in your area, for the purpose of providing you with a removal quote. We require all partner contractors to treat your data confidentially and to use it only for the purpose for which it was shared.
- Analytics and technology providers — we use third-party tools to operate and analyse the Website; these providers process data on our behalf as data processors under written agreements [PLACEHOLDER: list specific providers, e.g. Google Analytics — to confirm]
- Legal and regulatory authorities — where we are required to disclose data by law, court order or regulatory requirement
We do not sell your personal data. We do not share your data with any third party for their own marketing purposes.
7. Data Retention
We retain your personal data for no longer than is necessary for the purposes for which it was collected:
- Enquiry and contact data — retained for [PLACEHOLDER: X months/years — to be confirmed with legal adviser] from the date of your last interaction with us
- Active service relationship data — retained while our service relationship with you is ongoing and for a reasonable period thereafter
- Technical and analytics data — retained in accordance with the data retention settings of the relevant tool [PLACEHOLDER: confirm per tool]
When personal data is no longer required, we delete or anonymise it securely.
8. Data Security
We take reasonable technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction or damage. These measures include [PLACEHOLDER: confirm specific measures — e.g. SSL/TLS encryption for data in transit, access controls, secure hosting provider]. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach, where required by law.
9. Your Rights Under UK GDPR
Subject to certain conditions and exceptions, you have the following rights in relation to your personal data:
- Right of access — you have the right to request a copy of the personal data we hold about you (a “subject access request”)
- Right to rectification — you have the right to ask us to correct inaccurate or incomplete personal data
- Right to erasure — you have the right to ask us to delete your personal data in certain circumstances (the “right to be forgotten”)
- Right to restriction of processing — you have the right to ask us to restrict how we use your data in certain circumstances
- Right to data portability — where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format
- Right to object — you have the right to object to processing based on legitimate interests; we will stop processing unless we can demonstrate compelling legitimate grounds that override your interests
- Rights related to automated decision-making — you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects on you
To exercise any of these rights, please contact us at [PLACEHOLDER: hello@sprayfoamremovalcompany.co.uk]. We will respond within one calendar month. We may ask you to verify your identity before processing your request.
10. Cookies
Our Website uses cookies and similar tracking technologies. Cookies are small text files placed on your device when you visit a website.
We use the following types of cookies:
- Strictly necessary cookies — required for the Website to function; these cannot be disabled
- Analytics cookies — [PLACEHOLDER: e.g. Google Analytics — to be confirmed] help us understand how visitors use the Website so we can improve it; these are only placed if you consent
- Preference cookies — [PLACEHOLDER: to be confirmed] remember your settings and choices
When you first visit the Website, you will be presented with a cookie consent banner that allows you to accept or decline non-essential cookies. You can change your cookie preferences at any time [PLACEHOLDER: add link to cookie preference centre or explain how to adjust browser settings].
For more information, please see our [PLACEHOLDER: separate Cookie Policy page — or incorporate full cookie schedule here].
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. The “Last updated” date at the top of this page indicates when the policy was last revised. Where changes are material, we will take reasonable steps to bring them to your attention — for example, by displaying a prominent notice on the Website.
We encourage you to review this policy periodically.
12. Complaints
If you have a concern about how we handle your personal data and are not satisfied with our response, you have the right to lodge a complaint with the UK’s data protection supervisory authority:
Information Commissioner’s Office (ICO)
Website: ico.org.uk
Telephone: 0303 123 1113
Post: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
13. Contact
For any questions, requests or concerns relating to this Privacy Policy or our data processing practices, please contact us at:
[PLACEHOLDER: Spray Foam Removal Company Ltd]
[PLACEHOLDER: Registered Address — TBD]
Email: [PLACEHOLDER: hello@sprayfoamremovalcompany.co.uk]