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How we operate

Privacy
Policy.

Your privacy is important to us.

This policy explains what personal data Element Seven Digital Limited collects, why we collect it, who we share it with and what rights you have. It covers this website and our dealings with clients and enquirers. It does not cover the websites and applications we build for our clients; on those, the client is responsible for its own privacy policy.

Who we are

Element Seven Digital Limited is a company registered in Northern Ireland (company number NI653626), of 14 High Street, Holywood, BT18 9AZ. We are the data controller for the personal data described in this policy. You can contact us about anything in it at [email protected].

When we build or maintain a website or application for a client, any personal data on that system is controlled by the client and processed by us on their instructions. Our obligations in that role are set out in clause 32 of our Terms and Conditions or in a separate data processing agreement.

We publish statistics about the performance of the work we have done, in the case studies on this website and in our marketing material. Where those statistics are drawn from a client's analytics, search, app store or platform reporting, we access that reporting as the client's processor and with their agreement. Everything we publish is aggregated and does not identify any individual visitor, customer or user. Clients can ask us to remove, amend or replace any published figure, and clause 14 of our Terms and Conditions sets out how.

What we collect and why

When you contact us or request a callback. Your name, email address, telephone number, business name and whatever you tell us in your message. We use this to respond to you and to discuss the work. Our lawful basis is legitimate interests, namely responding to an enquiry you have made, or steps taken at your request before entering a contract.

When you complete our AI readiness audit. Your name, business name, role, email address, telephone number, postcode and website address, together with your answers to the audit questions and the score generated from them. We use this to produce and send your scorecard and to follow up about the results. Our lawful basis is consent, which you give by ticking the box on the form, and you can withdraw it at any time by contacting us. We verify the email address and telephone number you give us to check they are valid and reachable, using the providers listed below. We also record your IP address and browser user agent to help prevent automated abuse of the form.

When you use the chat assistant on our website. The messages you send, the assistant's replies, a session identifier and related technical information. We use this to answer your question, to pass an enquiry to the right person, and to review and improve the assistant. Our lawful basis is legitimate interests, namely operating an enquiry channel on our own website. Please do not enter sensitive personal information, passwords or payment details into the chat.

When you become a client. Contact details for the people we work with, correspondence, project material, and the records needed to quote, invoice and account for the work. Our lawful basis is performance of a contract, and compliance with a legal obligation for accounting and tax records.

When you visit the website. Standard technical information including IP address, browser and device type, pages visited and referring site. Where you have agreed to analytics cookies, we use this to understand how the site is used. See the cookies section below.

We do not carry out automated decision-making that produces legal or similarly significant effects. The AI readiness audit produces an indicative score from the answers you give; it is not a decision about you, and a person reviews any follow-up.

Marketing

We may send you information about our services where you have asked us to, where you have given consent, or where you are an existing client and the information relates to services similar to those we have already provided. Every marketing email includes an unsubscribe link, and you can opt out at any time by contacting us. Opting out of marketing does not stop us sending messages we need to send about work in progress.

We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.

Who we share it with

We use a number of service providers who process personal data on our behalf. They act on our instructions and are not permitted to use the data for their own purposes. They are:

  • Hosting and infrastructure providers — to run this website and our systems.
  • Email delivery providers — to send email from our systems, including Mailgun, Postmark and Amazon Web Services depending on the message.
  • ZeroBounce — email address verification on the AI readiness audit form.
  • Twilio — telephone number verification on the AI readiness audit form.
  • OpenAI — to generate replies in our website chat assistant. Content submitted through our business account is not used to train their models.
  • Google — Google Tag Manager, Google Analytics and Google Ads, where you have accepted the relevant cookies.
  • Usercentrics — to record and manage your cookie preferences.
  • Professional advisers — our accountants and, where necessary, our solicitors and insurers.

We may also disclose personal data where we are required to by law, or where it is necessary to establish, exercise or defend legal claims. If our business is reorganised or sold, personal data may be transferred as part of it.

An up-to-date list of the sub-processors used on a particular client project is available to that client on request.

Our use of AI

We use AI tools in our own work and we run an AI assistant on this website. We do not put client confidential information or personal data into public or consumer AI services, and where we use these tools in connection with personal data we use business or enterprise services which are contractually committed not to train their models on what we submit. How we use AI more generally is set out in our AI Policy, and the contractual position is in clause 23 of our Terms and Conditions.

Transfers outside the UK

Some of our providers are based outside the United Kingdom, including in the United States. Where personal data is transferred outside the UK, we rely on an adequacy decision where one applies, or on the International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses, together with any additional safeguards required.

How long we keep it

We keep personal data only for as long as we need it for the purposes described above, and then delete or anonymise it. In practice that means:

  • Client records and correspondence — for the duration of the relationship and six years afterwards. This matches the six-year limitation period for bringing a contract claim in Northern Ireland, during which we may need the records to defend or bring a claim.
  • Accounting and tax records — six years from the end of the financial year they relate to, which is the period required by HMRC and the Companies Act 2006.
  • Enquiries that do not become work — six years from our last contact with you.
  • AI readiness audit submissions — six years from submission, or until you withdraw your consent or ask us to delete them, whichever is sooner.
  • Chat transcripts — two years from the date of the conversation.

You can ask us to delete your data sooner. Where you do, we will delete it unless we are required to keep it by law or need it to establish, exercise or defend a legal claim.

How we protect it

We apply technical and organisational measures appropriate to the risk, including access controls, encryption in transit, and restricting access to those who need it. No system is completely secure, but we take this seriously and will notify you and the Information Commissioner's Office where we are required to do so following a breach.

Your rights

Under data protection law you have the right to: be told how your data is used; get a copy of the personal data we hold about you; have inaccurate data corrected; have data erased in certain circumstances; restrict or object to processing, including objecting to direct marketing at any time; receive certain data in a portable format; and withdraw consent where we rely on it, without affecting processing carried out before you withdrew it.

To exercise any of these, email [email protected] or write to us at the address above. We will respond within one month. There is normally no charge.

If you are unhappy with how we have handled your data you can complain to the Information Commissioner's Office at ico.org.uk, by telephone on 0303 123 1113, or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would appreciate the chance to put things right first.

Cookies

We use three kinds of cookie:

  • Strictly necessary cookies, which the website needs in order to work. These do not require your consent.
  • Analytics cookies, which help us understand how the site is used. We set these only with your agreement.
  • Advertising cookies, set by Google Ads so we can measure the effectiveness of our advertising and show relevant ads to people who have visited the site. We set these only with your agreement.

Cookies are managed through Google Tag Manager, and your preferences are recorded by Usercentrics. You can change your choice at any time by managing your cookie preferences, or through your browser settings. Blocking cookies may affect how parts of the site work. For a general guide, see aboutcookies.org.

Other websites

This website links to other websites. This policy does not cover them, and we are not responsible for how they handle your data. Check their own privacy policies before using them.

Changes to this policy

We may update this policy from time to time. The version published here is the one in force.


This policy was last updated on 12 August 2026.

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