Privacy Policy
Last updated:
1. Introduction
Elbowspurgeskele ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information in connection with our website, educational services, and communications.
2. Information We Collect
2.1 Information You Provide
Contact Forms: When you submit a contact form or enquiry, we collect your name, email address, and message content.
Subscription Information: If you subscribe to our programmes, we collect name, email, contact details, and payment information (processed by third-party payment providers).
Communications: When you email us or communicate with us, we retain records of that communication.
2.2 Information Collected Automatically
Cookies and Tracking: Our site uses cookies for essential functionality, analytics, and optional marketing purposes. See our Cookie Policy for details.
Server Logs: We automatically log IP addresses, browser type, pages visited, and referral sources through standard server logging.
Analytics: We use Google Analytics (anonymised) to understand user behaviour and improve our site. Google may set cookies to track usage.
3. How We Use Your Information
- Respond to your enquiries and provide customer support
- Send educational materials and programme information
- Process subscriptions and payments
- Improve our website and services through analytics
- Comply with legal obligations
- Send newsletters (if opted in)
4. Legal Basis for Processing (GDPR)
Under GDPR Article 6, we process your information based on:
- Consent: You explicitly agree (e.g., contact form, newsletter signup)
- Contract: Necessary to deliver our services you've purchased
- Legal Obligation: Compliance with UK/EU law
- Legitimate Interest: Website security, analytics, customer service
5. Data Sharing and Disclosure
We do not sell your data. We may share information with:
- Payment Processors: Stripe, PayPal (to process payments)
- Email Providers: Mailchimp or similar (for newsletters, with your consent)
- Analytics Providers: Google Analytics (anonymised)
- Legal Requirements: Law enforcement or courts if required by law
6. Data Protection & Security
We implement industry-standard security measures including SSL encryption, secure password hashing, and restricted access controls. However, no system is 100% secure. We cannot guarantee absolute security of transmitted data.
7. Your Rights (GDPR & UK GDPR)
You have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate information
- Erasure: Request deletion ("right to be forgotten")
- Restrict Processing: Limit how we use your data
- Data Portability: Receive your data in a portable format
- Object: Opt-out of marketing communications
- Lodge a Complaint: With the Information Commissioner's Office (ICO)
To exercise these rights, email info@elbowspurgeskele.world.
8. Third-Party Services
Google Analytics: We use Google Analytics to analyse site usage. Google's privacy policy applies: https://policies.google.com/privacy
Google Ads Conversion Tracking: If you click a Google Ad to reach us, Google may set conversion tracking cookies. This is governed by Google's Consent Mode v2.
Google Maps: Our contact page uses an embedded Google Map. Google's terms apply to map data.
9. Cookies
See our Cookie Policy for detailed information about the cookies we use, their purpose, and how to manage them.
10. Data Retention
We retain personal information only as long as necessary:
- Contact form data: 12 months (unless you request deletion)
- Subscription data: For duration of subscription + 2 years for tax/legal purposes
- Email list: Until you unsubscribe
- Cookies: See Cookie Policy
11. International Data Transfers
Our servers are based in the United Kingdom/EU. If you are outside the UK/EU, your data may be transferred internationally. By using our site, you consent to such transfers.
12. Children's Privacy
Our services are not directed at children under 13. We do not knowingly collect data from children. If we become aware of such collection, we will delete it promptly.
13. Changes to This Policy
We may update this policy. Changes take effect when posted to our site. Continued use constitutes acceptance.
14. Contact Us
For privacy questions or to exercise your rights:
Elbowspurgeskele
12 Harley Street
London, W1G 9PF
United Kingdom
info@elbowspurgeskele.world
+44 207 946 0948
Data Protection Authority (UK): Information Commissioner's Office (ICO)
https://www.ico.org.uk