Privacy Policy

A head in the Cloud Agency Ltd – Privacy Policy

A head in the Cloud Limited respects you and your privacy and is committed to protecting your personal data as and when we hold it.

This Privacy policy provides information surrounding how A head in the Cloud Limited collects and processes your personal data when you contact us directly (or are contacted by us) by telephone, email, letter, or when you instruct us to provide you with a product or service via any means (even those not listed), and/or when you sign up to our direct marketing through your use of our site.

We provide business to business services that are not intended for children. We do not knowingly collect any data from or relating to children.

This Privacy Notice is issued for A head in the Cloud Limited and when we mention [“COMPANY”], “we,” “us” or “our” in this privacy policy, we are referring to A head in the Cloud Limited. A head in the Cloud Limited is the controller of, and responsible for this website.

Our Data Protection Officer will respond to questions relating to this privacy policy so if you do have any questions and/or a requests to exercise your legal rights, please contact our Data Protection Officer using the details set out directly below:

Full name of legal entity:                          ‘A head in the Cloud Limited’

Name of Data Protection Officer:               Baz McCarthy

Listed address:

A head in the Cloud Agency
First Floor
51 Upper Belgrave Road
Clifton
Bristol
BS8 2XP
UK

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would greatly appreciate the chance to deal with your concerns ahead of you approaching the ICO so please do contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

This Privacy Notice sets out most of your rights under current UK laws, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What information we collect, use, and why

Personal data, or personal information, is information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous/ anonymised data).

We may collect, use, store and transfer various kinds of personal data about you as follows:

Identity Data: Name(s) username or similar identifier, marital status, title, date of birth and gender.

Contact Data: billing address, delivery address, email address and telephone numbers.

Financial Data: bank account and payment card details.

Transaction Data: details about payments to and from you and other details of products and services you have purchased from us.

Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

Usage Data: information about how you use our website, products, and services.

Marketing and Communications Data: your preferences around receiving marketing from us, our third parties, and also on your own communication preferences.

We collect, use, and share data such as statistical and/or demographic data for any purpose. This ‘aggregated data’ may be derived from personal data but is not considered personal data in law as this data does not directly or indirectly reveal any identity.

The special categories of personal data about you collected is limited down to biometric residency data (personal data resulting from specific technical processing relating to the physical, physiological, or behavioural characteristics of a natural person), information about criminal convictions and offences is also collected where DBS and BPSS checking is required. (Notice of this collection is given in advance and all information collected is afforded more protection). Details about religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or information about your health and genetics will not be collected by any means or stored in any format.

If you fail to provide personal data

Where/when we need to collect personal data by law, or under terms of a contract we have with you and/or if you then fail to provide that data when requested to do so, we may not be able to perform the contract we have, or that we are trying to enter with you (for example, to provide you with goods or services, or to market those of others). In these cases we may, for example, have to cancel a product or service you have with us and we will notify you if this is the case, at the time.

 Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification– You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure– You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing– You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing– You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability– You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent– When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights/ subject access request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

We have laid out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on in order to legally do so. We have identified what our legitimate interests are where appropriate.

Please note that we may legally process your personal data under more than one lawful ground depending on the purpose for which we are using your data. Please contact us if you need details about the specific legal ground/s we are relying on to process your personal data where more than one potentially relevant ground has been set out in the table below.

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer OR your interest in becoming a new customer of ours	(a) Identity (b) Contact	(a) Performance of a contract with you or with our client
To process and deliver on your instructions including:(a) Manage payments, fees, and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Targeted marketing activity for our clients, based on legitimate interest.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you or with our client (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing ability, customer relationships and experiences	(a) Technical (b) Usage	(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and/or recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 Where we get personal information from

We use different methods to collect data from and about you, including:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal and special category data you provide when you:

• Instruct us to provide products or services.
• subscribe to our service or publications.
• request marketing to be sent to you; or
• give us some feedback.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
• Analytics providers such as Google based outside the EU.
• Advertising networks such as Facebook based outside the EU.
• Search information providers Google based outside the EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

 

 How long we keep information

We will only hold your personal data for as long as we need it, to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years plus the current period, starting after the end of our current accounting period after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: please see “Request erasure” below for further information.

In some circumstances we may anonymise personal data (so that it can no longer be associated with individuals) for research or statistical purposes in which case we may use this information indefinitely without further notice.

 

Disclosure of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above. These are: –

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with instructions.

 

 Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed in an unauthorised way. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and subject to a duty of confidentiality.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

 

Your legal rights

Under certain circumstances, you have rights under our data protection laws, in relation to your personal data.

No fee is usually required so far in that; –

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances as we seek to provide our services in good faith.

 

 How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details listed at the top of this policy.

 

Time to respond

We try to resolve all legitimate requests within a month. It may take us longer than a month to resolve if your request is particularly complex or if you have made several requests. In these cases, we will respond in advance to advise of this and update with progress.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Last updated

19^th of March 2025