Privacy

1. Introduction

We are committed to safeguarding the privacy of our website visitors and service users.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via the relevant page on our website.
In this policy, “we”, “us” and “our” refer to &DEV Limited. For more information about us, see Section 10.

2. How we use your personal data

In this Section 2 we have set out:

a. the general categories of personal data that we may process;

b. the purposes for which we may process personal data; and

c. the legal bases of the processing.
We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Your personal data held in our website database will be stored on the servers of our hosting services provider, Microsoft Azure. You can review Microsoft’s privacy practices at https://privacy.microsoft.com.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of personal data

In this Section 4, we provide information about the circumstances in which your personal data may be transferred to a country outside the United Kingdom.
Our hosting facilities and some of our service providers may be situated outside the United Kingdom. The processing of your personal data may involve transfers to countries outside the UK.
Where we transfer your personal data outside the United Kingdom, we will ensure that appropriate safeguards are in place to protect your personal data in accordance with the UK GDPR. These safeguards may include UK adequacy regulations, standard contractual clauses approved by the Secretary of State, or binding corporate rules.
You can find out more about international data transfers and adequacy decisions on the Information Commissioner’s Office website at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/.

5. Retaining and deleting personal data

This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:

a. usage data will be retained for a minimum period of 2 weeks following the date of collection, and for a maximum period of 7 years following that date;

b. enquiry data will be retained for a minimum period of 28 days following the date of the enquiry, and for a maximum period of 365 days following that date; and

c. notification data will be retained for a minimum period of 7 days following the date that we are instructed to cease sending the notifications, and for a maximum period of 28 days following that date (provided that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications).
Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Your rights

In this Section 6, we have listed the rights that you have under data protection law.
Your principal rights under data protection law are:

a. the right to access — you can ask for copies of your personal data;

b. the right to rectification — you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

c. the right to erasure — you can ask us to erase your personal data;

d. the right to restrict processing — you can ask us to restrict the processing of your personal data;

e. the right to object to processing — you can object to the processing of your personal data;

f. the right to data portability — you can ask that we transfer your personal data to another organisation or to you;

g. the right to complain to a supervisory authority — you can complain about our processing of your personal data to the Information Commissioner’s Office; and

h. the right to withdraw consent — to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent at any time.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-the-public/.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

7. Analytics

We use Fathom Analytics to analyse the use of our website. Fathom Analytics is a privacy-focused analytics service that does not use cookies to track visitors and does not collect personal data.
Fathom Analytics gathers anonymised information about the use of our website, including page views, referral sources, and general geographic location at a country level. This information is used to create reports about the use of our website and to help us improve our services.
Fathom Analytics is compliant with GDPR, PECR, and other privacy regulations, and does not require cookie consent banners because it does not use cookies or collect personal data.
You can find out more about Fathom Analytics and their privacy practices at https://usefathom.com/compliance.

8. Amendments

We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of significant changes to this policy by email or through the private messaging system on our website.

9. Your right to complain

If you are not satisfied with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the UK supervisory authority, the Information Commissioner’s Office (ICO).
The ICO can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Website: https://ico.org.uk/make-a-complaint/

10. Our details

This website is owned and operated by &DEV Limited.
We are registered in England and Wales under registration number 11895018, and our registered office is at Orwell House, Cowley Road, Cambridge, Cambridgeshire, United Kingdom, CB4 0PP.
Our principal place of business is at Orwell House, Cowley Road, Cambridge, Cambridgeshire, United Kingdom, CB4 0PP.
You can contact us:

a. by post, to the postal address given above; or

b. by email, at privacy@and.dev.

Last updated: December 2025