1. Who we are
ALTIOR DIGITAL LTD (“Altior”, “we”, “us” or “our”) operates the Altior website and is the controller of the personal data described in this policy.
Company number: 17106631
Registered office: Suite A, 82 James Carter Road, Mildenhall, IP28
7DE
Privacy contact: privacy@altior.digital
2. What this policy covers
This policy explains how we handle personal data when adults and business users:
- visit https://altior.digital;
- ask to receive one Altior blog email each week;
- confirm, manage or end an email subscription;
- contact us; or
- exercise a data-protection right.
Our website and blog subscription are not intended for children. A third-party website or service linked from our website may have its own privacy policy.
3. Personal data we collect
Depending on how you use the website, we may collect:
- Subscription data: your email address and any name or preference fields shown on the subscription form.
- Consent evidence: when and how you requested and confirmed a subscription, the consent wording and policy version shown, and technical evidence reasonably needed to demonstrate your choice.
- Suppression data: your email address, unsubscribe status, and the date and source of your opt-out.
- Communications data: the contents of messages you send us and information needed to reply.
- Technical and security data: information such as IP address, browser or device type, requested URL, timestamps, and security or diagnostic events generated when the website and its supporting services handle a request.
Please do not send sensitive personal data through a general website or email enquiry unless we specifically ask for it and explain why it is needed.
4. How we use personal data
We use personal data for the following purposes and legal bases:
| Purpose | Data used | Legal basis |
|---|---|---|
| Receive, verify and activate a blog subscription | Subscription data and consent evidence | Consent |
| Send confirmed subscribers one Altior blog email each week | Subscription data, preferences and consent evidence | Consent |
| Process an unsubscribe and prevent further marketing sends | Subscription and suppression data | Legal obligations and our legitimate interests in respecting and demonstrating opt-outs |
| Reply to enquiries | Communications and contact data | Our legitimate interests in communicating and operating our business |
| Handle a privacy request | Communications, contact and verification data | Legal obligation |
| Deliver, diagnose and protect the website | Technical and security data | Our legitimate interests in operating a secure and reliable website |
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.
5. Blog subscriptions
EspoCRM is Altior’s system of record for blog contacts, consent status and suppression status. Our email delivery provider processes confirmation and subscription messages on our behalf.
The subscription form uses a separate, optional, unticked control with this wording:
I agree to receive Altior blog emails. I can unsubscribe at any time. Read the Privacy Policy.
This consent covers one Altior blog email each week. It does not cover third-party marketing.
When you submit a subscription request:
- we record the request and applicable consent wording;
- we send a neutral confirmation message to the address provided;
- the subscription becomes active only after confirmation; and
- each blog email identifies Altior and provides a simple way to unsubscribe.
Until confirmation, we use the address only to complete the request and do not send blog marketing. We record opt-outs and maintain the minimum suppression information needed to prevent further subscription sends. We do not use a suppression record to send marketing.
Providing subscription information is optional. If you do not provide an email address and complete the confirmation step, we cannot send you Altior blog emails.
6. Who receives personal data
We may share personal data with:
- providers supporting our self-hosted CRM, website hosting, content delivery, security, backups and technical support;
- our email delivery provider;
- professional advisers; and
- courts, regulators, law-enforcement bodies or other public authorities where disclosure is required or permitted by law.
Service providers acting as processors must protect personal data, use it only for the agreed services, and assist us with our legal obligations. We do not sell personal data and do not share subscription data for third-party marketing.
7. International transfers
Some service providers or their subprocessors may process personal data outside the UK, including in the European Economic Area and the United States.
Before making a restricted transfer, we assess the transfer and use a lawful route appropriate to the circumstances. This may include UK adequacy regulations or contractual safeguards such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with additional measures where required.
You may contact privacy@altior.digital for information about the safeguards relevant to your personal data.
8. How long we keep personal data
We keep personal data only for as long as needed for the purpose for which it was collected, including legal, security and dispute-resolution needs.
| Record | Retention period |
|---|---|
| Unconfirmed subscription request | 30 days after the request if confirmation is not completed |
| Active subscriber record | While the subscription remains active |
| Consent and unsubscribe evidence | 3 years after unsubscribe or the last relevant consent event |
| Non-essential profile data after unsubscribe | Removed within 30 days |
| Minimum suppression record | While needed to prevent re-contact, with an annual necessity review |
| General enquiries | 12 months after the last meaningful contact |
| Routine website and security logs | 90 days |
| Privacy-rights request records | 3 years after closure, limited to necessary compliance evidence |
We may keep information longer where required by law or under a documented legal hold. We may delete or anonymise it earlier where it is no longer needed.
9. Your rights
Depending on the circumstances, UK data-protection law may give you the right to:
- ask for access to your personal data;
- ask us to correct inaccurate or incomplete data;
- ask us to erase personal data;
- ask us to restrict processing;
- object to processing based on legitimate interests;
- object at any time to direct marketing;
- withdraw consent; and
- receive certain data in a portable format where the legal conditions apply.
These rights are not absolute and may apply only in specified circumstances. The right to object to direct marketing is absolute.
To exercise a right, contact privacy@altior.digital. We may need to verify your identity. We will respond without undue delay and normally within one month. Where the law permits an extension for a complex request or several requests, we will tell you within the first month.
You may complain to the UK Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/. You do not have to contact us before approaching the ICO.
10. Cookies and similar technologies
We use technologies that are necessary to deliver and protect the website. If we introduce a non-essential cookie or similar technology that requires consent, we will explain its purpose and obtain consent before using it. We will make withdrawing consent as easy as giving it.
11. Security
We use technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. No internet or storage system is completely secure, so we regularly review the measures appropriate to the information and services involved.
12. Children
Our website and blog subscription are intended for adults and business users, not children. If we learn that a child has provided personal data, we will investigate and take appropriate action.
13. Changes to this policy
We may update this policy when our services, suppliers or legal obligations change. We will publish the current version at https://altior.digital/privacy/ and show its effective or revision date. If a change materially affects how we use data collected with consent, we will take any additional step required by law.