01 — Legal

Privacy Policy

Draft — requires client and legal approval before publication

Who we are

This draft privacy policy applies to the Chapter Twelve website ([domain to be confirmed]).

The data controller is [Full legal company name], [registered address], [country / jurisdiction to be confirmed].

If you have questions about this policy or how we handle personal data, please contact us at [privacy email address to be confirmed].

Scope of this policy

This policy explains how we collect, use, store and protect personal data when you visit our website or use the contact form. It does not cover data processed during a separate client engagement, which is governed by the relevant client agreement.

Information we collect

Through the contact form we may collect:

  • First name and last name
  • Work email address
  • Company name
  • Optional phone number
  • Selected enquiry type
  • Message content

We may also collect technical or device information, server logs, and analytics data only if and when such tracking is configured. At launch, analytics and similar technologies are not active and will be added only after review.

How we use information

The purposes and lawful bases below are drafts to be confirmed:

  • To respond to your enquiry and any pre-contract discussions (lawful basis: performance of a contract or legitimate interests).
  • To operate, maintain and secure the website (lawful basis: legitimate interests).
  • To send optional marketing communications, only where you have given consent and can withdraw it at any time (lawful basis: consent).

We do not sell personal information.

Service providers, processors and international transfers

We may use service providers or processors, including website hosting and any later scheduling or analytics providers. These providers will be confirmed before launch.

If personal data is transferred outside your jurisdiction, we will rely on appropriate safeguards to be confirmed.

Retention

We will retain personal data only for as long as necessary for the purposes described in this policy, or as required by law. Specific retention periods are to be confirmed.

Your rights

Depending on applicable law, you may have rights including access, correction, erasure, restriction of processing, data portability, and objection.

To exercise your rights, contact us at [privacy email address to be confirmed]. You may also have the right to complain to a supervisory authority in your jurisdiction.

Security

We apply appropriate technical and organisational measures to protect personal data. No method of transmission or storage is completely secure, however.

Children's privacy

Our website is not directed at children under the age of [age to be confirmed under applicable law], and we do not knowingly collect personal data from them.

Third-party links

Our website may contain links to third-party sites. We are not responsible for their privacy practices.

Changes to this policy

We may update this policy from time to time. The latest version will be posted on this page.

Contact us

For privacy questions, contact [privacy email address to be confirmed].

Last updated: [Date]