Graff Ventures Ltd

Privacy Policy

Effective date: [DATE]

Important notice about text messaging data

Graff Ventures Ltd does not sell, rent or share your mobile number, text message opt-in or consent data with any third party for their marketing purposes. Text message consent data is used only for the purpose for which it was collected.

1. Who we are

Graff Ventures Ltd ("we", "us") is a company registered in England and Wales, company number [COMPANY NUMBER], registered office [REGISTERED ADDRESS]. We are the data controller for the personal data described in this policy. ICO registration number: [ICO NUMBER].

Contact: [email protected].

2. Information we collect

Information you give us: your name, email address, mobile number, business name, website, main service, and anything you tell us in a form, message, call, chat or meeting.

Information collected automatically: your IP address, browser and device type, pages visited and time zone, collected through cookies and similar technology (see our Cookie Policy).

Calls and chats: if you call us or use our website chat, we may record the call or keep the chat transcript, including where our AI assistant answers. We tell you at the start of the call or chat.

3. How we use your information and our lawful basis

  • To reply to your enquiry, book calls and show you a demo (steps taken at your request before entering into a contract).
  • To provide our services to you once you're a client (contract).
  • To send text messages and marketing, only where you have ticked a consent box (consent). You can withdraw consent at any time.
  • To run, secure and improve our website and business, and to keep in touch with business contacts about relevant services (legitimate interests).
  • To meet tax, accounting and legal requirements (legal obligation).

4. Text messages

We only send the types of text message you have agreed to: demo, appointment and enquiry messages, and, if you opted in separately, occasional tips and offers. Up to 4 messages per month. Standard message rates may apply. Reply STOP to opt out at any time or HELP for help. We do not share your opt-in consent or mobile number with any third party for their marketing purposes. Full details are in our SMS Terms.

5. When we work for our clients

When a client asks us to contact their own past customers and enquiries, we act as a data processor for that client. The client is the data controller and is responsible for having a lawful basis to contact those people. We process that data only on the client's written instructions, keep it secure, and delete or return it when the work ends.

6. Who we share your information with

We never sell your personal data. We share it only with trusted service providers who help us run our business, under contracts that protect it, including: our website, CRM and messaging platform (HighLevel / LeadConnector), Google Workspace for email and calendar, our phone and text message providers, and professional advisers such as our accountants. We may also disclose information if the law requires it.

7. International transfers

Some of our providers store data outside the UK, including in the United States. Where they do, we rely on safeguards approved under UK law, such as the UK International Data Transfer Agreement or Addendum, or the UK-US data bridge.

8. How long we keep your information

  • Enquiries and demo requests: up to 2 years after our last contact unless you become a client.
  • Client records: 6 years after the end of the year the work ended, for tax and legal purposes.
  • Text message consent records: for as long as you are subscribed and up to 2 years after you opt out, so we can prove consent.
  • Call recordings and chat transcripts: up to 12 months.

9. Keeping your information safe

We use reasonable technical and organisational measures to protect your data. No method of transmission or storage is completely secure, but we work to protect your information and act quickly if anything goes wrong.

10. Your rights

Under UK data protection law you have the right to: access your data; have it corrected; have it deleted; restrict or object to how we use it; receive it in a portable format; and withdraw consent at any time. To use any of these rights, email [email protected]. We'll respond within one month.

If you're unhappy with how we handle your data, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113. We'd appreciate the chance to put things right first.

11. Cookies

See our Cookie Policy for how we use cookies and how to manage them.

12. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page with its effective date.

13. Contact us

Graff Ventures Ltd, [REGISTERED ADDRESS]

Email: [email protected]