Privacy Policy

1. The short version

This website has no analytics, no advertising, no tracking pixels, no third-party embeds, and no cookies. Nothing is stored in your browser. The fonts are served from our own server rather than from Google.

The only personal information you can give this site is what you type into, or attach to, one of its forms (the contact form, the Groundwork sign-up form, and the job application form described in section 21), plus, if you use the unsubscribe link in one of our emails, the code in that link. The contact form takes your name, your email address, your phone number if you choose to add one, and your message. The Groundwork sign-up form takes your name, your business's name, a phone number or email address, and the kind of work you do and where, if you add it. The contact form and the Groundwork sign-up form are each emailed to us so we can reply, and a short copy of a contact-form message also goes to our own client portal so that we see it on our phone straight away; that copy is deleted after 14 days. It is not sold, not shared, not added to any general mailing list, and used only to answer you (by email, or by a call or text if you gave a phone number), to send our follow-up emails if you leave the contact form's box ticked, or, for a Groundwork sign-up, to email you the Groundwork terms, follow up about your site, and send our Groundwork follow-up emails if you leave that form's box ticked; its email address also goes to our client portal so that any contact-form emails to it stop.

The contact form also has a box labelled "Email me offers from Velcrest." It is ticked when the page opens; untick it and we only reply. If you leave it ticked, our client portal uses your email address, and nothing else you typed, to send you a short series of six emails over about four weeks: our custom website offer, our Groundwork offer, and four short notes about choosing and starting a website, the last of which says it is the last. The Groundwork sign-up form has a similar box, "Email me a few follow-up notes about Groundwork.", also ticked when the form opens, which sends four short emails about Groundwork. Every one of these emails has an unsubscribe link, and once you use it we never send you another. A series also stops early if you reply and we take the conversation from there, book a walk-through, or become a client. Section 3 has the detail.

We also contact local businesses about our services, by phone or by email, and keep short records when we do. Some of those emails, and answers to the replies, are written and sorted by software. Section 17 explains how, what we keep, and how to tell us to stop.

If you apply for one of our sales roles through the application form on its job page, your application is emailed to us and stored in our client portal, and any résumé you attach is checked for viruses before anyone can open it. It is used only to consider you for that role, or a similar one, and to contact you about it. Section 21 has the detail, including how long we keep it.

The rest of this page is the detail behind those paragraphs, including your rights under European and UK law and the position under California law.

2. Who is responsible for your information

Kinetic Margin Holdings, LLC — a West Virginia limited liability company doing business as Velcrest Web Development, based in Morgantown, West Virginia, United States — is the data controller for the information described here. "Velcrest," "we," "us" and "our" mean that company.

We are not required to appoint a Data Protection Officer: our core activities do not involve large-scale monitoring of individuals or large-scale processing of special-category data. Privacy questions are handled directly by us rather than routed through a department. Contact details are in section 20.

3. What the contact form collects

When you submit the contact form we receive:

• Your name — required, so we know who we are talking to
• Your email address — required, so we can reply
• Your phone number — optional; if you give one, we may call you or send you a text in reply to your message
• Your message — required, and entirely up to you what it contains

The form sends those four fields to our mail address at info@velcrestwebdev.com. Nothing on this website itself stores your enquiry: the submission becomes an email, a short copy for our phone, described next, and, if you leave it ticked, the offers box described after that.

The copy on our phone. Once your message has reached us, our web server also sends a short copy of it to our client portal (section 16): your name, your email address, your phone number if you gave one, and the first 280 characters of your message, run together on one line. The request comes from our web server, not from your browser, so your IP address is not passed on, and it is signed, so the portal accepts copies only from our own form. No copy is sent if the decoy field described in section 5 is filled in. The portal then tells our own phone that a new enquiry has arrived; that notification says only "New enquiry from the website", with nothing you typed in it. We read the copy in our own phone app, which opens only with a PIN or Face ID, and use it only to reply to you. The portal deletes it 14 days after it arrived; the full message stays in our mailbox as section 9 says.

Replies by text. If you give a phone number, we may reply to your message by text, or call you. Each text we send about your message is typed and sent by one of us, one at a time, from our business phone number; we never text you automatically, and we do not send offers or advertising by text. (The separate number our portal uses to call us sends an automatic reply to anyone who texts it: see section 10.) If you would rather not get texts, say so in your message or in reply to one, and we will email or call instead. Your phone company's usual message rates may apply.

The automatic thank-you. Once your message has reached us, the form usually emails you a short thank-you from info@velcrestwebdev.com, so you know it arrived. It is fixed wording, except that it greets you by your first name if that is a plain name (letters, with an apostrophe or hyphen allowed); nothing else you typed is repeated. If you send more than one message in a day, you get one thank-you. To make that work, our server keeps a one-way fingerprint of your email address (made the same way as the fingerprint in section 5) with the time, for one day, and nothing else.

The offers box. Below the message there is a box labelled "Email me offers from Velcrest." It is ticked when the page opens, and you can untick it before you send. If you send the form with it ticked:

• Our web server passes your email address to our client portal (section 16), with a random reference number and the version of the form. Nothing else you typed goes with it, and neither does your IP address: the request comes from our web server, not from your browser. The short copy of your message described above is a separate record and is never used for offer emails. The request is signed, so the portal accepts addresses only from our own form.
• The portal sends you a series of up to six emails from news@velcrestwebdev.com, each at 10:00 AM Eastern: our custom website offer the next day, our Groundwork offer two days after that, then four short written emails about choosing and starting a website, about 7, 11, 16 and 24 days after you sent the form. A written email that would fall on a Saturday or Sunday goes on the Monday, and if one is held back by our daily sending limit, the ones after it move back with it, so they always arrive in order. If you reply, the reply comes to info@velcrestwebdev.com. If your address received one of the two offer emails in the last 30 days, that one is skipped.
• The series stops early if you unsubscribe; if you reply and we take the conversation from there (we stop it ourselves when we do); if you book a walk-through with us; if you sign up on our Groundwork page; if you become a client (we invite you to the client portal, send you a project document to sign, or set up your Groundwork agreement); if you tell us it wasn't a real enquiry; or if your mail server refuses the address. An address that belongs to a client is never entered. Stopping a series is not the same as unsubscribing: we can still reply to you ourselves.
• An address goes through the series at most once in any 12 months. If you send the form again within that time, we reply to you and nothing restarts.
• Each email is fixed wording, and the written ones open with "Hi,". Apart from the date and the unsubscribe link, it never repeats anything typed into the form, so nobody can use the form to put their own words in front of someone else. None of them has tracking, so we cannot tell whether you opened one; the written emails contain no link except the unsubscribe link.
• Every one of these emails carries an unsubscribe link, which opens a page on this website with one Unsubscribe button (opening the page alone changes nothing), and the one-click unsubscribe option many mail apps show. Pressing the button, or using your mail app's option, makes our web server pass the random code in your link to our client portal, signed in the same way, with only a note of whether you used the button or your mail app's option; not even your IP address goes with it, and the portal puts your address on the unsubscribe list. If the portal can't be reached or doesn't accept it at that moment, our web server emails that code to info@velcrestwebdev.com instead, so that we can finish it by hand, and the page tells you so; if that email can't be sent either, the page says so and asks you to try again later or to reply "unsubscribe". You can also reply "unsubscribe", or email or phone us. Once your unsubscribe is recorded (at once, or by us by hand, generally within one business day, if our system couldn't take it), nothing waiting for you is sent, and we never send you another of these emails, whatever asks for one later.
• If the decoy field described in section 5 is filled in, the box is ignored.

If you sent an earlier version of the form, used before October 19, 2026, you get only what its box promised then (one or two offer emails), never the later ones. The form records which version of the box your page showed, so that this holds even if you opened the page before the change and sent it after. The copy of your enquiry that reaches us notes whether the box was ticked and what happened to it, with a link that only we can use, after signing in to our portal, to stop the series.

The Groundwork sign-up form. On our Groundwork page, and after you try the example request form on one of our Groundwork example sites, you can ask to start with Groundwork. It collects your name and your business's name (both required), a phone number or an email address (at least one), the kind of work you do and where if you choose to add it, and which page you signed up from. It is emailed to info@velcrestwebdev.com in the same way and stored nowhere else on this website. If you give an email address, the form also emails you the Groundwork terms straight away, from info@velcrestwebdev.com, once your details have reached us; that email is fixed wording and never repeats anything typed into the form. We use what you send for that, to talk with you about your site, and, if you leave its box "Email me a few follow-up notes about Groundwork." ticked (it is ticked when the form opens), to send you four short emails about Groundwork from news@velcrestwebdev.com, at 10:00 AM Eastern about 2, 6, 12 and 20 days after you sign up, each with an unsubscribe link. They work like the contact form's series above: fixed wording, the same weekend and daily-limit rules, the same reasons for stopping early, and at most once in any 12 months. If you give an email address that is an ordinary one we email automatically, and the decoy field is empty, our web server also passes that address to our client portal, signed in the same way as the contact form's, with a random reference number, the version of the form and whether the box was ticked, but nothing else you typed. It does this whether or not the box is ticked, so that any contact-form series running for that address stops; if the box is unticked and nothing is running for that address, the portal keeps nothing. To stop hearing from us, reply "stop" or call us. So that the form can't be used to fill someone's inbox, the same address is sent the terms email at most once a week: our server keeps a one-way fingerprint of the address (made the same way as the fingerprint in section 5) with the time it was sent, for seven days, and nothing else. On an example site, what you typed into the example form is copied into the sign-up form within the page, so you don't have to type it again; nothing is sent until you press "Send to Velcrest". The example sites' own request forms send nothing at all: they only show how a real one works.

Please do not send passwords, card numbers, health information, government identification numbers, or anyone else's personal information through the form. Email is not encrypted end to end, and the form is not built to carry that kind of data. If you need to send us something sensitive during a project, ask and we will arrange a better route.

4. What the contact form does not collect

Your IP address is not recorded with your enquiry. It is not included in the email we receive, it is not attached to your message, and it is not kept as part of any record about you. This is deliberate.

The contact form also does not ask for your company, your budget, your job title, or anything else. There are no hidden profiling fields. Four hidden fields do exist and none describes you: one holds a reference number for the verification question described below, one carries your answer to that question so it can be checked, one says which version of the offers box the page showed (section 3), and one is the decoy field described in section 5, which people never see and should leave empty. The Groundwork sign-up form has the same three, plus one saying which page you signed up from. The same applies to it: your IP address is not recorded with your sign-up.

5. Spam protection and rate limiting

Four things protect the form from automated abuse, and all four run on our own server with no third party involved:

• A verification question. A simple arithmetic question generated by our server and checked by our server. The stored record contains a random reference number, the expected answer and the time it was created — nothing about you. It expires after ten minutes and is deleted as soon as an answer is checked against it.
• A timing and decoy check. The form contains a field invisible to people, and our server times each submission from when it made the page's verification question. Submissions that arrive impossibly fast are refused as automated. A submission that fills the invisible field is still delivered to us, marked as possibly automated, because some browser extensions fill it in for real visitors. The check itself uses no personal data, and the invisible field's contents are not kept and are not included in the email.
• Limits per connection. To stop the form being used to send floods of mail, or being tied up so that nobody else can use it, our server counts two things per network address (for an IPv6 connection, the network block its address belongs to): the messages it has accepted from that address in the last day — at most three — and the verification questions it has handed to that address in the last ten minutes — at most thirty. Opening a page with the form fetches a question, so every visit is counted this way, whether or not you send anything. To do that it briefly handles your IP address, which it converts (for an IPv6 address, only its network part) into a one-way fingerprint and uses to name a temporary file holding those times. The fingerprint is a keyed hash, produced with a randomly generated secret that is created on our server and never leaves it. Without that secret the address cannot practically be worked back out of the fingerprint. If the server cannot generate or store a random secret, these limits are skipped entirely rather than fall back to a weaker fingerprint — we would rather lose a spam control than keep a record of you that could be reversed. The address itself is never written down and never reaches the email we receive. The files hold nothing but times: the one counting questions expires ten minutes after the last question it counted, and the one counting messages expires a day after the last message it counted, so a visit that sends nothing leaves a record that expires after ten minutes. They and the verification records are deleted by housekeeping that runs from time to time as the form is used, so an expired file can remain on the server until then.
• A daily limit. Our server also counts how many messages the form has accepted that day (days run on UTC, the world standard clock), from all visitors together, and stops accepting more once a set number is reached; the form then asks you to email us instead. That count holds a date and a number and nothing about who sent anything.

The form also refuses requests that come from another website's pages. That check uses no personal data.

The Groundwork sign-up form is protected in the same way, with its own separate counts, and asks you to call us when a limit is reached. So is the job application form (section 21), which asks you to email us when a limit is reached. A Groundwork client's request form also works the same way, except that it asks visitors to call the business.

The unsubscribe page our offer and follow-up emails link to (section 3) has limits of the same kind. It counts the presses it has accepted from each network address in the last hour, at most ten, in its own file named by the same kind of fingerprint and holding only times, which expires an hour after the last press it counted. It also counts the presses from all visitors together in each hour, a count that holds the hour and a number and nothing about who pressed, and how many notices to finish by hand it has tried to send us each day, a count holding the date and a number. Opening the page counts nothing. Past any of these limits, the page asks you to try again later or to reply "unsubscribe" instead.

We consider the fingerprint used for rate limiting to be personal data under European law and we have described it here for that reason, even though we cannot tie it to you and never see it.

6. Web server logs

This website runs on shared hosting provided by Hostinger. Like every web server, theirs produces access logs that record the IP address of each request, the page requested, the time, and basic browser information. Those logs exist for security and for diagnosing faults. They are generated and retained by our hosting provider under their configuration and their retention schedule, not ours. We do not use them for analytics, we do not build profiles from them, and we do not export or combine them with anything else.

7. Information you give us as a client

If you become a client, we hold what a project requires: your contact details, your business's address, your billing details, the content and files you send us for your website, credentials you choose to share so we can do the work, our correspondence, and our invoices and payment records.

Payments are processed by Stripe. When you pay an invoice you enter your card details on a page hosted by Stripe, not by us. Stripe receives your name, your email address, your billing address, the amount, and the card details themselves. We receive the fact that the invoice was paid, the card brand, the last four digits and the expiry date — never the full number. We will not accept a card number by phone or by email, so if anyone asks you for one that way, it is not us.

Stripe is a separate company and decides for itself how it uses payment information, for processing, fraud prevention and the financial-regulation obligations it is under. For that information Stripe is its own controller rather than our processor, and its privacy policy is at stripe.com/privacy. If you pay from a bank account, Stripe may ask you to confirm the account by signing in to your bank through Stripe's own service, or by confirming two small test deposits Stripe makes to the account; that happens between you, Stripe and your bank, and we never see your bank sign-in or your full account number.

If you have a Care & Hosting plan or a Groundwork plan and set up automatic payment, Stripe stores your card or your bank account details so it can take the agreed monthly fee. Everything to do with that card or account — storing it, charging it, updating it — happens inside Stripe. We do not hold it. We can see the type of payment method on file and its last four digits, and we can stop the charges. What you agreed to, and how to stop it yourself, is in your plan agreement: Section 6 of the Care & Hosting Plan Agreement, or Sections 6 and 8 of the Groundwork Addendum.

If you sign up for a Groundwork plan, your first payment is taken on Stripe's own payment page, which you open from your private Groundwork link, by card or straight from a US bank account. To set that up, our server sends Stripe your business's legal name, the email address and phone number on your agreement, the name customers know your business by, and our own reference number for you. If you pay from a bank account, Stripe may ask you to confirm the account by signing in to your bank through Stripe's own service; that happens between you, Stripe and your bank, and we never see your bank sign-in or your full account number. We receive reference numbers and whether each payment is open, on its way or paid. Our bookkeeping also reads your monthly invoices from Stripe with a separate key that can only read; Stripe's copy of the invoice includes the billing details Stripe holds for you, and of it we keep only the invoice number, the amount, the sales tax and the day it was paid, and, while an invoice is unpaid, its amount and dates (section 16). Stripe then takes the monthly payments set out in Section 6 of the Groundwork Addendum and, from month 13, your Care & Hosting plan, until you cancel.

If your Groundwork Addendum says you pay by check, nothing about you or your plan is sent to Stripe. We email each invoice to you as a PDF and keep a copy on our server. When your check arrives we record its number, the amount, the day we received it, and the day it cleared or was returned unpaid. We never record your bank account or routing number, although the check itself shows them to our bank (section 10).

If you have a list refresh on your Groundwork plan, you email us an export of your products from your point-of-sale system. We use it only to update the product lists on your website. The email rests in our mailbox at Hostinger (section 10); we save the file on our own computer to upload it to the portal, which reads it in memory to build the lists and does not save it. We delete the email, and the copy on our computer, within 30 days of finishing the refresh, or within 30 days of receiving it if no refresh is done from it. Only the lists that appear on your site remain, as part of your site's files, and the portal keeps the day each export arrived, the day your lists were updated, any short note we add, and a line saying how many items were used. Please send an export of your products only: if it holds anything else, such as customer, supplier or staff details, we do not use it.

If you have a Local Growth Plan or Local Growth monthly, we keep your intake answers, your plan and your monthly reports as project files. Through the manager access you give us, we read your Google Business Profile and Search Console figures. We process the customer names and email addresses you send us as your processor: we use them only to send your emails and delete them within 30 days after the service ends, after handing you the list of people who asked to stop.

If your website, Business email we provide, or emails we send for you under Local Growth monthly, processes personal data about your own customers — through a contact form, a booking tool, an online shop's orders, an account system, or the mail in your mailboxes — that data belongs to you, and for it we act as your processor rather than as a controller. Where UK or EU data protection law applies to that processing, a written data processing agreement is required, and we will enter into one with you before the processing begins — you do not have to ask for it, and there is no charge. It sets out what we process, for how long, on whose instructions, the confidentiality and security obligations we are under, the rules for engaging any sub-processor, and what happens to the data when we are finished. If you would rather use your own form of agreement, send it to us.

If we run your shop's order system on our server, we hold your customers' orders — names, contact and delivery details, what they ordered, and any text they ask to have printed — only to run the shop for you. When the shop leaves our hosting we hand the orders to you, and 30 days after that handover we delete them; backup copies disappear as older backups are replaced.

If you take Business email through us, we hold the names and addresses of the mailboxes and where any forwarding addresses point, and each mailbox's starting password until its user changes it. The mail itself is held by Hostinger (section 10).

If you have a Groundwork plan, your website's request form sends each request your customers make straight to the email address you give us. We do not keep a copy of the request. Apart from the short-lived spam-protection files described in section 5 and our host's server logs (section 6), the form stores nothing. If a request cannot be delivered, any returned copy is deleted as soon as we have told you. For your customers' requests we act as your processor, as described above.

If we pay you as a supplier, our bookkeeping records your name, what we paid, when, and a short note. If we pay you for services, your name and the year's total also appear on our list of who may need a Form 1099, with two ticks: whether your Form W-9 is on file, and whether we paid you only by card or PayPal. Your W-9, which carries your tax identification number, never goes into the portal, and we never type your tax identification number into it. You can hand it to us, post it, or email it; email is not encrypted end to end, so handing or posting it is safer. An emailed W-9 is printed or saved to encrypted storage, and the email is deleted within 30 days. Our bookkeeping also keeps a copy of the transactions on our own business bank accounts and business credit card, read from our bank: for each one, the date, the amount, the name the bank shows for the other party (for a card purchase, the merchant), the bank's description and any memo. So a payment between you and us that passes through our bank or our card, such as one we make to you or a check you pay by where your agreement allows it, appears there as the bank describes it. If you give us a receipt or an invoice, we may keep a photo or PDF of it with that record. All of this is kept as section 9 says for payment records.

8. Why we are allowed to use your information

Under the UK and EU General Data Protection Regulation, we must have a lawful basis for each use. Ours are:

• Steps taken at your request before a contract, and performing a contract — answering your enquiry by email, phone call or text (including the automatic thank-you that tells you it arrived, and the short copy on our phone described in section 3), emailing you the Groundwork terms you asked for, quoting, carrying out project work, running a Care & Hosting or Groundwork plan, and running Local Growth (a Local Growth Plan or Local Growth monthly), including service emails about your site such as an outage notice (Article 6(1)(b))
• Steps taken at your request before a contract — considering a job application you send us and contacting you about it (Article 6(1)(b)). See section 21
• Our legitimate interests — keeping the form free of automated abuse and available to everyone, keeping the site and our systems secure, and keeping records of what was agreed. We have considered your interests and use the minimum data that works (Article 6(1)(f))
• Keeping a record of what was signed — when you sign the Groundwork Addendum electronically, we keep the signature record described in section 16, including the IP address and browser type it came from, so that either of us can later show who signed what and when (Article 6(1)(b) and 6(1)(f))
• Our legitimate interests in contacting local businesses — offering our services to local businesses, and keeping a record so that a "no" is respected (Article 6(1)(f)). See section 17
• Sending offer and follow-up emails — the emails the contact form's box or the Groundwork form's box was left ticked for (section 3), or a flyer you agreed to on a call with us (section 17), stopping a series when you reply, book, sign up or become a client, and keeping the unsubscribe list so that a "stop" is respected for good (Article 6(1)(f)). Each email has an unsubscribe link
• Legal obligation, and keeping accurate books — keeping invoices, payment records and tax records for the periods the law requires (Article 6(1)(c)), and our legitimate interest in keeping our books accurate and complete, including the copies of our bank and card transactions and of our Stripe fees, payouts and plan payments, and the list of who may need a Form 1099, described in sections 7 and 10 (Article 6(1)(f))
• Being told promptly about our own business — the calls between our portal and our own phone about a security alert, a site we host being down (including when a client tells us so through a request), a client's request that is due and not yet started, work waiting for our approval or the day's work, which can name a client's business (section 10), and keeping the number those calls use closed to anyone else who rings or texts it, and answering anyone who texts it. The status those calls use leaves out contact, address, card, bank and check details (Article 6(1)(f))

There is no tracking and no general mailing list (the Groundwork sign-up form, its follow-up box and the contact form's offers box are used only as sections 3 and 17 describe). Our software makes some routine decisions about the emails we send to businesses (section 17): whether it answers a reply itself, passes the conversation to a person, or stops writing. It also gives each reply a score for how likely a phone call is to be welcome. None of these decisions has a legal or similarly significant effect on anyone. Our portal also sorts job applications by two yes-or-no answers (section 21); a person reads every one. Apart from that, and the priority our lead search gives a business based on how its own website performs, we do not score or profile anyone.

9. How long we keep things

• Enquiries and Groundwork sign-ups that do not become projects — deleted within 12 months of your last message to us
• Job applications and résumés (section 21) — in the portal and in our mailbox, deleted within 12 months of when you sent them if we don't take you on; if we do, kept with your contractor file for as long as you work with us and seven years afterwards. Copies in the portal's backups disappear as older backups are replaced (section 18)
• The short copy of a contact-form message on our phone (section 3) — your name, email address, phone number, the first 280 characters of your message, when it arrived and whether we have marked it answered; deleted by the portal 14 days after it arrived. Copies in the portal's backups disappear as older backups are replaced (section 18)
• Offer and follow-up emails (the contact form's offers box, the Groundwork form's follow-up box, and flyers agreed to on a call) — the record of each email (the address, which email, when and how it was agreed to, and, for a call, the name of the person who agreed and which of us recorded it) is deleted 12 months after it was sent or cancelled. The record of each series (the address, the wording of the box, when it started, how far it got, and when and why it ended, including whether a mail server refused the address) is deleted 12 months after the series ended. The reference number that lets the link in our copy of your enquiry find your series is deleted after 60 days. An address with no record left is then deleted too, unless it is on the unsubscribe list
• Outage records for a site we host — when the site stopped answering and when it came back, what our outside checks found (section 10), and each outage email we sent about it (the address it went to, when, and what it said); deleted 12 months after the outage ended. Copies in the portal's backups disappear as older backups are replaced (section 18)
• Calls between our portal and our own phone (section 10) — for each call, what it was about, when it rang, whether we answered, how long it lasted and the voice-call service's short written summary of it, kept 180 days, or for as long as any note from that call is kept; the status sent for that call, kept 30 days and then deleted; and a note of anything we said that sounded like an instruction, with our own words from the call, kept until we have dealt with it and then 90 days. When anyone rings the voice-call service's number and says a number, the portal keeps the service's reference for that call and how many tries were made, for 30 days, and a count of each day's failed tries, for 90 days; it never stores the caller's phone number or what they said. Calls we make to that number ourselves, and texts we send it, are kept like the calls above. Notices about these calls and texted notes are also emailed to our own mailbox (section 10) and kept with our correspondence. The voice-call service keeps its own transcript and summary of each call, including calls from anyone else who rings its number, in our account for as long as its own terms allow, and deletes them when we ask it to. When anyone texts that number, the portal keeps nothing from the text unless it comes from, or appears to come from, our own mobile and starts with our private code word; a text like that from us becomes a note, kept like the notes above. For texts from our own mobile without that word, the portal keeps only a count for each day, for 90 days. The voice-call service keeps every text sent to its number, and its reply, together with a record of what it passed to our portal and the answer it got, in our account for as long as its own terms allow, and deletes them when we ask it to. What the voice-call service's memory feature kept while it was switched on, from October 19 to October 20, 2026, is no longer used, and we will ask the service to delete it. Copies in the portal's backups disappear as older backups are replaced (section 18)
• The unsubscribe list — the address, the date it was added, how it was added (the link, a mail app's unsubscribe button, a reply asking us to stop, by us on your request, or because you told us you're not interested; a press we finish by hand is recorded as the link) and the random code in that address's unsubscribe link, kept for as long as we send any marketing email, so that we never email it again. If you ask us to delete it, we will tell you that without it we can no longer guarantee you won't be emailed by mistake, and do as you decide
• Unsubscribe notices to finish by hand (section 3) — the email our unsubscribe page sends us when our system couldn't record a press, holding the code from your link and whether you used the button or your mail app's option; deleted within 12 months, like enquiries
• Client portal invitations that we decline, or that are never taken up — what was typed into the invitation form, the IP address and browser type recorded when the link was opened, and the unused account itself are deleted within 12 months. The portal's log keeps a line saying that an invitation was sent and what became of it, without those details
• Project files and correspondence — for the life of our engagement and for seven years afterwards, which covers our tax record-keeping and the period in which a claim about the work could realistically arise
• Invoices and payment records, including check records, the billing contact on them, the billing history log kept with them, our bookkeeping ledger built from them, the copy of our business bank accounts' and business credit card's transactions, the fees, payouts and plan payments our bookkeeping reads from Stripe, the rules we set for sorting them, the receipts kept with them, our mileage and equipment records, and the list of who may need a Form 1099 — at least seven years, which covers the periods tax law requires. A supplier's Form W-9 is kept for the same period, printed or in encrypted storage
• Your business's street address on your client record — on a portal client record, until we remove the record; on a Groundwork record, for as long as the Groundwork signature records below, because it is part of your agreement. Copies on a signed agreement or an invoice are kept as those entries say
• Groundwork signature records — the exact copy of the Groundwork Addendum you signed and its signature record (including the IP address and browser type recorded when you signed) — for as long as your plan runs and ten years after it ends, because they are the evidence of our agreement
• Groundwork sign-in codes — each 6-digit code is kept only as a one-way fingerprint, stops working after 10 minutes and is erased when it is used or replaced. The log line saying a code was sent or entered is kept with your client file; the IP address on it is removed after 90 days
• Groundwork intake answers, logo and photo uploads, and the name and email of the person who approves your site — project files, kept as the project-files entry above says. A file you remove before sending your answers is deleted at once. Our server keeps four copies of your site: the working copy your draft was built from, the version that is live, the version before your latest change (so that a change can be undone), and the copy a change is being made on. They are kept while you are on a plan and deleted 90 days after your plan ends
• Changes made to your live Groundwork site — what you asked us to change, the day your request reached us, what we changed and when it went live, and, if you asked us to change where your request form sends requests, the old and new address. Project files, kept as the project-files entry above says
• Requests you send us from the client portal or your Groundwork request page (section 16) — what you wrote, the kind of request, your plan, when it reached us and the day it was due to be addressed, each step it went through, and the notes you and we added. Kept while it is open and for 24 months after it is done, closed or withdrawn, then deleted. Files you attach are deleted 90 days after the request ends. A copy of each request, as it arrives, also reaches our mailbox and is kept with our correspondence, as the project-files entry above says. Your Groundwork request link is kept only as a one-way fingerprint; its codes and the log of them are kept as the Groundwork sign-in codes entry above says
• Your website hand-over pack — when you leave our hosting, or your site's files become yours to keep, we send one private link to your billing email address (for a Groundwork plan, the address on your agreement). The link works for 14 days, and each time it is opened we email a 6-digit code to that address; we keep only a one-way fingerprint of the link and of each code. The copy of the pack behind the link is deleted when the link expires or we switch it off. Files we upload only for your pack, such as a copy of your site or a backup, are deleted 90 days after the last link closes, or 90 days after we last changed them if no link is sent; a shop's orders and its database export are deleted 30 days after we first send the pack. Copies of your signed documents and invoices in the pack are kept as the entries above say. With your client file we keep a record of what was sent, to which address and when, and each step taken on the download page (a code asked for or entered, each download) with the IP address it came from; the IP address is removed after 90 days. Your passwords and other sign-in details are never put in the pack, in its email or in the portal: we record only how and when they were passed on to you
• Groundwork agreements sent but never signed — deleted 12 months after the last change to them
• Point-of-sale exports sent for a list refresh — not kept by the portal, which reads each file in memory to build your product lists. The email that brought it, and the copy on our computer, are deleted within 30 days of the refresh being finished, or within 30 days of receiving it if no refresh is done from it. The day each export arrived and the day your lists were updated are kept as the project-files entry above says
• Customer names and email addresses a client sends us for Local Growth monthly — used only to send that client's emails, and deleted within 30 days after the service ends, after we send the client the list of people who asked to stop. That list is kept only as long as we send emails for that client
• A shop's orders that we hold for a client — for as long as we run the shop for them, then deleted 30 days after we hand the orders over when the shop leaves our hosting (see section 7)
• Business email mailboxes we provide for a client — held by Hostinger in our account while the client's plan includes Business email; kept open 30 days after it ends, then deleted from our account 30 days after they close (Hostinger's own backups follow its schedule). An export we make for a client is deleted from our side once they confirm they have it. The list of addresses and forwards is kept with the client file
• Requests sent through a Groundwork client's website — not kept by us; each one is emailed to the client. Apart from the spam-protection records below and our host's server logs (section 6), nothing is stored; if a request cannot be delivered, any returned copy is deleted as soon as we have told the client (see section 7)
• Verification question records — ten minutes, or until used, whichever comes first; they expire on that schedule and are then deleted by housekeeping that runs from time to time as the form is used, so an expired file can remain until then
• Thank-you fingerprints — a one-way fingerprint of an email address that was sent the contact form's thank-you, with the time, kept one day and then swept on the same basis as the rate-limiting files
• Terms-email fingerprints — a one-way fingerprint of an email address that was sent the Groundwork terms, with the time, kept seven days and then swept on the same basis as the rate-limiting files
• Rate-limiting fingerprints — ten minutes after the last verification question counted for that network address, or a day after the last message accepted from it, or, for the unsubscribe page, an hour after the last press it counted, then swept on the same basis (the unsubscribe page's housekeeping runs only as presses arrive, so an expired file can stay until a later one). Each record holds only times, in a file named by the fingerprint described in section 5; both are scratch files on the server
• Web server logs — retained by our hosting provider under their schedule, not ours
• Sales contractor accounts and their activity record (section 21) — kept for as long as you work with us and seven years after your account closes. The IP address, device and browser type on each line are removed after 90 days, and the line saying what was done stays. Tax and payment records are kept as the invoices entry above says. Call recordings are kept as section 10 says.
• Records of businesses we have contacted — while we are talking to you, and deleted 12 months after our last contact if it goes no further. Once a business is a client, its record is kept with the client file. If you're not interested, the "Not interested" note is kept until our search has worked through every town in your state, and then only Google's reference number (or a hand-added business's phone number), so that we don't call you again. If you ask us to delete your record, only that reference, marked "do not contact", is kept, and, if we ever emailed you (a flyer or one of the emails described in section 17), your email address on the unsubscribe list, so that you are never sent another
• Our emails to businesses (section 17) — each email we send and each reply we receive is deleted 12 months after it was sent or received. That includes when it went, what our software did with it and the score it gave. We keep them that long so that we can show we followed the law on commercial email. The record of the business is deleted 12 months after our first email to it, or 30 days after we found it if we never emailed it. That record holds the address, where and when we found it, what our check found, and how far the emails got. A reply that can't be matched to one of our emails is deleted after 30 days. A conversation that becomes a lead is kept as the records of businesses we have contacted are, above
• The portal's security records of our own administrator account, including the log of who opened our bookkeeping, what was changed or exported, and which receipts were opened — the IP address and browser type are removed after 90 days; the line saying what was done stays. A line in that log can include the name the bank shows for the other party to a payment, a supplier's name on the 1099 list, the purpose of a business trip, or a receipt's file name
• The portal server's security logs — the IP address, time, page requested and browser type of each connection to the portal's server, sign-in attempts to the server itself, and addresses blocked for misuse. They are kept on the server for up to five weeks, and an encrypted copy is kept with the cloud storage provider described in section 10. Both are used only to investigate security problems, and the copy is deleted after 90 days

Where a longer period is genuinely needed to establish or defend a legal claim, we keep the relevant records until that period ends and then delete them. You can ask us to delete your information sooner — see section 11.

10. Who else can see your information

We do not sell your personal information. We do not share it for advertising. We do not use data brokers, and we never have.

The organisations that can technically come into contact with it are:

• Hostinger, our web host and the provider of the mail service that receives enquiries, Groundwork sign-ups, the job applications described in section 21, and the email clients send us, including attachments such as a point-of-sale export. Your message passes through their systems and rests in the mailbox there. It also sends the requests made through a Groundwork client's website, the contact form's thank-you and the Groundwork terms email described in section 3 (from info@velcrestwebdev.com), and the offer and follow-up emails described in sections 3 and 17 (from news@velcrestwebdev.com), and the notice our unsubscribe page sends us when our portal can't record a press, and the request notices and status emails described in section 16, and notices about our emails to businesses. If a client takes Business email through us, their mailboxes are provided by Hostinger through our account: the mail is the client's, held by Hostinger, and we open a mailbox only to set it up, to fix a problem the client has asked us to look at, to hand it over to them, or where the law requires it. If a mailbox is sending spam or appears to have been taken over, we change its password straight away and tell the client.
• Stripe (Stripe, Inc., United States), which issues our invoices and processes card and bank payments, including a Groundwork plan's monthly payments. Your name, email address, billing address and payment details go to Stripe; for a Groundwork plan our server also sends it your business's legal and trading names, your phone number and our reference number for you (if your Groundwork Addendum says you pay by check, nothing about you goes to Stripe); for a website project or Care & Hosting plan, our server sends Stripe your billing contact's name and email, your company name, our reference number for you, and any purchase-order reference you give us (if your agreement lets you pay by check, none of your billing details go to Stripe). Stripe handles them as its own controller under its privacy policy at stripe.com/privacy. Stripe is not embedded anywhere on this website or in the client portal: you reach it from a link on an invoice, the payment button on your private Groundwork link, or the link we email you (also shown on your portal Billing page) to put a card or bank account on file for a Care & Hosting plan, and paying happens on Stripe's own pages. Separately, our bookkeeping reads our own Stripe account with a key that can only read: Stripe's fees, its payouts to our bank, and the invoices of Groundwork plans, paid and unpaid. That key cannot charge, refund or pay out anything, and our bookkeeping sends Stripe nothing about you.
• Zoom (Zoom Communications, Inc., United States), the service we use for video calls. If you join one of our calls, the call runs on Zoom's systems: Zoom receives the name you enter, your email address if you are signed in to Zoom, your IP address and device details, and whatever you share during the call (sound, video, screen and chat). Zoom handles this under its own privacy statement on zoom.com. We send Zoom nothing about you: the invitation is only a link, and Zoom is not embedded anywhere on this website or in the client portal.
• Google Voice (Google LLC, United States), the phone service we use to call and text people who contact us. When we call you, or text you in reply to an enquiry, the call or text runs on Google's systems, and the texts and your number are kept in our Google Voice account. Google handles this under its own privacy policy at policies.google.com/privacy. We type each text ourselves; neither this website nor our portal sends Google anything.
• An automated voice-call service, which carries calls between our client portal and our own mobile phone. The portal can ring us when there is a security alert, when a site we host is down (including when a client tells us so through a request), when a client's request is due and we have not started it, when work is waiting for our approval, when a business that replied to one of our emails is ready for a call, and in the morning with a summary of what needs us that day; and we can ring the service's number to ask how things stand. For each call the portal gives the service a short, read-only status, which it reads out to us and uses to answer our questions on that call. The status can include a client's business name and website address, that the site is down and what our checks found, which of the client's invoices are late and by how long, whether a plan payment has failed, totals of past-due invoices and of checks received, and the next steps on their project. It never includes anyone's email address, phone number, street address, check number, bank details or card details. Businesses we contact before they are clients, and messages sent through our contact form, appear in it only as a number. The service carries the sound of each call and turns what is said into text so that it can understand and answer; it keeps a written transcript and summary of each call in our account for as long as its own terms allow, and deletes them when we ask it to. Its recording feature is switched off. Anyone else who answers our phone hears only that the call is automated and transcribed, and the call ends. Anyone else who rings the service's number hears one fixed sentence saying the line takes no calls and is transcribed, and the call ends; the service still receives their phone number and, if they speak, the text of what they said, and keeps them with the call as above. Anyone who texts the service's number is sent an automatic reply, written by the service's software from our instructions; anyone else, and us whenever our call-in line is off, is told the number does not take messages and given our email address. The service receives their phone number and their message, reads the message to write that reply, keeps them as above together with a record of what it passed to our portal and the answer it got, and passes the message to our portal, which keeps nothing from it unless it comes from, or appears to come from, our own mobile and starts with our private code word, in which case it is written down as a note for us. The service's own memory feature, which would remember callers and texters from one call or text to the next, is switched off. While it was switched on, from October 19 to October 20, 2026, it may have kept the phone number of anyone who rang or texted the service's number, with details of those calls and texts. It is no longer used, and we will ask the service to delete it; if you rang or texted the number in that window, you can also ask us to under section 11. The service may use its own sub-providers to do this, under its data processing terms with us, and may use information about how its service is used, made so that it no longer identifies anyone, to improve its products. It cannot see or change anything else in our systems, and nothing said on a call or sent by text is acted on unless we later do it ourselves.
• A writing-assistance service, which helps us draft the wording of a Groundwork client's website from the business details in their intake answers: the business's name, town, area and hours, its services, the promises it ticked and what it told us about itself. It does not receive payment details, the business's street address, or the names, email addresses or phone numbers of the owner or the person who approves the site. It also helps us draft the Local Growth Plan and the monthly service's posts, emails and review replies, from intake answers and public review text; it never receives a client's customer list.
• An email delivery service, which sends the emails of Local Growth monthly from a client's own email domain. It receives the name and email address of each customer the email goes to, and the email itself, and is used for nothing else.
• Microsoft (Microsoft Corporation, United States), which provides the mailbox at velcrestweb.com that our emails to businesses come from (section 17). Those emails, the replies to them and any delivery-failure notices pass through, and are stored on, Microsoft's systems under its data processing terms with us. velcrestweb.com is a second web address of ours that leads to this website.
• An automated writing service, a separate company that, on our instructions, writes our emails to businesses and our answers to their replies, and sorts those replies (section 17). For a first email it receives the business's name and town and what our check of its website found. For an answer, it receives the text of the conversation so far, which includes whatever the business wrote, such as a person's name, a phone number or an email signature. We do not send it the business's email address separately, and it receives nothing else from our records.
• Google (Google LLC, United States), through the Google account we use to manage clients' Business Profiles and Search Console under Local Growth monthly. It holds what the client's profile and Search Console already hold, under Google's own privacy policy at policies.google.com/privacy; we send it only the posts and listing details a client approves.
• Our bank, for money that reaches us from Stripe, or by check where your agreement allows it in writing (a check you send shows our bank your account and routing numbers; in our billing records we keep only its number, amount and dates). Our bookkeeping reads the transactions on our own accounts and business credit card from the bank, as section 7 describes, and sends the bank nothing about you.
• Professional advisers — an accountant or a lawyer — where they need to see a record, under a duty of confidence.
• A subcontractor, if one is engaged on your project and needs access to do the work. They are bound to confidentiality and may use the information only for your project.
• Our sales contractors, independent contractors in West Virginia who call and visit local businesses for us and run website walk-throughs. Each signs in to a separate part of our client portal (and, if they choose, our phone app), with two-factor sign-in, and sees only the businesses we have given them to contact: our portal shows them the business's current public Google listing (name, address, phone number, hours, website, category and whether it is open) at that moment, without keeping it, and the notes they have made about that business's calls. They see no client records, invoices or bookkeeping, and nothing about a business another contractor is working. For a client they brought to us, they see the business's name, what it signed up for, and the date and amount of their commission on each payment. What they record goes into the record described in section 17. Their contractor agreement binds them to keep it confidential and to use it only for our work, and their access ends the day the agreement does.
• Google Maps Platform, which we use to find local businesses and to show us a business's current public listing. It receives Google's own reference numbers, not our notes. Our software also uses it, just before emailing a business, to confirm the business's current listing; nothing from it is kept.
• A cloud storage provider in the United States, which holds encrypted copies of the portal server's backups and security logs. They are encrypted before they leave us and the provider does not have the key, so it cannot read them.
• A password manager service, which holds the logins we keep for a client's accounts, such as a new mailbox's starting password, and any supplier's Form W-9 sent to us by email. They are encrypted on our own devices before they reach it, so it cannot read them.

We also use business tools that do not receive your personal information — for example, an uptime-monitoring service that checks from outside that this website and the sites we host are answering. It sees only the public web addresses it checks and what those pages return, the same as any visitor would, and its alerts go only to us. Our own server also checks the sites we host from outside, when one stops answering and once a day while it is up: whether its address points where it should, whether the server answers, whether its security certificate is valid, and when its domain registration runs out (from the domain registry's public record). It also reads our hosting provider's public status page. These checks send nothing about you. Likewise, when an enquiry, a job application or a client's request arrives, each business morning while requests are open, when one is due, when a reply to one of our emails to a business needs us, or when a site we host stops or starts answering, our server sends a notification to our own phone through the push service of the phone's maker (Apple or Google). It is encrypted so that the push service cannot read it, and it never names a person, a business or a web address. The calls to our own phone described above are different: they can name a client's business and its website address, which is why the service that carries them is listed above. If we ever add a provider that would receive your personal information, we will add it, or the type of provider it is, to the list above before it does. Some providers are described by type rather than by name; ask us and we will tell you which company it is.

We will also disclose information if the law compels it — a court order, a lawful request from a public authority, or where disclosure is necessary to protect someone's safety or to enforce our Terms of Service. If Velcrest is ever sold or transferred, client records may transfer with it, and you would be told before that happened.

11. Your rights

If you are in the United Kingdom, the European Economic Area or Switzerland, the law gives you the rights below. We extend the same rights to everyone who contacts us, wherever you are, because running two standards is not worth anyone's time.

• Access — ask for a copy of the personal information we hold about you
• Rectification — have anything inaccurate or incomplete corrected
• Erasure — ask us to delete it, where we have no overriding reason to keep it. If you ask us to delete a record of a business we contacted, we keep only what we need so that we don't contact you again (section 17). If you have rung or texted our automated call-in number, tell us the phone number you used and we will ask the voice-call service to delete its transcripts and texts of that number, and anything its memory feature kept about it
• Restriction — ask us to hold it but stop using it while something is disputed
• Portability — receive the information you gave us in a common machine-readable format, or have it sent to someone else
• Objection — object to any use we base on our legitimate interests, including the spam protections in section 5, and being contacted about our services. For our offer and follow-up emails, the unsubscribe link in each one is the quickest way
• Withdraw consent — where we ever rely on consent, withdraw it at any time without affecting what came before
• Automated decisions — no decision with a legal or similarly significant effect on you is ever made purely by automated means. The only automated decisions we make are the routine ones about our emails to businesses described in section 17, and the sorting of job applications described in section 21, which only decides which ones our phone is told about. If you would rather deal with a person, say so in a reply, or email or call us, and a person will take over

How to use them: email info@velcrestwebdev.com or call (304) 602-3470 and say what you want. There is no form and no fee. We will respond within one month, as the GDPR requires, and will tell you if a complex request needs longer. We may need to ask a question or two to be sure it is really you before we send personal information anywhere.

12. Sending your information to the United States

Velcrest is a United States business. This website and the mailbox that receives enquiries are hosted in a data center in Boston, Massachusetts, USA. If you write to us from the United Kingdom or the European Economic Area, your information is transferred to and processed in the United States.

The United States has not been found by the European Commission to provide an equivalent level of data protection in general terms, and US law can permit public authorities to access data in ways EU law would not. Where a safeguard is required for a transfer, we rely on the Standard Contractual Clauses approved by the European Commission, and the UK equivalent, as incorporated into our agreement with our hosting provider and into the data processing terms of the automated voice-call service.

For an enquiry you send us directly, we also rely on Article 49(1)(b) of the GDPR: the transfer is necessary to take steps at your request before entering into a contract, and to perform one. In plain terms — you cannot ask a Morgantown business for a quote without the question reaching Morgantown.

If you would like details of the safeguards in place, ask and we will provide them.

13. Our position on an EU and UK representative

First, whether the GDPR applies to us at all. It reaches a business outside Europe only where that business offers goods or services to people in Europe, or monitors their behaviour. Velcrest is a West Virginia business serving small and local businesses in and around Morgantown. We price in US dollars only, we do not sell or ship into the EU or the UK, our structured data describes a United States service area, we run no ads anywhere (the only promotional emails we send are the offer and follow-up emails in sections 3 and 17, including the emails to businesses described in section 17), and we do not track anyone; the only automated scoring we do is described in section 8. On the ordinary reading, we are not targeting people in Europe, and the GDPR does not apply to us by default.

Second, what we do anyway. Someone in Europe can still write to us through the form, and we would rather hold ourselves to this standard than argue about jurisdiction. So we apply the protections in this policy to everyone, wherever they are, and the rights in section 11 are available to you regardless of where you live.

Third, the representative. Article 27 of the GDPR — and the equivalent in the UK GDPR — requires some organisations outside Europe to appoint a local representative. It does not apply where the processing is occasional, does not include large-scale processing of special-category data or of criminal-offence data, and is unlikely to result in a risk to people's rights and freedoms. Our processing meets all three: a handful of unsolicited enquiries, the project records of any client who engages us, short records of United States businesses we contact, including our emails to them, and an unsubscribe list and records of offer and follow-up emails; no special-category data, no monitoring, and no profiling beyond the reply sorting described in section 17, which concerns United States businesses only. We have appointed no representative in the EU or the UK, and we have set out the reasoning here so you can judge it rather than take our word for it.

If we ever market to Europe, take European clients as a matter of course, or start processing European personal data as anything other than an occasional event, we will appoint representatives and name them on this page before that happens.

14. If you are in California

The California Consumer Privacy Act, as amended by the CPRA, applies to businesses that meet at least one of three thresholds: annual gross revenue over 25 million dollars; buying, selling or sharing the personal information of 100,000 or more California consumers or households in a year; or deriving 50 percent or more of annual revenue from selling or sharing personal information.

Velcrest meets none of those thresholds, so the CCPA does not currently apply to us. We are telling you that plainly rather than implying a compliance status we do not have.

Even so: we have not sold or shared personal information in the preceding twelve months, we do not do so now, and we have no plans to. We do not use personal information for cross-context behavioural advertising. We collect no sensitive personal information through this website. If you are a California resident and you want to know what we hold, have it corrected, or have it deleted, ask under section 11 and we will handle it the same way we handle every other request — and we will not treat you differently for asking. If we ever cross a threshold, we will update this section before we do anything that requires it.

15. Cookies and browser storage

This website sets no cookies at all. Not analytics cookies, not advertising cookies, not preference cookies, not session cookies. It does not use local storage or session storage. Nothing about your visit is written into your browser, so there is no consent banner because there is nothing to consent to.

The client portal is the one exception, and only once you sign in. It runs on its own separate address, which we give clients with their invitation, and it stores a sign-in token in that site's own local storage so you are not asked for your password on every page. That is strictly necessary to keep you signed in, it is a token rather than your password, it is never sent to anyone else, and clearing your browser data or signing out removes it. Nothing is written to your browser by simply visiting this marketing site.

The Groundwork page your private link opens stores nothing in your browser: its short session is held only in the page's memory and ends when you close the tab, sign out, or after 30 minutes without use. Your Groundwork request page works the same way.

The unsubscribe page an offer or follow-up email links to is on this website and stores nothing in your browser either. Some of our earlier emails link to the same kind of page on the client portal instead, which also stores nothing in your browser.

The hand-over pack page works the same way: nothing is stored in your browser, and its session ends when you close the tab, after 30 minutes without use, or after 2 hours at most.

Our fonts are served from our own server. This site loads no scripts, stylesheets, images, frames or trackers from any third-party domain, so no other company learns that you visited.

Because we do not track anyone, there is nothing for a Do Not Track or Global Privacy Control signal to switch off. We honour them by default, in the sense that we were never doing the thing they ask us to stop.

16. The client portal

The client portal is a separate application at its own address, which we give clients with their invitation. It runs on our own virtual server in Boston, over HTTPS, and it is used by clients during a project. This marketing site itself still has no sign-in and no account system.

You cannot create an account there. There is no sign-up form, and the registration endpoint refuses anyone who is not already an administrator. Once a project is agreed we send an invitation to your email address. Its link asks you to tell us who you are — your name, your company and your business's street address, and if you choose, your job title, a phone number and what the business does — and we check those details ourselves before any account can be used. We use the street address to confirm who you are, and on your agreement and invoices. We never publish it, never use it for marketing, and never send it to anyone other than the providers named in section 10. If you run the business from your home, this is your home address; it is handled exactly as described here, and we do not publish it. Only then do you receive a second link to set your own password. We never choose a password for you and never email you one, so nobody but you ever knows it.

Why there are two steps. An invitation can be mistyped and reach the wrong person, and we would rather add a step than let your project paperwork open to a stranger. For the same reason, when an invitation link is opened and when its form is sent, the portal records the IP address and the browser type of whoever did it, so that we can see whether the invitation reached the person we meant. We look at that record when we approve the account, and for nothing else. We do not look up a location from it, and it goes nowhere beyond the host and mail provider named in section 10 and, encrypted, the cloud storage provider described there.

What the portal holds: your name, email address and phone number if you give one; a job title if you set one; your company name, your business's street address and what the business does, as you entered them; the hash of your password, never the password itself; which of the four project phases you are in; screenshots you or we upload, and the comment threads attached to them; the documents we send you to complete, and the completed copies you upload; your answers to the project questionnaire, if you or we complete it in the portal — the pages and features you want, who is supplying the wording, photographs and logo, and whether you want us to host the site; any fee schedule we issue to you, which sets out the prices, payment method and target dates for your project; your billing contact's name and email, and any second email to copy and purchase-order reference you give us; your invoices (number, items, sales tax, totals, status, and PDF copies of check invoices); for check payments, the amount, check number and the dates each check was received, cleared or returned; your Care & Hosting plan, its billing dates, whether a payment method is on file with Stripe, and any changes; a log of billing actions, kept with the invoices; once an invoice is paid, a line in our own bookkeeping ledger with your company name, the invoice number and the amounts, and, when that money reaches our bank, the bank's record of the deposit, linked to your invoice or check; and a log of the invitation steps described above — sent, opened, details received, approved or declined — with the IP address and browser type behind each one. That log, the hand-over pack log described in section 9, the Groundwork records described below, and the security record of our sales contractors' accounts (section 21), are the only places the portal's database stores the IP address of anyone other than us. Separately, the portal's server keeps security logs of connections to it; section 9 says what they hold and how long they are kept. The portal also keeps a security record of what our own administrator account does, such as sending an invitation or working on a business record, with our own IP address and browser type, so that we can tell if that account is ever misused. Those IP addresses are removed after 90 days. It keeps you signed in with a token in that site's local storage — a token, not your password.

Offer and follow-up emails. The portal's database also holds the records of the offer and follow-up emails described in sections 3 and 17, and the unsubscribe list, and the portal sends those emails and records each unsubscribe that the unsubscribe page on this website passes to it (older emails link to an unsubscribe page on the portal itself). To see whether an address is a client and must not be sent them, it checks the address against its own client records; nothing is sent anywhere for that. Only our administrator account can see them. Section 9 says how long they are kept.

Website enquiries. The portal's database also holds the short copy of each contact-form message described in section 3, and the portal tells our own phone when one arrives. They can be seen only in our own phone app, behind its PIN or Face ID; they are not part of any client's portal account, and the portal deletes each one 14 days after it arrived.

Calls to our own phone. The portal's database also holds the records of the calls described in section 10. Only our administrator account can see them, and section 9 says how long they are kept.

If one of our sales contractors brought you to us, they can see your business's name, what you signed up for, and the dates of the payments their commission is counted on, for as long as it is counted. They never see the amounts you pay, your invoices or anything else in your records.

Requests. If you have a Care & Hosting plan, the portal's Requests page lets you ask us to change something, tell us something isn't working, ask a question, or tell us your site is down. A Groundwork client whose site is live does the same from their own request page (below). The portal keeps what you write, the kind of request, your plan, when it reached us, the day it is due to be addressed under your plan agreement, each step it goes through, the notes you and we add, and any files you attach: photos (JPEG, PNG, WebP or GIF), PDFs, and Word (.docx) or Excel (.xlsx) files without macros, up to five a request, 10 MB each and 19 MB together, scanned as described below. Each step is emailed to you, at your portal sign-in address or, for Groundwork, the address on your agreement. When a request arrives, the portal emails it to us and sends a notification to our own phone that never names you or says what you wrote (section 10). We can also read open requests, with their notes and the number of files attached, in our own phone app, behind its PIN or Face ID; nothing from them is stored on the phone, the files themselves cannot be opened there, and marking a request as being worked on or done from it sends you the same emails described above.If a request has not been started by 11 AM Eastern on the day it is due, or you tell us your site is down, the portal can also ring our own phone through the automated voice-call service in section 10; that call gives only the request's number, never your name or what you wrote, and a site-down report rings it at most once a day for each client, and not overnight: one sent at night rings in the morning. While a request is open, our own morning email and a reminder on its due day list it by your business name and request number. A request that is ready for you to check is marked done after 14 days without word from you. Please don't put passwords, card numbers or health information in a request; ask, and we'll arrange a safer way to send them. Section 9 says how long requests and their files are kept.

Everything you upload is scanned for malware — screenshots and completed documents alike — with ClamAV on our own server, after upload and before anyone can open it. A file that is found to be infected is deleted immediately. A file that cannot be scanned is never treated as safe: it is held, and is neither displayed nor made available to download. Completed documents are accepted only as PDF or Word (.docx) files; Word files that contain macros are refused. Files are stored outside the web root and are only ever served to people entitled to see them. If a client is removed from the portal, their uploaded files are deleted along with their record. Invoices and payment records are kept as section 9 says, even if the portal record is removed. A Groundwork client's uploads are kept as section 9 says.

The progress view shows you information about your own project; it does not track you. The comment threads reach us on the same server. No analytics, no advertising and no tracking. Beyond the host and mail provider named in section 10 and the encrypted cloud storage described there, the portal sends personal information only to: Stripe (section 7); Google, for the lookups in section 17; the automated voice-call service; the writing-assistance service and email delivery service used for Groundwork and Local Growth work; and Microsoft and the automated writing service used for our emails to businesses (section 17). The portal holds none of your card or bank account details. For Groundwork clients it opens Stripe's own payment page and sets up the monthly payments with Stripe, or, if your Groundwork Addendum says you pay by check, issues your invoices itself as PDF files and records each check, as section 7 describes. For custom-site clients it creates and tracks your invoices with Stripe, or, if your agreement lets you pay by check, issues them itself as PDF files; for a Care & Hosting plan it sends you a link to Stripe's own page to put a card or bank account on file, and sets up the monthly charge with Stripe.

Groundwork clients. A Groundwork client does not get a portal account. We create your Groundwork record ourselves from what you have told us (your business's legal and trading names, your name, email address and phone number, your business's street address, your number of pages and response level, and your domain if you have one) and email you a private link, which works for 30 days. Your street address goes only on your agreement and our records; it is never published. Each time you use it, the portal emails a 6-digit code to the address on your agreement; entering it opens a session that ends after 30 minutes without use, or after 4 hours at most. Once your site is live that link stops working, and we can send you a separate link to your request page, which works the same way, with the same codes, for as long as your site is live; sending a new one switches the old one off.

Signing the Groundwork Addendum. When you sign, the portal keeps a signature record: an exact copy of the addendum you were shown and its SHA-256 fingerprint; your Section 1 details; your initials on each initialled statement; the consent wording you ticked; the name and title you typed; the time you signed; when and to which address your code was sent and entered; and the IP address and browser type your signature came from. We email you a copy straight away. We do not look up a location from the IP address. If you send us a question before signing, it is emailed to us and its first 200 characters are kept in your record's log.

Your intake form. After your first payment clears, the link opens your intake form. Your answers are saved on our server as you type, never in your browser. They can include your business's contact details and hours, your services and the promises you choose, what you tell us about your business (such as the year you started and any licence or insurance), your colour and request-form choices, your domain details, links to your Google Business Profile, Facebook, Instagram or other pages, notes, and the name and email address of the person who approves your site; if that is someone else, please let them know. Logo and photo uploads are accepted only as JPEG, PNG or WebP, up to 15 MB each, and are scanned as described above. Your draft site is built on our own server from your answers and your virus-checked uploads; the private preview link we send you works for 30 days.

The log. The portal logs each Groundwork step (link sent, code sent and entered, question asked, signed, each invoice sent and each check recorded, cleared or returned, paid, intake sent, built, approved, each change to your live site as it is started, published or undone, a list refresh started, changed or stopped, the day each point-of-sale export arrived and the day your lists were updated, each product-list import with the number of items, and the Care & Hosting level you choose for month 13, your request link being sent, each request-page code sent, entered or wrong, and the link being switched off) with the IP address for the steps you take yourself.

Your payments in our books. When a monthly payment is paid, our bookkeeping reads that invoice from Stripe (section 10) and keeps its number, amount, sales tax and the day it was paid, recorded in our ledger under your business's name, together with Stripe's fee on it. They are kept as section 9 says for payment records. If you pay by check, each invoice is recorded in our ledger under your business's name once its checks have cleared, and each invoice and each check we receive is counted in our sales-tax records under your business's name. While a monthly invoice is still unpaid, our bookkeeping also keeps its number, amount and dates, so that we can see what is owed to us. That record is removed the next time our bookkeeping reads Stripe after the invoice is paid, cancelled or written off, or straight away if our bookkeeping stops reading Stripe.

17. Businesses we contact before they are clients

We are a small local business, and part of our work is contacting local businesses that might want a website, by phone or by email. When we do, we keep a short record so that we don't lose track of a conversation or call anyone twice. We only contact businesses in the United States.

How we find you

Our own software searches public Google Maps listings for local businesses, reads each business's own website to check how well it works and to find the email address the website publishes, and emails us a short list each morning. It may check a website again later to see whether a problem is still there. It does not visit Facebook, Instagram, LinkedIn or Google search pages. Owner names come only from a business's own website.

What the record holds

• The business's name as your own website gives it, or as we type it in; details you give us; what your business publishes on its own website (its email address, links to its public pages such as Facebook or Instagram, and the owner's name if your website states it); and an email address that a person at Velcrest copies by hand from your Facebook page, Instagram page or Google Business Profile, with where and when it was found.
• Links or short pieces of text we choose to save from public pages we have opened ourselves, such as your Facebook or Yelp page. Nothing is collected from those pages automatically.
• If we add a business by hand, the details we type in, such as its town and phone number, and a priority mark we set for our own planning.
• Google's reference number for the business's map listing. That number is the only thing our software keeps from Google. When we open the record, or just before our software emails a business, the current listing (name, address, phone number and hours) is fetched from Google Maps at that moment. It is used then, to show it to us, to check we have the right business, or to show us the number to call, and it is not kept. If we copy an email address by hand from your Google Business Profile, we keep that address and note where and when we found it.
• Our notes of calls, visits and what was agreed, the date we plan to follow up, and any walk-through we arrange (below).
• If one of our sales contractors (section 10) contacts you: what happened on each call (no answer, call back, booked, not interested, or do not contact), the day to call back, the business's name and the name and email address of the person they spoke to as given on the call, short notes about the business, and which contractor made each call. Notes on calls are deleted 12 months after they were written unless you become a client.

If you're not interested

We erase the record down to three things: Google's reference number (or, for a business we added by hand, its phone number), the state it is in, and the words "Not interested"; and, if we ever emailed you (a flyer or one of the emails described in section 17), your email address on the unsubscribe list, so that you are never sent another.

How to say no

Tell us on the call, by email or by phone that you don't want to hear from us, and we won't contact you again. Saying no to one of our sales contractors is the same as saying no to us: it takes your business off every contractor's list at once. Our sales contractors call only between 8 AM and 9 PM where your business is, give their name and ours on every call, and record a request not to be called so that no one from Velcrest calls again. If we have emailed you a flyer, its unsubscribe link does the same for email. If we have emailed you, reply "unsubscribe" and we won't email you again from any of our addresses.

Why we are allowed to keep it

Our legitimate interest in offering our services to local businesses, and in respecting a "no" once you have said it (for anyone the GDPR covers, Article 6(1)(f)). You can object at any time, and we will stop.

Who can see it

Only us and the service providers named here and in section 10. Our emails to businesses, and the replies, pass through Microsoft, which provides the mailbox they are sent from, and the automated writing service described in section 10. The record is kept in the client portal's database on our own server (section 16) and in the backups of that server described in section 18. Our administrator account can reach every record, behind two-factor sign-in. A sales contractor (section 10) can reach only the records of the businesses we have given them, while they are working on them, and their own phone app shows the same behind its own PIN or Face ID. A contractor's phone shows your business's number only between 8 AM and 9 PM where your business is. When we open a record, Google's reference number, and nothing we have written, is sent to Google to fetch the current listing. Our software also sends Google a business's reference number just before it emails that business, to check the current listing; what comes back is used at that moment and not kept. When we act on a business from our morning email, the listing's phone number is also checked against our do-not-contact list, and it is not kept. When we open a record we may also read your business's own website again, to suggest its name, email, social links and owner's name as the site states them. Our morning search skips any business already in our records or marked "do not contact"; the list it checks against sits on the same server. If we search for your business on Google ourselves, its name and town go to Google as an ordinary search from our own browser. The record is never sold.

How long we keep it

• While we are talking to you. If we stop talking without a decision, the record is deleted 12 months after our last contact.
• If you become a client, the record is closed and kept, with its notes, alongside your client file for as long as client records are kept (section 9).
• If you're not interested, the "Not interested" note is kept until our search has worked through every town in your state. After that we keep only Google's reference number (or the phone number, for a business we added by hand), so that we never call you again.

Deleting it

Ask, and we delete the record and every note on it. We keep one thing: Google's reference number (or, for a business we added by hand, its phone number), marked "do not contact", so that we don't contact you again by mistake. It says nothing else about you. If we ever emailed you (a flyer or one of the emails described in section 17), your email address also stays on the unsubscribe list, so that you are never sent another. Copies in our backups disappear as older backups are replaced (section 18).

Flyers by email

If you say yes on a call to getting one of our flyers by email (Groundwork, or custom websites), we send it from news@velcrestwebdev.com to the address you give us, and replies come to info@velcrestwebdev.com. We keep a record of it: the address, which flyer, the date and time, that it was agreed to on a call, the name of the person who agreed as they gave it, and which of us sent it. A note saying the same goes on the record above. The flyer is fixed wording with no tracking, and it tells us nothing about whether you opened it.

Every flyer carries an unsubscribe link, which opens a page with one Unsubscribe button, and the one-click unsubscribe option many mail apps show. Once your address is on the unsubscribe list we cannot send it a flyer or any other marketing email again, from news@velcrestwebdev.com or from our velcrestweb.com address, even by mistake, and anything still waiting for it is cancelled. If we have sent you a flyer and you then tell us you're not interested, or ask us to delete your record, that address goes on the list too. Section 9 says how long these records are kept.

Walk-through invitations

When you agree to a walk-through, we email you an invitation at the address you give us, with a calendar file so you can add it to your calendar. The email and the file hold the date and time, how long it will take, where it happens, your email address, and your first name in the greeting. We keep a note of the invitation (the time, the type of meeting, the place if we are meeting in person, and the address it went to) with the record above. The email has no tracking, and it tells us nothing about whether you opened it.

• On Zoom: the invitation carries the link to our Zoom meeting room, the same link we use for our other calls; a waiting room means nobody joins a call until we let them in. When you join, Zoom runs the call as described in section 10. We don't create a Zoom account for you, and we don't send your details to Zoom; only what you choose to enter or share when you join reaches them. We don't record calls, and Zoom's automatic summaries and transcripts are switched off for our calls. If we ever want to record one, we will ask first, and record only if everyone on the call agrees.
• In person: the invitation carries the place we agreed to meet, and nothing is shared with anyone else.
• With one of our sales contractors: the invitation names them and carries their own Zoom meeting link, so the call runs on their Zoom account under Zoom's terms. We send Zoom nothing about you. Their agreement with us bars recording, transcripts and automatic summaries.

Emails we send to businesses first

Some businesses we find get an email from us before we have spoken. We send one only when our checks find a specific reason a business might want a website now: for example, its website is not working, shows a security warning or a "coming soon" page, or the business has a Facebook or Instagram page but no website. Each email is plain text, written to one business, and sent from our address at velcrestweb.com. It has no tracking pixels or tracked links, so we cannot tell whether you opened it. The email says it is a business solicitation, where and when we found your address, and how to stop further emails.

Where your address comes from. Only from a page your business publishes. Either our software read it on your own website, or a person at Velcrest opened your Facebook page, Instagram page or Google Business Profile and copied it by hand. We never guess addresses, buy lists, or have software read Facebook, Instagram or Google pages.

Who writes them. The emails, and most answers to replies, are written by the automated writing service described in section 10, from a fixed set of facts about our services and our published prices. Before anything is sent, our own software checks it against fixed rules: only facts our checks found, only our published prices, and no promises of dates. Anything that fails is held and not sent. Emails that pass are sent without a person reading them first.

What happens when you reply. Our software reads each reply as it arrives and does one of these things:

• If you ask us to stop, or your reply reads as a "no", your address goes on our unsubscribe list. Nothing more is sent to it from any of our addresses.
• If you ask about what we offer, our published prices, how our plans work, or examples of our work, it may answer. It sends at most four answers in a conversation, between 7:00 AM and 9:00 PM Eastern.
• Any other reply goes to a person at Velcrest, and the software sends nothing more in that conversation. This always includes questions about the email itself, how we found your address, or whether it was written by a person, and any complaint.
• If you ask to talk, give a phone number, ask how to start, or the writing service scores a call as very likely to be welcome, the software stops writing and a person at Velcrest is asked to phone you. We use the number you gave, or your business's published number.

These decisions only settle whether the software answers you, whether a person takes over and may phone you, or whether we stop writing. They do not affect any price, offer or terms. If you would rather deal with a person from the start, say so in a reply.

How often. If you don't reply, we send at most one follow-up, about four business days later, in the same conversation. If the reason was a website problem, we only send it if a fresh check shows the problem is still there. After that we don't email the same business again for at least 12 months. If a conversation leads somewhere, it becomes the record described above, with the emails kept as notes.

Saying no. Reply "unsubscribe", or anything that asks us to stop. Your address then stays on the unsubscribe list, as section 9 describes.

Why we are allowed to. The same legitimate interest as above (Article 6(1)(f)). You can object at any time.

18. How we protect information

What is actually true, stated without exaggeration:

• The site is served over HTTPS with a valid TLS certificate, so what you type into the form is encrypted between your browser and our server
• Enquiries are not stored in a database on this website; there is no database of enquiries on this website to breach. The contact form passes on only two things, both to the client portal's database on our own server (section 16) over an encrypted, signed connection: the short copy of your message described in section 3, which is deleted after 14 days, and your email address when the offers box is ticked. The job application form passes on the application and any résumé, as section 21 describes. The Groundwork sign-up form passes on only the email address you give, as section 3 describes. The unsubscribe page passes on only the code in your link and whether you used the button or your mail app's option, the same way (section 3)
• Access to the mailbox, the hosting account and project files is limited to Velcrest personnel, and to any subcontractor who needs it for a specific project
• Accounts we control are protected by unique passwords, and by a second authentication factor where the provider offers one
• All three forms carry the abuse protections described in section 5

We back up the portal's server regularly. The backups are copied to our own computer, and an encrypted copy is kept in cloud storage that cannot read it. We keep the five most recent backups on our own computer, and the encrypted cloud copies for no more than 30 days; anything deleted from the portal drops out of them as older backups are replaced. The portal server's security logs are copied, encrypted, to the same storage and deleted after 90 days.

Our bookkeeping only ever asks our bank and Stripe to read. The bank key is one we create as read-only in the bank's own settings, so it can see the transactions on our accounts and our business credit card but cannot send money or set up payments; the bank gives our software no way to check a key's permissions, so that setting is ours to get right. The Stripe key is a separate restricted key for fees, payouts and invoices; before saving it, our software checks with Stripe that it cannot charge, refund, pay out or change customer records, or read customers, charges or payment methods, and refuses it otherwise. Both keys are kept only on the portal's server, readable only by the portal's own account, and are never displayed again once they have been entered. Receipts kept in our bookkeeping are scanned for malware before they can be opened, and only our administrator can open them, after the same separate authenticator code that opens the bookkeeping.

Your message reaches us as ordinary email, which is not encrypted end to end along its whole path. That is why section 3 asks you not to send sensitive information through the form. No method of transmitting or storing information is completely secure, and we will not claim otherwise. If a breach ever affects your personal information and creates a risk to you, we will tell you and the relevant authority as the law requires.

19. Children

We sell services to businesses. This website is not directed to children, and we do not knowingly collect personal information from anyone under 13, or under 16 where local law sets that age. If you believe a child has sent us information through this site, tell us and we will delete it promptly.

20. Complaints, and how to reach us

If something here concerns you, raise it with us first — a real person reads the mail, and most things are resolved in a single reply. You will generally hear back within one business day.

Email: info@velcrestwebdev.com
Phone: (304) 602-3470, Monday to Friday, 9:00 AM to 1:00 PM Eastern
Fax: (304) 407-4850
Location: Morgantown, West Virginia, United States

If you are not satisfied, you have the right to complain to a data protection authority. In the United Kingdom that is the Information Commissioner's Office (ico.org.uk). In the European Economic Area it is the supervisory authority in the country where you live, where you work, or where you believe the problem happened; the European Data Protection Board lists them at edpb.europa.eu. You do not have to come to us first, though we would rather you did.

21. People who apply to work with us

Our Careers page lists the roles we are looking to fill. Each job page has an application form. It collects the role, your name and email address (required), your phone number if you choose to add one, your answers to the questions on the page (whether you live and work in West Virginia, whether a commission-only contractor role suits you, your years of experience and, for the closer role, whether you have closed sales by phone or video), anything you write about your experience, and, if you attach one, a résumé as a PDF file of up to 2 MB. We use it only to consider you for the role you applied for, or one like it, and to contact you about it. Please don't send your Social Security number, date of birth, bank details or anything about your health: we never need them to look at an application.

Where it goes. The form is protected in the same way as the contact form (section 5), with its own separate counts. Once it passes those checks, our web server sends your application to our client portal (section 16) over an encrypted, signed connection; the request comes from our web server, not from your browser, so your IP address is not passed on. It also emails your answers, without the résumé, to info@velcrestwebdev.com. Your IP address is not recorded with your application; the form only uses it briefly to make the one-way fingerprint for its limits described in section 5. A résumé sent through the form is stored in the portal, where our server checks it for viruses before anyone can open it; a file that fails the check, or can't be checked, is never opened, and a file found to be infected is deleted at once. If we download a résumé to read it, we delete that copy once we've finished considering your application. If you email us your application or résumé instead (the form suggests this if something goes wrong), it rests in our mailbox like any other email and is deleted on the same schedule.

Who sees it. Only our administrator account can see applications. Our own phone app, which opens only with a PIN or Face ID, also lists recent applicants who answered yes to both of the yes-or-no questions, with their name, role, years of experience, phone number and email address, so that we can call or email them. It never shows the résumé or what you wrote, and nothing from it is stored on the phone. When an application meets the role's basic requirements, our own phone gets a notification that says only "New job application", with nothing you typed in it. Our portal sorts each application by your two yes-or-no answers: if you answered no to either, it is marked as not a fit and our phone is not told about it. A person still reads every application, and no decision about one is made by software alone. With each application we also keep its status and any short note we add.

Applications are not sold, shared or added to any mailing list, and nothing about them goes to any service other than our host and mail provider and the encrypted backup storage described in section 10. If we don't take you on, your application and résumé are deleted from the portal, and the email copy from our mailbox, within 12 months of when you sent them; tell us if you would like them deleted sooner. If you start working with us, your application is kept with your contractor file for as long as you work with us and seven years afterwards, and the tax and payment records that go with it are kept as section 9 says. The rights in section 11 apply to applications too.

If you work with us as a sales contractor, your portal account holds your name, email address, your role, the name we show businesses and the other contractor, whether your signed agreement and W-9 are on file (the W-9 itself is kept printed or in encrypted storage, never in the portal), your meeting link, the times you mark open, your connected phone, the calls and deals you record, your commission on each client payment and what we have paid you. It also keeps an activity record of your account, on the web and in our phone app: each sign-in and each wrong password or authenticator code, each lead you open, call you log, walk-through you book, deal you record and commission page you view, and each action the portal refuses, with the time, the IP address and the type of device and browser. Only our administrator account can see that record. It is not shown to you in the portal, but you can ask us for a copy (section 11). If our business phone line records your calls (section 10), only our administrator can hear the recordings, and you can't reach them. Only you and our administrator can see your own commission. Section 9 says how long all of this is kept.

22. Changes to this policy

We will update this policy when our practices change — for example when we add something to the client portal. The date at the top of this page always tells you when it last changed, and the current version is the one published here.

If a change materially affects how we handle information we already hold about you, we will tell the clients affected directly rather than relying on you noticing a new date.