+++
title = 'Privacy Policy'
date = 2026-02-08T08:00:00-00:00
description = ''
+++

The right to privacy is a fundamental human right. We protect it not just because it is the law, but because it is the
right thing to do. We respect and value the privacy of everyone who visits this website, (“Our Site”) and will only
collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and
your rights under the law.

Below is our privacy policy, which contains a lot of legal references, but know that SR2 Communications Limited does not
merely set out to comply with the legislation but to hold itself to a higher standard.

Please read this Privacy Policy carefully and ensure that you understand it.

## 1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Our Website”
: means any website or service designed for electronic access by mobile or fixed devices which is owned or operated by
us. It includes all web pages controlled by us.

“Services”
: means all of the services available from Our Website, whether free or charged.

“Account”
: means an account required to access and/or use certain areas and features of Our Site;

“Cookie”
: means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or
when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”
: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

## 2. Information About Us

Our Website is owned and operated by SR2 Communications Limited, a limited company registered in Scotland under company
number SC692687.

E-Mail Address: support@sr2.uk.

Registered Office: 499 Union Street, 2nd Floor, Aberdeen, AB11 6DB.

We are registered with the Information Commissioners Office, registration number ZB036723.

## 3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Website and Our Services. Our Website may contain links to other
websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we
advise you to check the privacy policies of any such websites before providing any data to them.

## 4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data
Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable
person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers
obvious information such as your name and contact details, but it also covers less obvious information such as
identification numbers, electronic location data, and other online identifiers.

## 5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold, regardless of
your geographical location or citizenship (we will not refuse requests solely on the basis that you are not in the
European Union):

* The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you
  everything you need to know, but you can always contact us to find out more or to ask any questions using the details
  in Part 15.
* The right to access the personal data we hold about you. Part 13 will tell you how to do this.
* The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
  Please contact us using the details in Part 15 to find out more.
* The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that
  we hold. Please contact us using the details in Part 15 to find out more.
* The right to restrict (i.e. prevent) the processing of your personal data.
* The right to object to us using your personal data for a particular purpose or purposes.
* The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your
  personal data, you are free to withdraw that consent at any time.
* The right to data portability. This means that, if you have provided personal data to us directly, we are using it
  with your consent or for the performance of a contract, and that data is processed using automated means, you can ask
  us for a copy of that personal data to re-use with another service or business in many cases.
* Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us
using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you
changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local
Citizens Advice Bureau. You can also learn more about digital privacy at the EFF's website.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with
the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so
please contact us first, using the details in Part 15.

As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our registered
office for this purpose.

The supervisory authority responsible for our place of business is:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, ENGLAND

## 6. What Data Do You Collect and How?

If you become a customer we collect and process Personal Data to be able to offer our Services. The data are either
provided by you, or acquired by your use of our services. Unless provided by you or acquired by your use of our
services, we do not attempt to capture this information deliberately through your use of Our Website, however it may be
collected as a side-effect when you contact us through Caller ID, e-mail headers or signatures, or other communications
metadata.

Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any
‘special category’ or ‘sensitive’ personal data or data relating to criminal convictions and/or offences. Please find
below an overview of the types of data we process:

* Identity information: type of customer (individual, business, NGO), name, title, address, place of residence
* Contact information: email address, telephone number.
* Contact history: a record of past interactions, including emails, call dates, and conversation summaries.
* Payment information: such as credit card information and ways of payment.
* Business information: business name, job title, profession.
* Technical information: IP address, browser type and version, operating system.
* Other details: other information actively provided by you while placing an order, in email correspondence, or by
  phone.
* Service information: services you are subscribing to

## 7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table
describes how we may use your personal data, and our lawful bases for doing so:

| What We Do                                                                                                                                                           | What Data Do We Use                                                                                      | Our Lawful Basis                                                                                                                                                                    |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Communicating with you.                                                                                                                                              | Identity, contact, technical and service information, as well as contact history.                        | Legitimate Interests: responding to communcations that you have initiated or if this is required to deliver our Services or inform you of any changes in our Products and Services. |
| Supplying you with information by email, post, or messaging service that you have opted-in-to (you may opt-out at any time by using the contact details in Part 15). | Identity information, contact information, and technical information.                                    | Consent.                                                                                                                                                                            |
| Allowing you to create an account and providing you with Services.  |                                                                                                  | Identity, contact, business and service information, as well as other details as described in Section 6. |  | Legitimate Interests: as required to deliver our Services and meet legal requirements.                                                                                             | 
| Handling your payment.  |                                                                                                                                              | Identity, contact, business, service and payment information.  |                                           | Legitimate Interests: as required to deliver our Services and meet legal requirements.                                                                                              |

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may
include contacting you by email, post or messaging service with information, news, and offers on our products and
services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and
comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC
Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer
to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third
parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such
third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably
believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for
that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible
with the original, please contact us using the details in Part 15. If we need to use your personal data for a purpose
that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and
explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may
process your personal data without your knowledge or consent. This will only be done within the bounds of the Data
Protection Legislation and your legal rights.

## 8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first
collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the
following factors will be used to determine how long it is kept):

| Type of Data                       | How Long We Keep It                                                                                                                                                               |
|------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Identity and Service Information   | Two years since last contact, or in case of contracts and invoices up to seven years after we have ceased to provide you with Services, as needed to meet any legal requirements. |
| Contact information.               | Two years since last contact, or in case of contracts and invoices up to seven years after we have ceased to provide you with Services, as needed to meet any legal requirements. |
| Contact history and other details. | Two years since last contact.                                                                                                                                                     |
| Business information.              | Two years since last contact, or in case of contracts and invoices up to seven years after we have ceased to provide you with Services, as needed to meet any legal requirements. |
| Payment information.               | Two years since last contact, or in case of contracts and invoices up to seven years after we have ceased to provide you with Services, as needed to meet any legal requirements. |
| Technical information.             | Three months since collection.                                                                                                                                                    |

## 9. How and Where Do You Store or Transfer My Personal Data?

If you’re in the EEA or UK, we’ll only transfer your personal data to countries that provide adequate protection for EEA
and UK personal data, or to countries where we have appropriate safeguards in place with the recipient to protect your
personal data, for example, by entering into “Standard Contractual Clauses”. For more information, please contact us by
emailing support@sr2.uk.

Third-party data processors we use are:

* [Hetzner Online GmbH](https://www.hetzner.com/legal/privacy-policy/)
* [Stripe, Inc.](https://stripe.com/gb/privacy)
* [Stablepoint](https://kb.stablepoint.com/docs/privacy-policy)
* [Migadu-Mail GmbH](https://www.migadu.com/privacy/)
* [Xero Limited](https://www.xero.com/uk/legal/privacy/)
* [ClouDNS](https://www.cloudns.net/privacy-policy/)
* [Amazon Web Services, Inc.](https://aws.amazon.com/compliance/gdpr-center/)

## 10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exception:

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if
we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a
government authority.

## 11. How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via
Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong
controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails
from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your
details).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference
Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the
MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not
prevent you from receiving marketing communications that you have consented to receiving.

## 12. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and
functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14.

## 13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a
copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access
requests should be made in writing and sent to the email or postal addresses shown in Part 15.

To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to
use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as
possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (
for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete
response, including a copy of your personal data within that time. In some cases, however, particularly if your request
is more complex, more time may be required up to a maximum of three months from the date we receive your request. You
will be kept fully informed of our progress.

## 14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those
placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and
to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure
that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device.

Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used
on Our Site for nothing. For more details, please refer to the table below. These Cookies are not integral to the
functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those
Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience
and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site
may not function fully or as intended.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”.
These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still
important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as
detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure
that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer when you use Our Website's client area:

| Name of Cookie  | Type               | Purpose                                                           |
|-----------------|--------------------|-------------------------------------------------------------------|
| WHMCSInstanceID | Strictly Necessary | Stores the unique session ID for each visitor.                    |
| WHMCS*          | Strictly Necessary | Stores details associated with the login session for a visitor.   |
| WHMCSUser       | Functional         | Used if a client chose to have the system remember their details. |

The following third-party Cookies may be placed on your computer or device when you use Our Website's client area:

| Name of Cookie | Type               | Purpose                   |
|----------------|--------------------|---------------------------|
| __stripe_sid   | Strictly Necessary | Provide fraud prevention. |
| __stripe_mid   | Strictly Necessary | Provide fraud prevention. |

If you spot a first- or third-party cookie being installed on your computer by this website that is not included in this
list, please send a message to the contact email address in Part 15. The first report received in each calendar month
for an unlisted cookie will be eligible for a £10 reward. Reports will require confirmation by us before the reward is
made.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most
internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By
default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help
menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that
enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation
settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and
guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are
unsure about adjusting your privacy settings.

## 15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access
request, please either use our support system or use the following details:

E-Mail Address: support@sr2.uk.

Postal Address: 499 Union Street, 2nd Floor, Aberdeen, AB11 6DB.

## 16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we
change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy
Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep
up-to-date. This date of the last update will be displayed at the top of this page.
