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PRIVACY POLICY
Last updated: 11 November 20261. Who we are
James Ponders ("we", "us", "our") is the controller of the personal data described in this policy. Our address is Suite 369, Jolyon House, Amberley Way, Hounslow, United Kingdom, TW4 6BH.
If you have any question about this policy or about how we handle your data, email [email protected].2. What this policy covers
This policy explains what personal data we collect when you use this website, download the Free Gifting Start-Up Guide (the "Start-Up Guide"), subscribe to our emails, or apply for or take part in the Gifting Brand Mentorship.
We have written it in plain English deliberately. If anything is unclear, ask us.3. The data we collect
When you download the Start-Up Guide or subscribe to our emails
- your first name and email address
- the date and time you signed up, the form you used, and your marketing consent choice
- your IP address at the point of sign-up
- how you interact with our emails, including whether you open them and which links you clickWhen you submit an application
- your name, email address and mobile number
- where you are based, what you do for work and your experience of selling on Amazon
- the information you provide about your budget, your goals, your circumstances and when you would like to start
- whether you ticked the box asking for your mentorship to start within the 14-day cancellation period
- anything else you choose to tell us in a free-text fieldWhen you buy from us
- your name, email address and billing details
- your start date, your chosen payment option, your payment history and the amounts paid
- correspondence relating to your purchase
Payments are made by bank transfer. We hold the name and bank details that appear on payments you make to us, and the details we need to send you any refund.During the mentorship
- notes we make about your progress, your goals and what we discuss
- work and materials you send us for feedback
- messages, voice notes and files you send us on WhatsApp
- recordings of sessions, where we record them and have told you so
- correspondence between usWhen you visit this website
Our website is a simple one-page site. It does not use advertising or tracking cookies. We use cookie-free analytics to count visits, which tells us the page you visited, the website that referred you, your browser and device type, and your approximate country, but not who you are. See section 9 for more.When you contact us
- your name, email address and the content of your message
- any attachments you send4. Where we get it from
Almost everything we hold comes directly from you. We do not buy lists, scrape contact details, or obtain your data from data brokers.
If you share information about other people with us, for example a business partner, an employee or a supplier contact, you confirm that you have the right to share it and that they would reasonably expect us to receive it.5. Why we use it, and our lawful basis
Under UK GDPR we must have a lawful basis for everything we do with your data. Ours are as follows.
To send you the Start-Up Guide and one follow-up email to check it arrived: because you asked us to. Lawful basis: consent.
To send you marketing emails: because you ticked the box asking for them. You can withdraw your consent at any time. Lawful basis: consent.
To assess your application for the mentorship: because it is necessary to take steps at your request before entering into a contract. Lawful basis: contract.
To provide the mentorship: because we need to in order to perform our contract with you. Lawful basis: contract.
To take payment, make refunds and keep financial records: because we need to perform the contract and because we are required by law to keep accounting records. Lawful basis: contract and legal obligation.
To improve our services and understand which of our content works, including counting visits to our website: because we have a legitimate interest in running and improving our business, balanced against your interests. Lawful basis: legitimate interests.
To keep our sign-up form secure and free of spam: because we have a legitimate interest in protecting the form from automated abuse. Lawful basis: legitimate interests.
To deal with complaints, disputes and legal claims: because we have a legitimate interest in defending our position and because we may be required to by law. Lawful basis: legitimate interests and legal obligation.
To keep a record of people who have asked not to hear from us: because we are required to respect that request. Lawful basis: legal obligation.
Where we rely on legitimate interests, you have the right to object. See section 11.6. Marketing emails
When you sign up for the Start-Up Guide, there is a separate, unticked box asking whether you also want to receive our marketing emails, which include information about the Gifting Brand Mentorship. Ticking it is optional. If you do not tick it, we will send you the Start-Up Guide and one short follow-up email to check it arrived, and nothing else.
If you apply for the mentorship or become a client, we will email and message you about your application and your mentorship. Those messages are not marketing. We will only send you marketing emails if you have ticked the box asking for them.
If you give us your mobile number when you apply, we may message you on WhatsApp about your application, for example to let you know we have emailed your offer. If you become a client, we also use WhatsApp for your support during the mentorship. WhatsApp is run by Meta, so those messages are also covered by WhatsApp's own privacy policy. You can ask us to stop messaging you on WhatsApp at any time.
Every marketing email we send contains an unsubscribe link that works immediately. You can also email us and we will remove you. If you unsubscribe, we keep a record of your email address on a suppression list so that we do not accidentally contact you again. That is the only reason we keep it.
We do not sell, rent or share your email address with anyone for their own marketing.7. Who we share it with
We use a small number of third-party service providers to run the business. Each processes your data on our instructions and under their terms with us, and none is permitted to use it for their own purposes. They fall into the following categories:
- email marketing and delivery platforms
- our business bank
- online form and application providers
- spam-protection services
- cloud storage, email and document services
- messaging services
- video recording, hosting and conferencing platforms
- website hosting providers
- website analytics providers
We also share data with our accountant and, where necessary, with our professional advisers or insurers.
We will disclose your data if we are required to by law, by a court, or by a regulator.
We do not sell your personal data. We never have and we do not intend to.
If you would like to know the specific providers we use, email us at [email protected] and we will tell you.8. International transfers
Some of the providers listed above are based outside the UK, or store data outside the UK, including in the European Economic Area and the United States.
Where your data leaves the UK, we make sure it is protected by an appropriate safeguard: either the country has been assessed by the UK government as providing an adequate level of protection, or the provider is bound by the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.
If you would like more detail on the safeguards for a particular provider, email us and we will tell you.9. Cookies, analytics and embedded content
This website does not use advertising, profiling or tracking cookies, and it does not use cookies for analytics. We do not track you across other websites.
The site may set a small number of strictly necessary cookies required for it to function and to keep it secure. These do not require your consent.
Analytics. We use Cloudflare Web Analytics to understand how many people visit this website and how they found it. It does not use cookies, does not store anything on your device and does not track you across other websites. It records general information such as the page you visited, the website that referred you, your browser and device type, and your approximate country. It is not used to identify you or to build a profile of you. We use it on the basis of our legitimate interest in understanding and improving our website.
Spam protection. Our Start-Up Guide sign-up form uses Google reCAPTCHA to stop spam and automated sign-ups. To do this, Google collects information such as your IP address and how you interact with the page, and may set cookies, in accordance with Google's own privacy policy. We use it on the basis of our legitimate interest in keeping the form secure.
Video. Our website embeds a video hosted on YouTube. We use YouTube's privacy-enhanced embed, which means YouTube does not set cookies on your device unless you press play. If you do press play, YouTube may set cookies and collect data in accordance with Google's own privacy policy, over which we have no control. If you would rather it did not, do not play the video.
Application form. Our application form is provided by Tally and appears within this page. Anything you enter into it is handled as described in this policy.
You can block or delete cookies through your browser settings at any time. Blocking strictly necessary cookies may stop parts of the site working.10. How long we keep it
- Email subscribers: for as long as you remain subscribed, and for six months after you unsubscribe, except for your email address on our suppression list, which we keep indefinitely so that we do not contact you again.
- Enquiries and applications that do not lead to a purchase: 12 months from our last contact.
- Customer and client records, including notes, WhatsApp messages and correspondence: six years from the end of our relationship, which reflects the period in which a legal claim could be brought and our obligations to keep accounting records.
- Financial records: six years from the end of the accounting period they relate to, as required by law.
- Session recordings: 12 months from the date of the session, unless you ask us to delete them sooner.
When a retention period ends, we delete the data or anonymise it so that it can no longer identify you.11. Your rights
Under UK data protection law you have the right to:
- be informed about how we use your data, which is what this policy is for
- access the personal data we hold about you
- have inaccurate data corrected
- have your data erased, in certain circumstances
- restrict how we use your data, in certain circumstances
- object to our use of your data where we rely on legitimate interests
- object to direct marketing at any time, with no exceptions
- receive your data in a portable format and have it transferred to another provider, in certain circumstances
- withdraw consent at any time, where we rely on consent
To exercise any of these, email [email protected]. We will respond within one month. If your request is complex we may extend that by a further two months, and we will tell you if so.
There is no charge. We may ask you to confirm your identity before we act on a request.
Some rights are not absolute. For example, we may not be able to erase data we are legally required to keep, such as records of a transaction. If we cannot do what you have asked, we will explain why.12. Automated decision-making
We do not make any decision about you by automated means that produces a legal effect or similarly significantly affects you. We may group email subscribers into basic segments so that we send relevant content, but a human makes every decision that matters, including whether to accept an application.13. Security
We take sensible steps to keep your data safe. Accounts are protected by strong, unique passwords and two-factor authentication where available. Access is limited to those who need it. Our providers are established services with their own security measures.
No system is completely secure, and we cannot guarantee the security of data transmitted over the internet. If a breach happens that is likely to result in a risk to your rights and freedoms, we will report it to the ICO within 72 hours and tell you where we are required to.14. Children
Our services are for adults. We do not knowingly collect data from anyone under 18. If you believe a child has given us their data, email us and we will delete it.15. Complaints
If you are unhappy with how we have handled your data, please tell us first at [email protected] so that we have a chance to put it right.
You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority for data protection:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
ico.org.uk16. Changes to this policy
We may update this policy. The date at the top tells you when it was last changed. If we make a significant change, we will tell subscribers and clients by email.