Freshwave customer privacy notice July 2025
Changes to this privacy notice
We will review our privacy notice from time to time. Any changes we make will be posted on this page, Freshwave.co.uk so please check back frequently. Your continued use of our website(s) after will constitute your acceptance of and agreement to any changes.
Introduction and Information Storage:
At Freshwave we are serious about keeping your data secure. We store your data on encrypted devices and encrypted cloud storage for back-up purposes, for example Google Drive, One Drive and Drop Box. Backing up your Data is essential to fulfilling our contract with you, for example restoring data when customers have inadvertently deleted it.
We never sell, lend or otherwise trade email lists with other companies and business for marketing purposes. In this this privacy policy, we have provided lots of information on when and why we collect your personal information, how we use it and how we keep it secure.
The information that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us, or for one of our suppliers. The laws in some countries may not provide as much legal protection for your information as in the EEA. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site or e mail address; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Contact details
Telephone
+44 7960 885 912
Email
info@freshwave.co.uk
What information we collect, use, and why
We collect or use the following information to provide & deliver services as part of our contract with you:
- Names and contact details
- Addresses including e mail addresses, telephone numbers, IP addresses and postal addresses.
- An Internet Protocol (IP) address is the unique identifying number assigned to every device connected to the internet. An IP address definition is a numeric label assigned to devices that use the internet to communicate. Computers that communicate over the internet or via local networks share information to a specific location using IP addresses.
- Purchase or account history.
- Website user information (including user journeys and cookie tracking)
- Media: Photographs or video recordings provided by you to update your website at your request and for which you have obtained consent where needed.
- We are not responsible for obtaining consent of any individuals in any media supplied to have their image/s or intellectual property used in this way. Provision by you of media and your request to upload it, will be taken by us as legitimate. You agree and we expect you to have carried out the necessary due diligence and any required consent processes before placing your request with us to use images or recordings or other media on your website. This applies to all references in this privacy notice to photography, video or media.
- Article or media statements which may contain names and identifiable information, provided by you to update your website at your request and for which you have obtained consent where needed.
- We are not responsible for obtaining the consent of any individuals in any articles or media statements supplied by you to upload to your website. Provision by you of such will be taken by us as legitimate. You agree and we expect you to have carried out the necessary due diligence around any required consent or consideration of intellectual property rights, before placing your request with us to upload your content. This applies to all references in this privacy notice to provided textual media.
- Records of meetings and decisions
- Information relating to compliments or complaints
We collect or use the following information for the operation of customer accounts and providing high quality services:
- Names and contact details
- Addresses including e mail addresses, telephone numbers, IP addresses and postal addresses.
- Purchase history
- Information used for security purposes
- Account information, including registration details
- Financial Transactions
- In order to financially transact with us as part of your contract, if you order via our website and provide your card details on our Website, we will use a third party processor specified on the website. We don’t see or store your bank details. You should read the third-party payment operator’s terms and conditions and privacy policy before making payment.
- If you pay our invoice by direct bank transfer into our account, we don’t see or store your bank details. You should read the third-party payment operators i.e. your bank or payment organisation’s terms and conditions and privacy policy before making payment.
We collect or use the following information for the provision of service and technical updates
Names and contact details
- Addresses including e mail addresses, telephone numbers, IP addresses and postal addresses.
- Location data
- Purchase or viewing history
- IP addresses
- Website and app user journey information
- Records of consent, where appropriate
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Address
- Account information
- Purchase, payment or service history
- Customer or accounts and records
- Correspondence
- Where customers leave voice mail or voice message via application, these may be used to resolve complaints or queries
We collect or use the following information to Provide troubleshooting and technical support via direct service in person, on the telephone or by remote connection:
- Names and contact details
- Purchase or account history
- Information relating to compliments or complaints
- Customer or client accounts and records
- Financial transaction information
- Purchase or viewing history
- IP addresses
- Website and app user journey information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details on our website.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide & deliver services as part of our contract with you are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we may be collecting or using your information because it benefits you, or Us. We only do this where we can do so without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- If we are providing hosting services to you and/or technical support, we will need access to the information relevant to your request, in order to provide services that you have requested. We do not process this information beyond that which is necessary at the time through remote or personal connection, to solve your query and/or to update your website and e mail packages so that your sites and accounts function efficiently.
- We only share information collected in these processes where it is necessary to provide the services you have requested and where that sharing with a third party is necessary to fulfill your request. For example, where additional technical expertise is required or liaison with third party providers of software or services you are utilising. You can tell us that you do not want us to use your personal information to deliver services in the way outlined above which will have the impact of us not being able to deliver the service you requested either partially or in full.
- Our hosting packages retain a technical record of your websites and e mail account operations as a necessary part of fulfilling our contract with you efficiently. If you cease to host with us or access our services, this technical record will be deleted within 14 days of contract termination.
- We may collect, store and process certain Personal Information involving third parties where we cease to be the Controller of data and become a Processor. For example, if you were to import your email contacts from third-party services like Gmail, or otherwise collect and manage contacts on your company website, such contacts could then be stored on a website we host or build for you, on your behalf.
- For such purposes, we would be considered as a “Processor” and not as the “Controller.” The “Controllers” would be responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
- Google Analytics. This website may Google Analytics (GA) to track user interaction. We use this data to determine trends in people using our site. Although GA records your computer’s IP address, which could potentially be used to identify you, Google does not grant us access to this information and no other information that Google collects personally identifies you to us. We consider Google to be a third-party data processor.
- Consent: If you ask us to undertake a specific technical or service request, which we feel requires consent to access or process other information in order to meet your request, we will ask for your consent at the time. We will explain what we would need to access, process or store to deliver the service you have requested and ask if you give us your consent to do so. You can refuse in which case we may not be able to meet your service request. If you consent and change your mind and we have not completed the service request, you can withdraw your consent. If we have completed the service request, you have the right to ask us to remove any data we may have collected to fulfil the request, if we are not currently using it to fulfil the other requests you have made. If you request full deletion of your data when we have outstanding work requests, we may not be able to fulfil your requests; you may still be liable for the charges associated with meeting those requirements and requests if we have started work on these and/or if purchases have been made on your behalf to meet your requests.
- Our lawful bases for collecting or using personal information for the operation of customer accounts and providing high quality services are:
- Contract – we need to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- If we are providing services to you, it will be necessary to operate a record of your account, payments towards that account and any reminders associated with unpaid accounts. We do not collect or process this information beyond that which is necessary, for example for billing purposes, answering customer queries about accounts and preparing accounts for the purposes of government requirements such as Taxation. You can at any time tell us that you do not want us to use your personal information to manage your financial transactions as outlined above, which will have the impact of us not being able to further contract with you. We will still need to retain any existing financial records relating to you for a period of 7.5 years for the purposes of audit and taxation in relation to our company.
Our lawful bases for collecting or using personal information for the provision of service and technical updates are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- If we are providing hosting services to you in relation to your website and/or e mail accounts, we will need run regular service updates to update your website and e mail packages so that your sites and accounts function efficiently. Our hosting packages retain a technical record of your websites and e mail account operations as a necessary part of fulfilling our contract with you efficiently.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for Provision of troubleshooting and technical support via direct service in person, on the telephone, by e mail or by remote connection are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Consent: If you ask us to undertake a specific technical or service request, which we feel requires consent to access or process information in order to meet your request, we will ask for your consent at the time. We will explain what we would need to access, process or store to deliver the service you have requested and ask if you give us your consent to do so. You can refuse in which case we may not be able to meet your service request. If you consent and change your mind and we have not completed the service request, you can withdraw your consent. If we have completed the service request, you have the right to ask us to remove any data we have collected to fulfil the request which we are not currently using to fulfil your other requests. If you request full deletion of your data when we have outstanding work requests, we may not be able to fulfil your requests; you may still be liable for the charges associated with meeting those requirements and requests if we have started work on these and/or if purchases have been made on your behalf to meet your requests.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- If we are designing and/or hosting your website and /or e mail accounts, it is in your interests to have an efficient operation; this requires undertaking regular technical updates, backups, account management and requested troubleshooting of problems that may have arisen, or which may arise without our activity. The outcome of these activities is legitimate to our contract with you and the operation is proportionate to the need to carry that out, with the aim of benefiting not harming you, and with the aim of ensuring we maintain our business reputation as a reliable provider of web services
Where we get personal information from
- Directly from you
- Publicly available sources
- Suppliers and service providers
- Third party applications engaged in activity related to our contract with you to provide Web and IT services, including but not limited to hosting of websites, e mails and design of websites, support for operation of your hardware and software, including customer support services we may need access from Third Parties on your behalf, where you have asked us to carry out a service for you or purchase a product on your behalf.
- In order to financially transact with us as part of your contract, if you order via our website and provide your card details on our website, we will use a third-party processor specified on the website. So we don’t see or store your bank details. You should read the third-party payment operators’ terms and conditions and privacy policy before making payment. If you pay our invoice direct by bank transfer into our account, we don’t see or store your bank details. You should read the third-party payment operators ie. your bank or payment organisation’s terms and conditions and privacy policy before making payment.
How long we keep information
We are obliged by law to keep financial and taxation records for at least 5 years after the 31 January submission deadline of the relevant tax year. Freshwave will delete accounts within 7 years unless you ask us to delete them after 5 years. This includes all sales and income and all business expenses that may relate to your business with us.
We will delete your website online data within 14 days of you closing your website services with us. If we are hosting your website for you on behalf of a third party, we will delete any online data we have access to that we are not obliged to keep by the Government, within 28 days of the third party notifying us that they no longer wish us to host the website, or that the website is closed.
Please note that where we receive a request to transfer your website, or hosting or both to a new third party, we will transfer with this request all liability for the security, retention and deletion of that data to the third party. We will not keep back-ups or transferred sites or data beyond the transfer window which will not exceed 2 months unless you have specifically requested otherwise.
Who we share information with
Others we may share personal information with
- Professional or legal advisors if this became necessary for a legitimate reason
- External auditors or inspectors if required to participate with such processes
- Warranty and guarantee providers of third-party services purchased on your behalf in pursuance of fulfilling our contract with you
- Suppliers and service providers, to the extent that it is necessary to effectively implement their product or services as part of our contract with you.
- Organisations we’re legally obliged to share personal information with
How to raise a concern
If you have any concerns about our use of your personal data, we would hope to resolve this with you and we would ask that you contact us in the first instance so that we can work with you to understand and respond to your concerns.
Last Updated 17/07/2025
