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Privacy Policy

Last updated: 21 September 2026

This Privacy Policy explains how THE DRAWBRIDGE MEDIA LTD, trading as The Drawbridge, collects, uses, stores and shares personal data when you visit james-gerrard.com, subscribe to email updates, or otherwise contact us.

Data controller

THE DRAWBRIDGE MEDIA LTD

Unit 1 The Old Slaughter House, Green Lane, Chickerell, Weymouth, England, DT3 4GG

james@thedrawbridge.com

www.james-gerrard.com

1. Who we are

THE DRAWBRIDGE MEDIA LTD is the data controller for this website and the associated newsletter sign-up forms. If you have questions about this Privacy Policy or the way we handle your personal data, please contact us using the details above.

2. What we collect

Depending on how you interact with the site, we may collect the following categories of personal data:

  • Identity and contact data, such as your name and email address.

  • Communication and preference data, such as whether you opted in to newsletters and related updates.

  • Technical and usage data, such as IP address, browser type, device information, pages viewed, timestamps, and referral information.

  • Correspondence data, such as messages you send to us and our responses.

  • Compliance records, such as consent timestamps, form versions, privacy notice versions, and unsubscribe status.

  • With analytics consent, random journey identifiers and newsletter or finance-form stages. Entered contact values and message contents are excluded from these analytics records.

We try to collect only the personal data that is reasonably necessary for the relevant purpose.

3. How we use your data

We use personal data for the purposes set out below. The exact lawful basis may depend on the context in which the data was collected.

  • To provide what you asked for: responding to a direct enquiry or message you send us. This is based on our legitimate interests in administering requests and communications, and where relevant taking steps at your request before entering into a relationship with you.

  • To send newsletter and related marketing emails: sending The Drawbridge newsletter, updates, or related promotional content by email. This is based on consent where required under UK GDPR and PECR.

  • To run, secure and improve the website: preventing spam or abuse, troubleshooting, and maintaining the website securely. This is based on our legitimate interests in operating and improving the website securely.

  • To understand newsletter signup and finance-form progress: consented browser analytics are processed by our own reporting service hosted on Netlify. Essential submission and security records remain separate.

  • To comply with legal and regulatory obligations: maintaining suppression lists, handling legal requests, and keeping compliance records. This is based on legal obligation and legitimate interests in demonstrating compliance.

4. Marketing emails

If you actively opt in, we may send you The Drawbridge newsletter and related marketing emails. We do not intend to rely on silence, inactivity, or pre-ticked boxes as consent for email marketing.

We use newsletter sign-up forms to collect consent for email marketing. We aim to make that consent clear, specific and unambiguous at the point of collection.

You can unsubscribe from marketing emails at any time by using the unsubscribe link in the email or by contacting us directly. This will not affect the lawfulness of processing carried out before your withdrawal.

5. Sharing your data

We may share personal data with service providers that help us operate the website and send communications. These may include providers in the following categories:

  • Website hosting, serverless function, form and operational storage providers, including Wix and Netlify.

  • Email marketing, CRM, or automation providers, including Kit.

  • Security, spam-prevention, operational support providers, and professional advisers where reasonably necessary.

  • Professional advisers, legal advisers, insurers, auditors, or regulators where reasonably necessary.

We require processors acting on our behalf to protect personal data and only process it in line with our instructions and applicable law.

6. International transfers

Some service providers may process personal data outside the UK or European Economic Area. Where this happens, we aim to ensure that an appropriate safeguard is in place, such as an adequacy decision, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another legally recognised transfer mechanism.

7. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this policy, including to meet legal, regulatory, tax, accounting, or reporting requirements.

Typical retention periods

  • Newsletter sign-up records: we do not currently apply a fixed deletion period. We retain these records unless and until you unsubscribe, ask us to delete your data, or we determine that continued retention is no longer necessary.

  • Newsletter subscriber records: until you unsubscribe or we otherwise stop sending the relevant communications.

  • Consent and suppression evidence: we may retain limited records after unsubscribe or deletion requests where reasonably necessary to demonstrate compliance and to ensure we respect your opt-out preferences.

  • Anonymous journey records and non-contact reporting outcomes: retained for up to 90 days. Monthly aggregate totals, without journey identifiers, are retained for 24 months. Daily maintenance removes expired analytics records. Essential submission records, consent and suppression evidence are maintained separately.

8. Your rights

Depending on your location and the circumstances, you may have rights to:

  • request access to your personal data;

  • request correction of inaccurate or incomplete personal data;

  • request deletion of your personal data;

  • request restriction of processing;

  • object to certain processing, including some processing based on legitimate interests;

  • request portability of certain personal data;

  • withdraw consent at any time where processing is based on consent.

To exercise any of these rights, contact us using the details in this policy. We may need to verify your identity before responding.

9. Cookies and analytics

We may use cookies or similar technologies to operate the website, maintain security, and support basic functionality through our website provider, Wix.

With your analytics consent through Privacy preferences on the newsletter or finance page, our own reporting service hosted on Netlify records newsletter engagement and form stages using a random identifier. It records the edition, link placement, selected product, device category, progress and time, but no entered names, email addresses, telephone numbers or message contents. Session storage may keep the random identifier for up to 24 hours in the current browser tab. We do not use an email address, email hash or Kit subscriber ID as a browser tracking identifier. We do not use GA4, PostHog, session replay or automatic abandoned-form emails in this experience.

You can withdraw analytics consent through Privacy preferences on the newsletter or finance page. These controls update your Wix consent policy. This stops further browser collection and clears the local tracking identifier; newsletter and enquiry forms continue to work. Previously collected records expire under the retention periods above. Essential backend submission outcomes do not depend on analytics consent and are reported separately from consented conversion rates.

Where functional storage consent permits, we remember a dismissed newsletter invitation for 30 days and a successful sign-up request for 180 days. These records contain an expiry and status, not an email address, and are a convenience rather than proof of subscriber identity. Without functional storage consent, the choice is remembered only while the page remains open.

Kit supplies email delivery and engagement reports where available, including email clicks. These indicate email engagement, not a completed enquiry or a reliable identity after forwarding.

10. Contact and complaints

If you have a concern about the way we handle your personal data, please contact us first at james@thedrawbridge.com.

If you are in the UK and remain unhappy, you may also complain to the Information Commissioner's Office. More information is available at ico.org.uk.

11. Changes to this policy

We may update this Privacy Policy from time to time. We will post the latest version on this page and update the Last updated date above. If a change is material, we may take additional steps to bring it to your attention where appropriate.

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