Privacy Policy

Last updated: 21 March 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.

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.

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 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, CMS, or form platform providers, including Wix.
• 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.
• Operational website records: retained in line with our hosting, security, and operational needs. We do not currently run analytics tools on the site.

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.

We do not currently use analytics tools on the site. If this changes, this Privacy Policy and any cookie notice or cookie banner should be updated so they accurately reflect the tools in use.

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.