1. INTRODUCTION

Welcome to Daryo89 Ltd (“we,” “us,” or “our”). We are a professional Web Design, SEO, and Performance Marketing Consultancy based in the United Kingdom.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (daryo89.com) or engage our services, and tell you about your privacy rights and how the law protects you.

2. CONTROLLER AND CONTACT DETAILS

Daryo89 Ltd is the controller and responsible for your personal data. We are registered with the Information Commissioner’s Office (ICO), establishing our commitment to lawful and transparent data processing.

3. THE DATA WE COLLECT

We utilize a “Minimal Data” approach, collecting only what is necessary to provide our strategic services. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: First name, last name, username, or similar identifier.
• Contact Data: Billing address, delivery address, email address (business and personal), and telephone numbers.
• Financial Data: Bank account and payment card details. Note: We do not store full credit card numbers on our own servers; these are processed securely via our third-party payment processors.
• Transaction Data: Details about payments to and from you and other details of services (Web Design, SEO Audits, Managed Care) you have purchased from us.
• Technical Data: Internet protocol (IP) address, your login data (for client portals), browser type and version, time zone setting, and other technology on the devices you use to access this website.
• Profile Data: Your project briefs, feedback, and survey responses.
• Usage Data: Information about how you use our website and services.
• Marketing Data: Your preferences in receiving marketing from us and your communication preferences.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract: To deliver the Web Design, SEO, or Marketing services you have engaged us for.
• Legitimate Interest: To manage our business relationship, secure our network (Managed Web Care), and improve our services.
• Legal Obligation: To comply with tax and accounting regulations (HMRC).
• Consent: Where you have explicitly opted-in to receive our strategic insights or newsletters.

5. DISCLOSURES OF YOUR PERSONAL DATA

As a modern digital consultancy, we utilize a secure stack of enterprise-grade sub-processors. We share data with:

Infrastructure & Communication

• Microsoft 365: Secure business email, calendar, and document storage.
• IONOS Cloud: Virtual Private Server (VPS) hosting.
• Cloudflare: DNS management, CDN, and security firewalling.
• AWS & Brevo: Delivery of transactional emails via SMTP.

Payment & Banking

• Stripe: Secure credit card processing.
• PayPal: Secure online payments.
• GoCardless: Direct Debit payments for retainers.
• Tide Platform / Xero: Business banking and accounting.

Business Tools

• FluentCRM: Our self-hosted CRM (Data remains on our secure VPS).
• FluentCart: Order and Subscription management.
• Fluent Support: Our dedicated Helpdesk for client tickets.
• Google Analytics: Anonymized traffic analysis.

Regulatory & Professional

• Professional Advisers: Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• HM Revenue & Customs (HMRC): Regulators based in the UK who require reporting of processing activities for tax purposes.

6. INTERNATIONAL TRANSFERS

Some of our external third parties (Microsoft, Google, AWS, Stripe) are based outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring safeguards (such as UK International Data Transfer Agreements) are implemented.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

• Encryption: SSL/TLS encryption for all data in transit.
• Access Control: Data access is limited to employees and contractors with a business need to know.
• Server Security: Our infrastructure is protected by Cloudflare Enterprise-grade firewalls, Real Cookie Banner consent management, and local server hardening (Wordfence).

8. DATA RETENTION

We retain data only as long as necessary:

• Client Project Data: Duration of relationship + 6 years (contract/warranty purposes).
• Financial Records: 6 years (HMRC requirement).
• Marketing Data: Retained until you withdraw consent or unsubscribe.

9. YOUR LEGAL RIGHTS

Under data protection laws, you have rights including:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing.
• Right to withdraw consent.

Contact us at d.lapegna@daryo89.com to exercise these rights.

10. THIRD-PARTY LINKS & COOKIES

This website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites.

We use Real Cookie Banner to manage your consent preferences. This ensures that no non-essential cookies are loaded until you explicitly agree. You can change your privacy settings via the link in our footer.

11. COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.