The formal privacy statement
Not final copy. Contents in brackets are facts to supply, and the whole page wants a pass from a qualified adviser before go-live. This is a first draft to hand to one, not legal advice.
Who we are
Subleeva Ltd (company no. 16808138), registered at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ. ICO registration [number — TBC]. Data contact: [contact / DPO if applicable — TBC].
What we collect
Professional identity and contact data; relevance signals from public and professional sources; site and registration data given directly; technical data (see cookies).
Where we get it
Direct from you (registration); from [named public/professional sources]; from clients about their own contacts.
Why, and our lawful basis
Legitimate interest for outreach (see how we apply legitimate interest); contract and legitimate interest for running engagements; consent only where genuinely relied on. Each purpose is stated separately.
Who we share it with
Processors: [the ones actually used — sending, email, hosting, model providers].
Where it’s processed
[hosting region, and any transfers outside the UK/EEA, with the safeguard relied on].
How long we keep it
[retention periods per data type].
Your rights
Access, rectification, erasure, restriction, objection, portability where applicable, and how to exercise each. Objection to legitimate-interest-based outreach is the easy, no-questions route.
Complaints
The Information Commissioner’s Office, with its current contact route.
Changes
Effective date and how updates are handled.