Privacy Policy

Who we are (data controller)

For personal data collected through our own sites and marketing, the data controller is System Switch Digital Ltd. You can reach us using the details in the Contact section below.

Where we run reactivation, follow-up or lead-generation campaigns on behalf of a client, that client is the data controller and we act as a data processor on their instructions. In those cases, the client's own privacy policy governs how your data is used, and we process it only to deliver the service they have engaged us for, under a written agreement.

Collection of your personal information

Please keep in mind that if you directly disclose personally identifiable or sensitive information through our sites, that information may be collected and used by others.

We collect only the minimum data necessary to deliver a good experience. Your data may come from a variety of sources, including: your visits to and behaviour on our sites; your engagement with us by phone, email, text message (SMS), WhatsApp or Facebook Messenger; preferences stored in browser cookies; your engagement with our advertisements; and information you submit through forms on our sites or via our advertisements, such as your name, email address, telephone number, business details and preferences.

We do not collect personal information about you unless you voluntarily provide it, or it is collected automatically as described below. You may need to provide certain personal information when you choose to use particular features or services, for example: (a) registering your details or booking a call with us; (b) entering a competition or promotion run by us or a partner; (c) signing up for offers, resources or updates from us or selected third parties; or (d) contacting us by email, phone or message. We will use that information to respond to and deliver the services or products you have requested from us, and for the related purposes set out below.

How we use your personal information, and our lawful bases

We collect and use your personal information to operate our sites and to deliver the services you have asked for. Under UK GDPR we must have a lawful basis for each use; ours are:

• Consent - where you have opted in to marketing, cookies that are not strictly necessary, or other optional processing. You can withdraw consent at any time.
• Performance of a contract - to provide a service you have requested or to take steps before entering into a contract with you.
• Legitimate interests - to run and improve our business, respond to enquiries, and tell you about our relevant services, provided this does not override your rights.
• Legal obligation - where we must process data to comply with the law.

We may use your information to respond to you, provide and improve our services, and to tell you about other products or services available from us. Where the law requires consent for marketing, we will obtain it, and you can opt out at any time.

Sharing information with third parties

We do not sell, rent or lease your personal information to third parties.

We may share data with trusted suppliers (processors) who help us run our business — for example to host our sites and store data, send email, SMS, WhatsApp or Messenger messages, perform analytics, or provide customer support. These suppliers include CRM and messaging platforms, Google Workspace, Kit, Google Analytics, and Meta. All such suppliers are permitted to use your personal information only to provide services to us, are bound by contract, and are required to keep your information confidential and secure.

We may disclose your personal information, without notice, if required to do so by law or in the good-faith belief that it is necessary to: (a) comply with the law or legal process; (b) protect and defend our rights or property; or (c) act to protect the personal safety of users of our sites or the public.

When we act for our clients (processor role)

When we deliver a reactivation or lead-generation campaign for a client, we process the personal data held in that client's systems (for example contacts on their existing list) on their behalf and on their instructions. The client remains the data controller and is responsible for the lawful basis for contacting those individuals and for their own privacy notice. We put a written data processing agreement in place, process the data only to perform the agreed service, apply appropriate security, and return or delete the data at the end of the engagement.

International transfers

Some of our suppliers are based in, or store data in, the United States or other countries outside the UK. Where we transfer your personal data outside the UK, we rely on appropriate safeguards recognised under UK data protection law (such as the UK Addendum to the EU Standard Contractual Clauses, or the UK Extension to the EU–US Data Privacy Framework) to ensure your data is protected to UK standards.

Tracking user behaviour

We may keep track of the pages our users visit within our sites to understand which services are most popular. This helps us deliver relevant content and advertising within our sites, or by phone, email, text, WhatsApp or Messenger, to people whose behaviour indicates an interest in a particular subject.

Automatically collected information

Information about your device may be collected automatically. This can include your IP address, browser type, domain names, access times and referring website addresses. We use this information to operate and maintain the quality of the service and to produce general statistics about use of our sites.

Use of cookies

Our sites may use cookies to help personalise your experience. A cookie is a small text file placed on your device by a web page server. Cookies cannot run programs or deliver viruses. They are uniquely assigned to you and can be read only by a web server in the domain that issued them.

You can accept or decline cookies. Most browsers accept them automatically, but you can usually change your browser settings to decline them. Where we use cookies that are not strictly necessary (for example analytics or advertising cookies), we will ask for your consent first.

External links

Our sites contain links to other sites. We are not responsible for the content or privacy practices of those sites. We encourage you to read the privacy statement of any site you visit that collects personal information.

Security of your personal information

We take appropriate measures to secure your personal information from unauthorised access, use, alteration or disclosure, including encryption in transit (SSL/TLS) and strict access controls.

Payments

We do not currently take payments through our sites. If we introduce a store or checkout (for example at store.systemswitch.digital), payments will be handled by a third-party payment provider such as Stripe or Whop.

How long we keep your data

We keep personal data only for as long as necessary for the purposes set out in this Policy. Unless the law requires a longer period, we keep enquiry and marketing data for up to 24 months after your last engagement with us, and client-account records for the length of our engagement plus 6 years for legal and accounting purposes.

Your rights under UK data protection law

You have the right to be informed, access your data, rectify inaccuracies, request erasure, restrict processing, data portability, object to processing, withdraw consent, and complain to the Information Commissioner's Office (ICO — ico.org.uk, helpline 0303 123 1113).

Email and marketing communications

If you no longer wish to receive marketing or promotional communications, you can opt out at any time by clicking "unsubscribe" at the bottom of any marketing email, replying STOP to a text message, or contacting us directly.