Privacy policy

This Privacy Policy sets out how we collect, store and use information about you when you use or interact with our website (, (Our Website) and where we otherwise obtain or collect information about you.

This Privacy Policy is effective from 19th May 2018 and covers

  • Our details
  • Information we collect when you visit our website
  • Information we collect when you contact us
  • Information we collect when you interact with our website
  • If and how we collect or obtain information about you from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Your right to object to the processing of your information for certain purposes
  • Changes to our Privacy Policy


This section summaries how we obtain, store and use information about you.

  • Data controller: The Company De Courtenay Associates Ltd is a Data Controller in relation to Your personal data. Our registered address is 107 Kirkgate, Leeds, England, LS1 6DP. The Company may be contacted by email at
  • How we collect or obtain information about you:
  • when you provide it to us by contacting us, submitting a contact form on our website or signing up to our newsletter.
  • from your use of our website, using cookies and similar technologies.
  • Information we collect may include: your name, email, your IP address, information about how you use our website, the geographical location from which you accessed our website (based on your IP address).

For the purposes of online advertising, some service and social media providers, and particularly Google and Facebook, do not provide Us with any personal or specific data about You, but they do use what they know about You in order to present Our advertising to You online after You have visited Our Website.

How we use your information: for administrative and business purposes particularly to contact you and process orders you place on our website, to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, and to analyse your use of our website.

For as long as We have access to Your personal data, We will use it for the following purposes, unless otherwise required as a result of You exercising Your data protection rights. We may use Your personal data for any of the following purposes, whether We obtained it directly from You (or someone You trust), or another source:


To provide You with Our products and/or services in accordance with Our contract with You.

To process Your payment for Our products and/or services.

To provide You with information that You request from Us, or respond to Your enquiries made directly to Us.

To prepare, and send You, solicited or unsolicited direct marketing (unless You ask Us to stop), consisting of online advertising directed to You via our service providers or of direct correspondence with You, and containing relevant information about products and/or services that We provide.

Also to select or de-select You for each of Our direct marketing initiatives.

To provide Us with information about how You use the Website, so we and our service providers can review the information and ensure that the Website is presented in the most effective manner for You and for Your devices, and that it is an effective sales and communication tool.

For Us to take legal or administrative action, including to collect debts, resolve disputes with You, and deal with regulators.

To contact You by email. We will ask for Your consent and will not contact You by email if You have specifically withheld or withdrawn Your consent to this.

Disclosure of your information to third parties: For as long as We have access to Your personal data, We may share any of it with any of the following to the extent that they need to have access to Your personal data in order to perform their role:

  1. Any employee within Our organisation.
  2. Our IT service providers who provide, maintain, improve, manage, optimise or fix the IT facilities that We use or rely on in Our business, including computing devices, computer networks, connectivity, telecommunications, software and Our Website.
  3. Our online service providers, who provide networking opportunities, information about networking groups, marketing and advertising placement services for Us, including providers of search engines, analytics services, behavioral marketing services, advertisement placement services, social media and online software applications.
  4. Our professional service providers, such as accountants, auditors, legal advisers and insurance brokers.
  5. Any third party company or companies in the event that We go through a business transition, such as a merger, being acquired by another person or company, or selling a portion of Our assets.

We reserve the right to disclose Your personal data to other third parties if We have lawful grounds to do so, or are under a legal obligation to disclose or share it with them, or in order to establish, exercise or defend Our legal rights, or to protect the rights, property, or safety of the Company or Our employees or subcontractors.

We do not (other than in the course of a business sale or purchase or similar event) sell your information to third parties

How long we retain your information: For no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business).

Use of cookies [and similar technologies]: We use cookies on our website including essential, functional, analytical and targeting cookies.

How to withhold personal data: You can control all of Our sources of Your personal data. You can:

  • provide less personal data than We request;
  • use our Website to tell Us to stop contacting You with Our marketing;
  • not respond to Our marketing and communications (and You also have rights to stop Our direct marketing to You: see below);
  • change Your settings and connections in the social networks that you use; and/or
  • change Your internet browser settings to prohibit cookies.

Transfers of your information outside the European Economic Area:

Our internal IT systems on which We store Your personal data are all within the European Economic Area (the “EEA”).

We or our service providers who process Your personal data for us may, however, use external IT services that are accessed from the UK and established outside the EEA. In particular, services that are established in the United States of America will be used. The European Commission decides, for the purposes of Data Protection Legislation, whether or not states outside the EEA have “adequate” safeguards for personal data. In the case of the United States, it is not currently considered to provide adequate safeguards, although its Government operates Privacy Shield and members of that scheme are considered to have “adequate” safeguards.

Your personal data that you give us is kept by the company and is not passed on to any third party.

When We use social networks, Our use (as well as Yours) is subject to each social network provider’s terms and conditions and policies, which may state that the provider will store Your personal data outside of the EEA. Please refer to each provider and their terms and conditions and policies.

Your rights in relation to your information

  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here:

You can submit a data access request at any time. In order to do this, please contact Us at You have the right to ask Us not to process Your personal data for marketing purposes (including profiling). You may unsubscribe at any time by emailing Us directly at

Our protection of Your personal information

We have taken reasonable steps to put in place appropriate security measures to protect Your personal data when it is processed by Us or on Our behalf.

We do not accept any responsibility for the policies of third party Data Controllers, such as providers of search engines and social networks. Your use of such third parties, their websites and services is at Your own risk. Please check the third parties’ Privacy Notices before You submit any personal data to them.

Changes to Privacy Notice

We reserve the right to make changes to this Privacy Notice from time to time. If this Privacy Notice changes in any way, We will place an updated version on Our Website. Regularly reviewing Our Website ensures that You are always aware of what information We collect, how We use it and under what circumstances, if any, We will share it with other parties.

If You do not agree to the changes that We make from time to time, please tell Us via

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at:”