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Privacy policy

This notice explains what personal information Subtle Standard handles, why it is used, the choices available to you and how to raise a concern.

Last updated
31 October 2026
Version
1.1
Applies to
subtlestandard.com
On this page
  1. 01Who controls your information
  2. 02Who and what this notice covers
  3. 03Information we may collect
  4. 04Where information comes from
  5. 05Purposes and lawful bases
  6. 06Website enquiries, chat and email
  7. 07Cookies and browser storage
  8. 08Who information may be shared with
  9. 09International transfers
  10. 10How long information is kept
  11. 11Security and incidents
  12. 12Your data protection rights
  13. 13Your right to object
  14. 14Complaints and the ICO
  15. 15Children, automation and changes

Who controls your information

Luke McInery, a sole trader trading as Subtle Standard, is the data controller for personal information handled for the studio's own business purposes. Subtle Standard is not a registered company or separate legal entity. It is a digital design studio based in Ascot, Berkshire, England. References to “Subtle Standard”, “we”, “us” and “our” in this notice mean Luke McInery carrying on business under the Subtle Standard name.

You can contact Luke McInery trading as Subtle Standard quickly by email at hello@subtlestandard.com. Luke McInery's name and a UK postal address at which documents relating to the business can be served are stated on every proposal, contract, invoice and business letter, and are given in writing straight away to anyone dealing with the business who asks at legal@subtlestandard.com.

Privacy questions, rights requests and data protection complaints can be sent electronically to legal@subtlestandard.com. Please use the subject line “Data protection”.

Where we process personal information solely on a client's documented instructions—for example, while maintaining a client system—the client will normally be the controller and we will act as its processor. The relevant client privacy notice and a written data-processing agreement will govern that activity.

Who and what this notice covers

This notice covers personal information relating to:

  • visitors to subtlestandard.com;
  • people who contact the studio or request a proposal;
  • prospective, current and former clients and their personnel;
  • suppliers, professional advisers, collaborators and their personnel; and
  • business contacts with whom we communicate lawfully.

It covers the website, website chat, email enquiries, project administration, service delivery, hosting or support administration where agreed, billing, legal compliance and related business records. A client-specific contract or privacy notice may provide additional information for a particular service.

Information we may collect

Identity and contact details

Name, role, organisation, postal address, email address, telephone number and communication preferences where provided.

Enquiry and project information

Website chat messages, project descriptions, briefs, budgets, timing, requirements, decisions, approvals, correspondence, meeting notes and files supplied for the work.

Contract and financial records

Proposal and contract records, invoicing information, payment status, transaction references and information needed for tax or accounting. We do not currently collect card details through this website.

Service and support information

Authorised account contacts, support requests, issue history, system access records and technical information needed to provide an agreed service.

Website and security information

IP address, request time, requested URL, referrer, browser or device information, response status and security events that may appear in ordinary server, proxy or security logs.

Rights and complaint records

Your request or complaint, relevant correspondence, evidence of identity or authority where reasonably needed, the enquiries made and the outcome.

Please do not provide special-category information—such as health, biometric, political, religious or trade-union information—or criminal-offence information unless it is genuinely necessary and we have agreed a lawful and secure way to receive it.

Where information comes from

Most information is received directly from you when you email, enquire, meet with us, enter into an agreement or use an agreed service. We may also receive relevant information from:

  • your employer, organisation, authorised representative or project colleague;
  • a client, supplier, collaborator or professional adviser involved in the same project;
  • public professional or business sources, such as an organisation's website or a professional directory, where it is reasonable and lawful to use the information; and
  • hosting, security and technical systems that create routine service logs.

If we obtain personal information from another source and the law requires us to notify you, we will provide the relevant privacy information within one month and, where an earlier point applies, by the first communication or before disclosure.

Why we use information and our lawful bases

We only use personal information where a lawful basis applies. More than one basis may apply to the same information where the purposes are different.

Purposes for using personal information and the corresponding lawful bases
PurposeInformation normally involvedLawful basis
Responding to enquiries, discussing requirements and preparing a proposalIdentity, contact, organisation and project informationSteps requested before a contract; legitimate interests in responding to business enquiries and developing the studio
Entering into, administering and delivering an agreed serviceContact, contract, project, account and service informationPerformance of a contract; legitimate interests where the contract is with your organisation rather than you personally
Hosting, maintenance, support, service security and troubleshooting where contractedAuthorised contacts, support material, access and technical logsContract; legitimate interests in providing, securing and documenting the service; legal obligations where applicable
Invoicing, accounting, tax, fraud prevention and debt administrationIdentity, contact, contract, transaction and payment-status recordsLegal obligation; contract; legitimate interests in receiving payment and preventing misuse
Operating, protecting and improving the website and business systemsTechnical, security and limited usage informationLegitimate interests in security, reliability and proportionate improvement; consent where required for non-exempt browser technologies
Managing suppliers, advisers and collaboratorsContact, contract, due-diligence and payment recordsContract; legitimate interests in operating and protecting the business; legal obligation
Sending relevant business communications or direct marketing where lawfulBusiness contact details, relationship and preferencesConsent where required; otherwise legitimate interests in proportionate business development, subject to the right to object and PECR
Complying with law, resolving disputes and establishing, exercising or defending legal claimsInformation relevant to the obligation, complaint or claimLegal obligation; legitimate interests in protecting legal rights; special legal-claims conditions where relevant

Our legitimate interests include responding to prospective clients, delivering and improving services, protecting systems, maintaining appropriate records, receiving payment, managing suppliers and defending legal rights. We assess necessity, proportionality and the effect on individuals before relying on those interests.

Website enquiries, chat and email

When you submit the website enquiry form, the name, email address, selected service and project description you provide are sent over HTTPS to the website server. The server validates the submission and uses Resend, an email-delivery service operated by Plus Five Five, Inc., to deliver it to the studio inbox. After that copy is accepted, Resend also sends a one-off transactional acknowledgement to the email address you supplied. The acknowledgement contains your name, selected service and enquiry reference, but not the project description. The website does not create a separate enquiry database, and no automatic marketing subscription is created.

You are not legally required to make an enquiry. If you want a proposal, we need enough contact and project information to understand and answer the request. If you do not provide it, we may be unable to respond, quote or enter into a contract. Please use an email address you control or are authorised to use, and do not include passwords, unnecessary sensitive information or material you are not authorised to share. Resend and the relevant mailbox providers receive the information and delivery metadata needed to transmit the enquiry and acknowledgement. Resend states that standard email data is retained for 30 days. The copy received in the studio inbox is then kept according to the enquiry retention period below.

If you start the website chat, the name, email address and messages you provide are stored in a first-party conversation database within the website hosting environment. The browser receives a secure session token so it can reopen only its own conversation. Luke can read and respond through a private, password-protected inbox. Resend may send Luke a new-message alert and may send you a transactional copy of Luke's reply if the chat has not recently been open. Chat messages are not used to train or operate a chatbot, and starting a chat does not create a marketing subscription.

Cookies and browser storage

At the date of this notice, this website has no analytics, advertising, behavioural-tracking or third-party media technologies enabled. First-party interface preferences may remember the storage notice or that a chat greeting was dismissed. If you start the chat, a secure first-party session cookie is used to restore the conversation you requested. None of these technologies identifies you across websites or permits future tracking.

Exact details, duration and controls are set out in the cookie and storage policy. If optional technologies are introduced, they will remain disabled until any consent required by PECR and UK data protection law has been obtained.

Who information may be shared with

We may disclose personal information only where reasonably necessary to:

  • email, hosting, cloud, domain, security and technical providers that support the website or agreed services;
  • payment, accounting, banking and business-administration providers;
  • approved specialist collaborators or subcontractors working on an agreed project and bound by appropriate confidentiality and data-protection terms;
  • lawyers, accountants, insurers and other professional advisers;
  • courts, regulators, law-enforcement bodies, tax authorities or other parties where disclosure is required or permitted by law;
  • a prospective purchaser, investor or successor in connection with a genuine business reorganisation, subject to appropriate safeguards; or
  • another party where you have instructed or authorised the disclosure.

Providers acting for us may only handle information for agreed purposes and under appropriate contractual duties. We do not sell personal information. Material provider categories and transfer information are maintained in the studio's internal data map, and further relevant detail is available on request. The website currently uses Resend (Plus Five Five, Inc.) as a processor for website-form email delivery, chat alerts and transactional offline chat replies. Chat records are held in the website's own database within its hosting environment rather than in a separate chat platform. Mailbox, hosting, storage, backup, security, accounting and payment providers are assessed and recorded before they handle relevant information.

International transfers

Resend states that customer data, including email metadata, logs, API records and message content, is stored in the United States. Resend's published data-processing addendum incorporates the UK Addendum to the approved Standard Contractual Clauses for restricted transfers and also records its participation in the UK Extension to the EU–US Data Privacy Framework. We will keep the applicable transfer mechanism, provider terms and transfer-risk assessment under review.

Other service providers or project tools may also process information outside the United Kingdom. Before making a restricted transfer, we will assess the destination, recipient and purpose and use a lawful mechanism. You can ask for information about safeguards relevant to your information by emailing us.

How long information is kept

We keep information only for a defined period or according to documented criteria, then delete, anonymise or securely archive it unless law or a live dispute requires longer retention. The intended schedule is:

Retention periods for categories of personal information
RecordNormal retention
Website chats, enquiries and proposals that do not proceedUp to 18 months after the last meaningful communication
Client contracts, project records and material correspondenceNormally six years after the relationship or relevant contract ends
Invoices, payments and tax or accounting recordsNormally six years after the relevant accounting period, or longer where law requires
Support requests and service-administration recordsUp to 24 months after closure, unless needed with the main contract record
Routine website and security logsNormally up to 90 days; relevant extracts may be retained longer for an incident or claim
Marketing preferences and suppression recordsUntil consent is withdrawn or an objection is made; a minimal suppression record may then be kept to honour the choice
Rights requests and data protection complaintsNormally three years after closure, unless a longer period is reasonably needed for a claim or legal obligation
Cookie or storage-notice preferenceUp to 183 days on the device, unless reset sooner
Chat greeting preference and secure chat session cookieThe greeting preference is used for 7 days, with its timestamp removed when next checked after expiry. The chat session cookie lasts up to 90 days. Either can be deleted sooner.

These periods must be reflected in day-to-day systems. A record may be retained for longer where litigation is reasonably anticipated, a legal hold applies, a regulator requires it, or deletion would conflict with another legal duty.

Security and incidents

We use proportionate technical and organisational measures intended to protect personal information against accidental or unlawful loss, alteration, disclosure, access or destruction. Measures may include access controls, least-privilege access, authentication, supported software, secure transfer, backups where contracted, confidentiality duties and provider due diligence.

No internet or storage system can be guaranteed completely secure. We assess suspected personal-data incidents and will notify affected people and the Information Commissioner's Office where the law requires it. Please report a suspected privacy or security issue promptly to legal@subtlestandard.com.

Your data protection rights

Depending on the circumstances and lawful basis, you may have the right to:

  • ask whether we use your personal information and receive a copy;
  • correct inaccurate or incomplete information;
  • ask for erasure of information in qualifying circumstances;
  • restrict how information is used in qualifying circumstances;
  • receive information you supplied in a structured, commonly used and machine-readable format, or ask us to transfer it, where portability applies;
  • object to processing based on legitimate interests and object at any time to direct marketing;
  • withdraw consent at any time, without affecting processing carried out before withdrawal; and
  • challenge a qualifying decision made solely by automated processing.

Rights are not absolute and exemptions may apply. Send a request to the privacy email above. We may ask for information reasonably needed to confirm identity, clarify the request or verify authority to act for another person. We normally respond within one month, subject to any lawful extension. There is normally no fee, although the law permits a reasonable fee or refusal in limited circumstances.

Your right to object

You can object to direct marketing at any time

If personal information is used for direct marketing, your objection is absolute. We will stop the marketing and may retain only the minimum suppression information needed to make sure the objection is respected.

You may also object where processing relies on legitimate interests. Tell us the reasons relating to your situation. We will stop unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the information is needed for legal claims.

Data protection complaints and the ICO

You can raise a data protection complaint electronically by emailing legal@subtlestandard.com with the subject “Data protection complaint”. Explain what happened, the information involved, the outcome you want and any relevant dates. Do not send unrelated identity documents unless requested.

You can also write to us at hello@subtlestandard.com or raise a concern through another contact channel. You do not have to use a particular subject line, form or legal wording for us to recognise and handle a data protection complaint.

We will acknowledge a data protection complaint within 30 days of receipt. We may provide the substantive outcome at the same time. Without undue delay, we will make appropriate enquiries, keep you informed where the investigation is ongoing and explain the outcome. If someone complains for you, we may require evidence that they are authorised to act.

You also have the right to complain to the UK Information Commissioner's Office. You can use the ICO's online complaint service, call 0303 123 1113, or write to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. We would appreciate the opportunity to address the issue first, but this does not restrict your right to approach the ICO or a court.

Children, automated decisions, links and changes

Children

The website and services are intended for business and professional audiences and are not directed to children. We do not knowingly seek personal information from children through the website. A parent or guardian who believes a child has provided information should contact us.

Automated decision-making

We do not currently make decisions about people using solely automated processing that produces legal or similarly significant effects, and the current site does not profile visitors for advertising.

External websites

Links to third-party websites do not make us responsible for their privacy practices. Review the notice provided by the relevant operator before giving it information.

Changes to this notice

We review this notice when services, providers, legal requirements or processing activities change. The version and date above identify this notice. If a material new use is proposed, we will provide information before it begins where required and seek fresh consent where consent is the lawful basis.

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© 2026 Subtle Standard. Based in Ascot, Berkshire. Working with local businesses across Berkshire and clients UK-wide.
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