Version 1.0 — Effective 21 January 2026
The Short Version
We collect your email address. That's it. Purchases are handled by our payment processor, who collects billing information separately under their own privacy policy.
Who We Are
Hartley DSP is operated by Hartley Works Ltd, registered in England and Wales.
Contact for data queries: support@hartleydsp.com
What We Collect
Information You Provide
| Data | When Collected | Why |
|---|---|---|
| Email address | Registration, mailing list signup, or purchase | Account identification and access, customer support, essential communications, marketing (with consent) |
That's the complete list. We don't collect names, addresses, phone numbers, or payment details.
Information From Payment Processors
When you purchase a product, our payment processor (acting as Merchant of Record) collects payment and billing information directly. They share the following with us:
- Your email address
- What you purchased and when
- Transaction reference numbers
We do not receive or store your payment card details, billing address, or other financial information.
Full product purchase is not currently available. When it is, we will update the policy with details of our chosen payment processor(s).
Technical Information
Our web hosting provider automatically logs IP addresses and browser information for security and server operation. We do not routinely access these logs except for troubleshooting. Retention is managed by Krystal.
How We Use Your Email
Communications You'll Receive
Without separate consent (contractual/legitimate interest):
These typically include:
- Account verification and security notices
- Password reset emails
- Purchase confirmations and license delivery
- Important product updates, such as:
- Security fixes
- Critical bug fixes
- Significant improvements included in your licence
- Customer support, such as verifying your identity and responding to requests
With your consent (opt-in):
For example:
- Newsletter and announcements
- Marketing emails and promotional offers
- Beta testing invitations
You can withdraw marketing consent at any time via your account preferences or the unsubscribe link in any email.
Legal Basis for Processing
We process your data under the following legal bases. The examples given are illustrative, not exhaustive.
| Purpose | Legal Basis (GDPR Article 6) |
|---|---|
| Account management and access | Contract performance |
| Purchase fulfilment | Contract performance |
| Customer support | Contract performance |
| Security notices | Legitimate interest |
| Product updates (owned products) | Contract performance (where included in license), Legitimate interest (otherwise) |
| Marketing communications | Consent |
| Beta programme | Consent + Contract (Beta Testing Agreement) |
Who We Share Data With
Payment Processors
Purchases will be processed by third-party payment providers acting as Merchant of Record. They collect and process billing information under their own privacy policies.
Full product purchase is not currently available. When it is, we will update the policy with details of our chosen payment processor(s).
Service Providers
We use third-party service providers for web hosting and email delivery. These providers process data on our behalf to operate our services.
We Do Not
- Sell your data
- Share your email with unrelated third parties
- Use your data for advertising profiles
How Long We Keep Data
| Data | Retention |
|---|---|
| Active accounts | Until you delete your account |
| Mailing list (unsubscribed) | Email may be retained for suppression list to prevent re-subscription errors; removed on request |
| Purchase records | indefinitely (minimum 7 years required for legal/tax purposes) |
| Server logs | Managed by our hosting provider |
Your Rights
Under GDPR, you have the right to:
- Access your data (we'll provide what we hold)
- Rectify inaccurate data
- Erasure ("right to be forgotten") — with exceptions below
- Restrict processing in certain circumstances
- Portability — receive your data in a structured format
- Object to processing based on legitimate interest
- Withdraw consent at any time for consent-based processing
Exceptions to erasure: We may need to retain purchase records for tax and legal compliance, and basic email records to honour suppression requests.
To exercise any right, email support@hartleydsp.com.
Complaints
If you're unhappy with how we've handled your data, you can complain to the UK Information Commissioner's Office (ICO) at ico.org.uk.
Changes to This Policy
We'll notify you of material changes by email and update the version number and date above. Continued use of your account after notification constitutes acceptance of the updated policy.
Children
Our services are not directed at anyone under 16. We don't knowingly collect data from children.