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RE-FRESH MARKETING
PRIVACY POLICY

Last Updated: Monday 27th April 2026

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Re‑Fresh Marketing ("we", "us", "our") is committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains what information we collect, how we use it, and the rights you have under UK GDPR and the Data Protection Act 2018.

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We operate as a freelance digital marketing and creative agency based in the UK, providing services such as social media management, digital advertising, content creation, photography, videography, and marketing consultancy.

1. Who We Are

Re‑Fresh Marketing
Email: re-freshmarketing@outlook.com
Phone: 07365437639
Registered Address: Office 9376, 321–323 High Road, Chadwell Heath, Essex, RM6 6AX
Data Controller: Callum Bishop

 

When we work with subcontractors, they act as Data Processors and must comply with UK GDPR.

2. What Personal Data We Collect

We collect different types of information depending on how you interact with us.

2.1 Information you provide directly

  • Name

  • Email address

  • Phone number

  • Business name, title and contact details

  • Project briefs and creative requirements

  • Billing information

  • Any information submitted via contact forms, emails, or messages

2.2 Information collected automatically

When you visit our website or social platforms:

  • IP address

  • Device type

  • Browser type

  • Pages visited

  • Time spent on site

  • Cookies and tracking data (e.g., Google Analytics, Meta Pixel)

2.3 Information collected during projects

Depending on the work we carry out:

  • Photos, videos, or audio recordings

  • Social media account access (where agreed)

  • Marketing performance data

  • Consent forms for photography/videography

  • Contact details for client team members

2.4 Sensitive data

We do not intentionally collect sensitive data. If safeguarding concerns arise during photography/videography, we follow our Safeguarding Policy and only record what is necessary.

3. How We Use Your Personal Data

We use your information to:

  • Provide and manage our services

  • Communicate with you about projects, proposals, and support

  • Deliver digital marketing campaigns

  • Improve our website and services

  • Send invoices and manage payments

  • Maintain internal records

  • Comply with legal obligations

  • Protect our business from fraud or misuse

We do not sell your data or share it with third parties for marketing.

4. Legal Basis for Processing

Under UK GDPR, we rely on the following lawful bases:

  • Contract: To deliver the services you’ve hired us for

  • Consent: For cookies, newsletters, photography/videography consent

  • Legitimate interests: For business operations, analytics, and communication

  • Legal obligation: For tax, safeguarding, or regulatory requirements

For photography and videography, our lawful basis is consent, which can be withdrawn at any time.

5. How We Store and Protect Your Data

We take data security seriously. Your information may be stored in:

  • Secure cloud storage (e.g., Google Workspace, Microsoft 365)

  • Encrypted devices

  • Password‑protected project management tools

  • Secure CRM or email platforms

We use:

  • Strong passwords

  • Two‑factor authentication

  • Access controls

  • Regular data reviews

We only keep data for as long as necessary for the purpose it was collected.

6. Sharing Your Data

We may share your data with trusted third parties when necessary, such as:

  • Payment processors

  • Email and CRM platforms

  • Cloud storage providers

  • Subcontractors (e.g., photographers, videographers)

  • Advertising platforms (Meta, Google, TikTok)

  • Legal or regulatory bodies (if required)

All subcontractors and partners are required to comply with UK GDPR. We never sell or trade your data.

7. International Transfers

Some tools we use may store data outside the UK (e.g., US‑based cloud services). We only use providers with appropriate safeguards such as:

  • UK GDPR adequacy decisions

  • Standard Contractual Clauses (SCCs)

  • Strong security and compliance frameworks

8. Your Rights

You have the right to:

  • Access your personal data

  • Correct inaccurate information

  • Request deletion (“right to be forgotten”)

  • Restrict processing

  • Object to processing

  • Withdraw consent

  • Request data portability

To exercise your rights, email us at re-freshmarketing@outlook.com.

9. How to Complain

If you are unhappy with how we handle your data, you can contact the Information Commissioner’s Office (ICO): Website: ico.org.uk
Phone: 0303 123 1113

We would always appreciate the chance to resolve your concerns first.

10. Cookies

Our website uses cookies to improve your experience and analyse performance.

You can:

  • Accept or decline cookies

  • Change your browser settings

  • Withdraw or update your cookie preferences at any time

  • Request more information about how cookies are used

A full Cookie Policy can be accessed here

11. Photography & Videography

When capturing images or footage:

  • We obtain consent where required

  • We follow our Safeguarding Policy

  • We store media securely

  • We only use content for agreed purposes

Clients are responsible for ensuring consent from participants at their events unless otherwise agreed.

12. Data Retention

We keep data only for as long as necessary:

  • Client project files: typically 12–36 months

  • Financial records: 6 years

  • Email enquiries: 12 months

  • Photography/videography consent forms: duration of usage rights

We review data regularly and securely delete what is no longer needed.

13. Data Breaches

If a data breach occurs, we will:

  • Assess the severity

  • Notify affected individuals where required

  • Report to the ICO if legally necessary

  • Take steps to prevent future breaches

14. Children’s Data

We do not knowingly collect personal data relating to children. If you believe a child has provided us with personal information, please contact us so we can delete it.

15. Third‑Party Links

Our website may contain links to third‑party websites. We are not responsible for their privacy practices or content.

16. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website.

17. Contact Us

If you have questions about this policy or how we handle your data:

Re‑Fresh Marketing
Email: re-freshmarketing@outlook.com
Phone: 07365437639

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