LEGAL · REG
PROPER WEB LTD · 66 Paul Street, LONDON, EC2A 4NA United Kingdom · https://properweb.cloud
Privacy Policy
This Privacy Policy explains how PROPER WEB LTD (“we”, “us”, “our”) collects, uses, stores, shares and protects personal data when you visit https://properweb.cloud, communicate with us, or engage our computer systems design, IT consulting and software development services. We are a company established in the United Kingdom with its principal place of business at 66 Paul Street, LONDON, EC2A 4NA United Kingdom. You may contact us by telephone on +44 7245 678901 or by email at assist@properweb.cloud.
We process personal data in accordance with the United Kingdom General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) as amended, and other applicable laws of England and Wales. This Policy forms part of our wider compliance framework and should be read together with our Cookie Policy, Terms of Service and Terms and Conditions, each available on https://properweb.cloud.
By using our website or instructing us to provide services, you acknowledge that you have read this Privacy Policy. Where we rely on consent, we will seek that consent in a clear and affirmative manner. Where we rely on another lawful basis, we will identify it in this Policy or in a related notice provided at the point of collection.
1. Data controller and contact details
The data controller responsible for personal data processed under this Policy is PROPER WEB LTD. Our registered and trading address for correspondence is 66 Paul Street, LONDON, EC2A 4NA United Kingdom. For all privacy-related enquiries, including requests to exercise data subject rights, please write to assist@properweb.cloud or telephone +44 7245 678901. Please mark correspondence “Data Protection” so that it can be routed promptly.
If you are dissatisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the supervisory authority for data protection in the United Kingdom. We encourage you to contact us first so that we may attempt to resolve your concern. Details of the ICO are published at ico.org.uk. Nothing in this Policy limits your statutory rights under UK data protection law.
We may appoint a data protection lead or, where legally required, a data protection officer. Contact details for any such appointment will be published on https://properweb.cloud or provided on request via assist@properweb.cloud. Until a formal appointment is notified, privacy queries should be directed to the contact channels above.
2. Scope of this Policy
This Policy applies to personal data relating to visitors of https://properweb.cloud, prospective clients, clients, suppliers, contractors, professional contacts, recruitment candidates and any other individuals whose personal data we process in connection with our business of computer systems design and related services, IT consulting and software development. It does not apply to third-party websites or services that we do not control, even if they are linked from our site.
Where we process personal data on behalf of a client as a processor, the client’s instructions and the relevant data processing agreement will govern that processing in addition to this Policy. In such cases, the client remains the controller for the purposes of UK GDPR, and we act only on documented instructions unless we are required by law of England and Wales or the United Kingdom to process data otherwise.
This Policy covers processing carried out through our website, email, telephone, video conferencing, project management tools, cloud hosting platforms, analytics technologies and offline communications at our London premises or elsewhere in the United Kingdom. It also covers personal data contained in proposals, contracts, invoices, source code repositories (where personal data appears), support tickets and marketing materials where lawfully used.
3. Categories of personal data we collect
Depending on how you interact with PROPER WEB LTD, we may collect and process the following categories of personal data.
3.1 Identity and contact data
This includes your name, job title, employer or organisation, postal address, email address, telephone number and professional credentials. If you contact us from 66 Paul Street or arrange a meeting, we may also record visitor details for security and health and safety purposes consistent with legitimate interests and legal obligations.
3.2 Commercial and contractual data
This includes information needed to prepare quotations, statements of work, service agreements, purchase orders, invoices, payment references, project milestones, acceptance records and correspondence about deliverables. For business clients we typically process business contact data rather than consumer financial account details, but payment-related identifiers may be processed through our banking and accounting providers.
3.3 Technical and usage data
When you visit https://properweb.cloud we may collect internet protocol address, browser type and version, device type, operating system, referring uniform resource locator, pages viewed, time and date of visits, approximate location derived from IP address, and similar diagnostic information. Cookie and similar technology data are described more fully in our Cookie Policy.
3.4 Communication content
We process the content of emails, messages, forms, call notes and meeting notes that you send to assist@properweb.cloud or provide by telephone on +44 7245 678901, including attachments that may contain personal data. Please avoid sending unnecessary special category data unless we have expressly agreed a secure channel and lawful basis.
3.5 Recruitment data
If you apply for a role or submit a curriculum vitae, we may process employment history, education, skills, right-to-work information, references and interview assessments. Special category data will only be processed where permitted by Schedule 1 of the Data Protection Act 2018 and with appropriate safeguards.
3.6 Marketing preferences
Where we send electronic marketing, we record preferences, consents, soft opt-in status under PECR where applicable, suppression lists and unsubscribe requests so that we honour your choices.
4. Sources of personal data
We obtain personal data directly from you when you complete forms on https://properweb.cloud, email assist@properweb.cloud, call +44 7245 678901, attend meetings, sign contracts or use our services. We may also obtain personal data from your employer or colleagues when they nominate you as a project contact, from publicly available professional sources such as company websites and business registries, from referrals by existing clients, and from service providers who support our operations under appropriate contracts.
If you provide personal data relating to another individual, you confirm that you have the authority to do so and that you have provided that individual with the information in this Privacy Policy where required. PROPER WEB LTD relies on you to ensure that such disclosures are lawful.
Automated technologies on our website may collect technical data as described above. We do not knowingly purchase marketing lists of individuals without verifying a lawful basis and compliance with PECR and UK GDPR.
5. Purposes and lawful bases for processing
Under UK GDPR, we must have a lawful basis for each processing purpose. The following table of purposes is presented in narrative form for clarity.
We process identity and contact data to respond to enquiries, schedule consultations and maintain professional relationships. The lawful bases are typically legitimate interests in operating and growing a professional IT services business, and where applicable performance of a contract or steps taken at your request prior to entering a contract.
We process commercial data to negotiate, perform and administer contracts for computer systems design, IT consulting and software development, including billing and debt recovery. The lawful basis is performance of a contract and, for related compliance and record-keeping, legal obligation and legitimate interests.
We process technical and usage data to secure https://properweb.cloud, diagnose faults, improve performance, understand aggregated traffic patterns and prevent abuse. The lawful bases are legitimate interests in network and information security and, where cookies are not strictly necessary, consent as described in our Cookie Policy and PECR.
We process communication content to provide support, document instructions, manage projects and keep accurate business records. Lawful bases include contract performance, legitimate interests and legal obligation where records must be retained.
We process recruitment data to assess suitability for roles, conduct interviews and comply with employment and equality law. Lawful bases include steps prior to a contract, legitimate interests and legal obligation. Where special category data is involved, we rely on the relevant DPA 2018 conditions.
We process marketing data to send relevant information about our services where permitted. Where required by PECR, we obtain consent; otherwise we may rely on soft opt-in for existing customers of similar services, always providing a simple opt-out. You may withdraw consent or object at any time by emailing assist@properweb.cloud.
We may process personal data to establish, exercise or defend legal claims, comply with court orders, respond to regulators and meet tax and accounting duties under the laws of England and Wales and the United Kingdom. The lawful bases are legal obligation and legitimate interests.
6. Legitimate interests assessment
Where we rely on legitimate interests, we balance our interests against your rights and freedoms. Our core interests include delivering high-quality software and consulting services, maintaining a secure website and IT estate, preventing fraud and misuse, managing supplier and client relationships, improving our offerings based on non-intrusive analytics, and promoting our professional services to organisations that have shown interest or are existing clients.
We take into account the reasonable expectations of business contacts dealing with an IT consultancy at 66 Paul Street, LONDON, EC2A 4NA, the limited and proportionate nature of the data we hold, the availability of opt-outs for marketing, and the security measures described in this Policy. You may object to processing based on legitimate interests by contacting assist@properweb.cloud. We will cease processing unless we demonstrate compelling legitimate grounds or the processing is needed for legal claims.
7. Cookies and similar technologies
https://properweb.cloud uses cookies and similar technologies as explained in our Cookie Policy. Strictly necessary cookies are used on the basis of our legitimate interests and PECR exemptions for services requested by the user. Non-essential cookies, including analytics or preference cookies where deployed, are only set with your consent unless another PECR exemption applies. You can manage preferences through our cookie controls where available and through your browser settings. Disabling certain cookies may affect site functionality.
For further detail on cookie categories, retention and third-party providers, please read the Cookie Policy linked from every page of our website, including privacy-policy.html and the site footer Model Directory.
8. Sharing of personal data
We do not sell personal data. We share personal data only where necessary for the purposes described in this Policy, including with:
Service providers acting as processors under written contracts that impose UK GDPR-compliant obligations, such as hosting providers, email and productivity platforms, customer relationship tools, analytics providers (where consented), accountants, insurers and professional advisers.
Clients and project stakeholders where you are a nominated contact and sharing is required to perform the contract.
Regulators, courts, law enforcement or other authorities where required by the law of England and Wales or the United Kingdom, or where necessary to protect our rights, users or the public.
A prospective buyer or investor in the event of a corporate transaction involving PROPER WEB LTD, subject to appropriate confidentiality and, where required, notice to affected individuals.
All processors are required to process personal data only on our documented instructions, implement appropriate security, and assist us in meeting UK GDPR obligations including data subject rights and breach notification where applicable.
9. International transfers
PROPER WEB LTD is based in the United Kingdom. Some of our service providers may process personal data in countries outside the United Kingdom. Where we transfer personal data internationally, we ensure that a lawful transfer mechanism is in place, such as an adequacy regulation under UK GDPR, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another transfer tool recognised under UK law, together with transfer risk assessments where required.
If you require further information about specific transfer mechanisms applicable to your data, contact assist@properweb.cloud. We will provide a summary of safeguards without disclosing commercially sensitive security details that could create risk.
10. Retention
We retain personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, accounting and reporting requirements under English and Welsh law. Typical retention periods include: enquiry records for up to twenty-four months after last meaningful contact unless a longer period is needed; contractual and project records for six to seven years after the end of the engagement to align with limitation periods and tax rules; recruitment records for up to twelve months after the conclusion of a recruitment process unless you agree to a talent pool for longer; website logs for a shorter operational period unless needed for security investigations; and marketing suppression records for as long as necessary to honour opt-outs.
When personal data is no longer required, we securely delete or anonymise it. Backup copies may persist for a limited period until overwritten in accordance with our backup cycles, during which access remains restricted.
11. Security measures
We implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. Measures include access controls on a need-to-know basis, authentication for systems holding personal data, encryption in transit where supported, secure configuration of hosting environments, staff awareness of confidentiality, vendor due diligence, and incident response procedures.
No method of transmission over the internet or electronic storage is completely secure. While we strive to protect personal data relating to visitors of https://properweb.cloud and our clients, we cannot guarantee absolute security. Please use strong unique passwords for any portals we provide and notify us promptly at assist@properweb.cloud if you suspect unauthorised access.
Our premises correspondence address is 66 Paul Street, LONDON, EC2A 4NA United Kingdom. Physical documents containing personal data are handled with care and stored securely when retained in hard copy.
12. Data subject rights
Subject to UK GDPR and the Data Protection Act 2018, you have the following rights in relation to personal data we hold about you.
The right of access: you may request confirmation of whether we process your personal data and a copy of that data, together with certain information about the processing.
The right to rectification: you may request correction of inaccurate personal data and completion of incomplete data.
The right to erasure: you may request deletion in certain circumstances, for example where data is no longer necessary or consent is withdrawn and no other lawful basis applies.
The right to restrict processing: you may request that we limit processing in specified situations, such as while accuracy is contested.
The right to data portability: where processing is based on consent or contract and carried out by automated means, you may request to receive your data in a structured, commonly used and machine-readable format, or to have it transmitted to another controller where technically feasible.
The right to object: you may object to processing based on legitimate interests, and to processing for direct marketing, which we will stop upon request.
Rights related to automated decision-making: we do not make solely automated decisions producing legal or similarly significant effects about individuals visiting https://properweb.cloud. If that changes, we will update this Policy and provide required information.
The right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.
To exercise any right, contact assist@properweb.cloud or write to PROPER WEB LTD, 66 Paul Street, LONDON, EC2A 4NA United Kingdom, or call +44 7245 678901. We may need to verify your identity before fulfilling a request. We will respond within one month, extendable by two further months for complex requests as permitted by UK GDPR, in which case we will inform you.
13. Children
Our website and services are directed to businesses and professional adults. We do not knowingly collect personal data from children under sixteen for marketing or account creation. If you believe a child has provided personal data to us, please contact assist@properweb.cloud so that we can delete it where appropriate.
14. Personal data breach notification
In the event of a personal data breach likely to result in a risk to the rights and freedoms of individuals, we will notify the ICO without undue delay and, where feasible, within seventy-two hours of becoming aware, as required by UK GDPR. Where a breach is likely to result in a high risk to individuals, we will also communicate with affected data subjects without undue delay, unless an exception applies. We maintain internal procedures for detecting, investigating and documenting incidents affecting systems used for https://properweb.cloud and client engagements.
15. Third-party links
https://properweb.cloud may contain links to third-party websites, plug-ins or applications. Clicking those links may allow third parties to collect data about you. We do not control those third parties and are not responsible for their privacy statements. We encourage you to read the privacy policy of every site you visit.
16. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in law, technology, our services or our processing activities. The updated version will be published on https://properweb.cloud with a revised effective date. Material changes may be highlighted on the website or communicated to active clients where appropriate. Continued use of the website after changes are posted constitutes acknowledgement of the updated Policy, without prejudice to rights that require consent.
This Privacy Policy was prepared for PROPER WEB LTD operating in computer systems design and related services, IT consulting and software development, under the laws of England and Wales, United Kingdom.
17. How to contact us
For questions about this Privacy Policy or our data practices, contact PROPER WEB LTD at 66 Paul Street, LONDON, EC2A 4NA United Kingdom, telephone +44 7245 678901, email assist@properweb.cloud, website https://properweb.cloud. Please include sufficient detail for us to locate your records and respond accurately.
Related documents: Cookie Policy, Terms of Service, Terms and Conditions, and our Contact page.
18. Detailed processing activities by business function
This section provides additional transparency about how PROPER WEB LTD processes personal data across typical activities associated with computer systems design, IT consulting and software development delivered from our United Kingdom base.
18.1 Website administration
We operate https://properweb.cloud to describe our capabilities, present portfolio information, and enable organisations to request consultations. Personal data submitted through contact pathways is reviewed by authorised personnel only. We may keep a record of the pages that referred you to a contact action for internal performance measurement in aggregate form. Where individual-level analytics would require non-essential cookies, we will rely on consent as set out in the Cookie Policy.
Server logs may record IP addresses and request metadata for a limited period to investigate suspicious traffic, distributed denial-of-service attempts, or application errors. These logs are secured and accessed by technical staff on a need-to-know basis. Retention is kept short unless an investigation requires a longer period, in which case access remains restricted and documented.
18.2 Pre-sales and discovery
When an organisation approaches PROPER WEB LTD about a potential engagement, we process business contact details and information about the prospective project, including technical constraints, timelines and budget ranges. This processing is necessary to take steps at the request of the prospective client prior to entering a contract and to pursue our legitimate interest in responding accurately to commercial enquiries. We do not use discovery information for unrelated profiling of individuals.
Proposals and statements of work may include named stakeholders. Those individuals are typically acting in a professional capacity. We will still respect data subject rights and will update contact details promptly when notified via assist@properweb.cloud or +44 7245 678901.
18.3 Delivery of consulting and development services
During delivery we may process personal data appearing in client systems, content repositories, issue trackers, design files or test datasets. Where we act as processor, we follow the client’s documented instructions and the applicable data processing terms. Where we act as controller for our own operations, this Policy applies. Clients must not provide special category data or children’s data unless expressly agreed in writing with appropriate safeguards.
Project communications may be retained in email archives and project tools to evidence instructions, acceptance and change control. Retention aligns with the periods in section 10 and with any longer period required by a specific contract governed by the laws of England and Wales.
18.4 Support and maintenance
If you open a support request, we process the description of the issue, environment details and contact information needed to resolve the matter. We may need to access logs that incidentally contain personal data. Access is limited to personnel assigned to the ticket. After resolution, ticket content is retained for quality assurance and contractual record-keeping as described above.
18.5 Finance and administration
We process names, roles and business contact details of accounts payable and receivable contacts, together with invoice data, purchase order numbers and payment references. Processing is necessary for contract performance and for compliance with tax and accounting obligations applicable in the United Kingdom. Our accountants and banking providers process such data under their own privacy notices and our processor or controller-to-controller arrangements as applicable.
18.6 Supplier management
When PROPER WEB LTD engages subcontractors or vendors, we process contact details of supplier representatives and, where relevant, due diligence information. Sharing of client personal data with subcontractors occurs only under written terms imposing equivalent data protection obligations and only to the extent necessary for the subcontracted services.
19. Special category and criminal offence data
PROPER WEB LTD does not seek to collect special category personal data through https://properweb.cloud. Special category data includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a person, data concerning health, or data concerning a person’s sex life or sexual orientation.
If special category data is provided to us inadvertently, we will delete it where feasible unless processing is necessary for legal claims, employment law obligations in recruitment contexts with Schedule 1 conditions, or another UK GDPR Article 9 condition applies with an appropriate DPA 2018 condition. Criminal offence data will only be processed where authorised by law.
Please do not include special category data in routine emails to assist@properweb.cloud unless we have agreed a specific secure process for a defined purpose.
20. Automated tools in software delivery
In the course of software development we may use automated testing, continuous integration, monitoring and error-tracking tools. Those tools may process identifiers such as user IDs within client applications when configured by the client. Configuration choices that determine whether personal data is collected in staging or production environments remain the client’s responsibility unless we have expressly agreed to design privacy-preserving defaults as part of the statement of work.
We encourage privacy by design and by default in solutions we build, including data minimisation, role-based access, encryption options and retention controls, consistent with UK GDPR principles and the expectations of professional IT consulting practice in England and Wales.
21. Joint controllers and collaborative projects
Occasionally PROPER WEB LTD may collaborate with another organisation in circumstances that amount to joint controllership under UK GDPR. Where that occurs, we will determine our respective responsibilities for compliance in a transparent manner and make the essence of the arrangement available to data subjects on request via assist@properweb.cloud. In most standard client engagements we act either as independent controller for our business operations or as processor for client-controlled datasets, rather than as joint controller.
22. Records of processing
We maintain records of processing activities as required by UK GDPR Article 30, proportionate to the size and risk profile of our organisation. Those records include categories of data subjects and personal data, purposes, recipients, international transfers, retention and security measures at a high level. They are available to the ICO on request and are reviewed periodically by our privacy lead.
23. Training and accountability
Personnel who handle personal data receive guidance on confidentiality, secure handling, phishing awareness and escalation of suspected incidents. Access to client environments is granted only as needed for the engagement and is revoked when no longer required. Accountability measures include contractual clauses with vendors, documented policies, and leadership oversight from PROPER WEB LTD at 66 Paul Street, LONDON, EC2A 4NA United Kingdom.
24. Marketing in more detail
Business-to-business electronic mail marketing is conducted in line with PECR and UK GDPR. Where we rely on consent, you may withdraw it at any time. Where we rely on soft opt-in for similar services to existing customers, each message includes an unsubscribe mechanism. Postal marketing, if used, will respect objections. We do not engage in unsolicited automated calling. Preference changes can be sent to assist@properweb.cloud or requested by telephone on +44 7245 678901.
We may use business contact details obtained from legitimate networking, events or referrals to make proportionate professional approaches about our computer systems design and related services. You may object at any time and we will update our records accordingly.
25. Accuracy and your duty to update
We take reasonable steps to keep personal data accurate and up to date. Please notify us of changes to your contact details or role so that project communications and invoices remain correctly addressed. You can update us via assist@properweb.cloud. Inaccurate data will be rectified upon request without undue delay.
26. Governing law of privacy notices
This Privacy Policy is drafted for compliance with United Kingdom data protection law and is intended to be interpreted under the laws of England and Wales. Nothing in this Policy creates contractual rights beyond those required by statute, except where incorporated by reference into a signed agreement with PROPER WEB LTD.
For service-specific contractual terms, see our Terms of Service and Terms and Conditions. For cookie disclosures, see our Cookie Policy. To speak with us about a project, visit Contact or explore Services and About.
27. Processor due diligence summary
Before engaging processors that handle personal data for PROPER WEB LTD, we consider the nature of the processing, the sensitivity of the data, the provider’s security posture, contractual UK GDPR terms, and transfer mechanisms where data may leave the United Kingdom. Reviews are proportionate to risk and to the size of our organisation. Clients who appoint us as a processor may request a high-level description of sub-processors used for their engagement via assist@properweb.cloud, subject to confidentiality of security details that could create risk if publicly disclosed.
We update processor lists when material changes occur. Objection rights to new sub-processors, where contractually granted in a data processing schedule, will be handled as stated in that schedule rather than in this public Privacy Policy alone.
28. CCTV and premises visits
If you visit premises associated with PROPER WEB LTD at or near 66 Paul Street, LONDON, EC2A 4NA United Kingdom, building management may operate CCTV or access control systems as independent controllers. We will process visitor information you provide for meeting arrangements under legitimate interests in security and operations. Ask building reception about their surveillance notices where relevant.
29. Telephone call notes
Calls to +44 7245 678901 may be summarised in written notes for follow-up. We do not routinely record calls. If call recording is introduced, we will provide a notice at the start of the call and update this Policy. Notes form part of our business records and are retained under section 10.