Privacy Notice

Last updated: 1 October 2026

1. Who we are

Websphere Studio is operated by Zackary Wright, a sole trader trading as Websphere Studio (“Websphere”, “we”, “us” or “our”).

Email: support@websphere.studio

Website: https://websphere.studio

For the purposes of UK data protection law, Zackary Wright trading as Websphere Studio is the data controller for the personal information described in this Privacy Notice.

2. Information we collect

We may collect personal information that you provide when you:

  • submit a Free Website application;
  • contact us through an enquiry or contact form;
  • communicate with us by email, telephone or another agreed channel;
  • become a client;
  • provide information or materials required for us to build, host, maintain or support your website.

This information may include:

  • your name;
  • business or trading name;
  • email address;
  • telephone number;
  • business address;
  • website and social-media links;
  • information about your business and services;
  • project requirements;
  • correspondence with us;
  • billing and invoice information;
  • content, images or files you provide for your website.

Please do not submit special-category or otherwise sensitive personal information through our general website forms unless we specifically request it and there is a legitimate reason for us to process it.

3. Technical information

Our website and hosting infrastructure may process limited technical information when you visit websphere.studio.

This may include:

  • IP address;
  • browser and device information;
  • request and server logs;
  • date and time of access;
  • error logs;
  • security-related information.

We may use this information where reasonably necessary to operate, secure, troubleshoot and maintain the website.

We do not use websphere.studio for behavioural advertising.

4. How we use your information

We may use personal information to:

  • respond to enquiries;
  • review Free Website applications;
  • assess whether a proposed project is suitable for our services and current capacity;
  • communicate with applicants and prospective clients;
  • prepare project scopes, service agreements and invoices;
  • enter into and perform contracts with clients;
  • design, build, host, maintain and support client websites;
  • make requested website content changes;
  • maintain business and accounting records;
  • protect our website, systems and services against misuse, fraud and security threats;
  • establish, exercise or defend legal claims;
  • comply with legal, regulatory, tax or accounting requirements.

5. Our lawful bases

We rely on one or more lawful bases under UK data protection law depending on why we are processing your information.

Contract and steps before entering into a contract

We may process your information where this is necessary to take steps at your request before entering into a contract, or to perform a contract we have entered into with you.

This may include reviewing an application, discussing project requirements, providing a proposal, preparing a service agreement, issuing invoices and providing Website Care or other agreed services.

Legitimate interests

We may process limited personal information where necessary for our legitimate business interests, provided those interests are not overridden by your rights and interests.

These legitimate interests may include:

  • administering enquiries and applications;
  • managing our business and client relationships;
  • maintaining appropriate business records;
  • protecting our services against abuse, fraud and security threats;
  • improving the reliability and operation of our services;
  • establishing, exercising or defending legal rights.

Legal obligation

We may process information where necessary to comply with legal obligations, including tax, accounting, regulatory and other statutory requirements.

Consent

Where we rely specifically on your consent, we will ask for it clearly.

You may withdraw consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

6. Free Website applications

Submitting an application does not guarantee acceptance.

We use the information provided in an application to:

  • understand the applicant’s business;
  • understand the requested website;
  • determine whether the project fits our standard Free Website scope;
  • assess suitability and current capacity;
  • communicate with the applicant;
  • manage accepted projects and our build queue.

Applications are reviewed by us.

We do not use solely automated decision-making to determine whether an application is accepted.

7. Service providers

We use third-party service providers where necessary to operate Websphere Studio and provide our services.

These may include providers of:

  • website hosting and deployment;
  • form delivery;
  • email;
  • domain and DNS services;
  • invoicing and payment processing;
  • cloud storage;
  • infrastructure and security services;
  • accounting or bookkeeping services.

Free Website applications and general business enquiries are stored using a database service.

Where third parties process personal information on our behalf, we take reasonable steps to use providers appropriate for the services being provided.

Some third-party providers may also process information as independent controllers under their own privacy notices.

8. International transfers

Some of our service providers may process or make personal information accessible outside the United Kingdom.

Where UK data protection law treats this as a restricted international transfer, we will use an appropriate lawful transfer mechanism where required.

This may include:

  • UK adequacy regulations;
  • appropriate contractual safeguards;
  • another lawful transfer mechanism permitted by UK data protection law.

You may contact us at support@websphere.studio if you require further information about relevant safeguards.

9. Payments

We do not require you to submit payment-card details directly through the standard forms on websphere.studio.

Payments may be made by bank transfer or through a third-party payment provider where offered.

If a third-party payment processor is used, that provider may process payment information under its own privacy notice and terms.

We may retain invoice, transaction-reference and payment-status information where necessary for accounting, contractual and legal purposes.

10. How long we keep information

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected and for relevant legal, accounting, contractual and business requirements.

Our general retention approach is:

  • unsuccessful, declined or inactive applications and enquiries may normally be retained for up to 12 months after the last meaningful contact;
  • client correspondence and project records may normally be retained for the duration of the client relationship and for up to 6 years afterwards where reasonably necessary for contractual, accounting or legal purposes;
  • invoices, payment records and accounting information are retained for the period required by applicable tax and accounting law;
  • technical and security logs are retained only for an appropriate operational or security period.

We may retain information for longer where reasonably necessary to establish, exercise or defend legal claims or where we are legally required to do so.

11. Sharing your information

We do not sell personal information.

We may share information where reasonably necessary with:

  • service providers that support our website or services;
  • payment, invoicing, accounting or bookkeeping providers;
  • professional advisers such as accountants, insurers or legal advisers;
  • regulators, courts, law-enforcement bodies or public authorities where legally required;
  • a purchaser or successor if all or part of the business is sold, transferred or reorganised, subject to appropriate safeguards.

12. Your data protection rights

Depending on the circumstances and the lawful basis used for processing, you may have rights including:

  • the right to access personal information we hold about you;
  • the right to ask us to correct inaccurate or incomplete information;
  • the right to ask us to erase personal information in certain circumstances;
  • the right to ask us to restrict processing in certain circumstances;
  • the right to object to certain processing;
  • the right to data portability in certain circumstances;
  • the right to withdraw consent where processing is based on consent.

These rights may be subject to legal conditions and exemptions.

Your right to object

Where we process personal information on the basis of legitimate interests, you may have the right to object to that processing.

To exercise any of your data protection rights, contact:

support@websphere.studio

We may need to verify your identity before completing a request.

13. Complaints

If you have concerns about how we use your personal information, please contact us at:

support@websphere.studio

We will try to investigate and resolve the issue.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.

Information Commissioner’s Office:
https://ico.org.uk

14. Security

We use reasonable technical and organisational measures intended to protect personal information from unauthorised access, loss, misuse, alteration or disclosure.

No internet-based service can be guaranteed to be completely secure.

15. Cookies and analytics

We do not use websphere.studio for behavioural advertising.

We use Google Analytics to understand how visitors use websphere.studio and to help us improve the website. The Google tag loads when the site loads, using Google Consent Mode with analytics storage and advertising-related consent states denied by default. Analytics cookies and storage are not granted unless you choose to accept analytics.

While consent remains denied, Google Analytics may receive limited, cookieless consent and technical signals. If you accept analytics, analytics storage is updated to granted; advertising storage and personalisation remain denied.

Google may process technical and browser usage information, such as device and browser details, approximate location derived from an IP address, pages viewed and interactions with the website. We do not send application or enquiry contents, names, email addresses, telephone numbers, business names, full submission references or other direct identifiers to Google Analytics.

You can reject analytics when the consent banner is shown. You can change your choice later using the “Analytics settings” link in the website footer.

16. Changes to this Privacy Notice

We may update this Privacy Notice where our services, providers, legal obligations or processing activities change.

The latest version will be published on websphere.studio and the “Last updated” date will be revised where appropriate.