Last updated: 15th August 2025
1. Who We Are
Controller: Jason McCarthy, sole proprietor, trading as DigitalPentagon.
Contact: Email: jason [@] f7.uk ; Address: The Farm, Cranwell Grove, Shepperton, TW17 0JR, UK.
2. What Data We Collect & How
We use Google Analytics and Facebook/Meta tracking pixels to measure website performance, analyze user engagement, and support ad targeting.
These tools may collect data such as your IP address, device/browser type, click behaviour, and session duration.
3. Legal Basis for Processing
We rely on consent (Article 6(1)(a) UK GDPR) for deploying tracking pixels and cookies that are not strictly necessary for website functionality. Should you withdraw your consent, we will cease non-essential tracking.
4. Cookies & Tracking Technologies
We use essential cookies (e.g. for login or preferences) that do not require consent.
For marketing and analytics cookies or pixels (Google, Facebook), explicit prior consent is required. You will be presented with a clear cookie consent banner to manage preferences.
No tracking will occur before you provide consent.
5. Third-Party Processors & Transfers
Data collected via these pixels is processed by:
Google (e.g., Analytics): subject to Google's data protection terms.
Meta Platforms (Facebook/Instagram): subject to Meta’s terms.
Any transfers outside the UK will be safeguarded as required under UK GDPR (e.g., adequacy decisions or standard contractual clauses).
6. Your Rights
Under UK GDPR, you have the right to:
Access your data; request corrections, deletion, or restriction of processing.
Object to processing based on consent or legitimate interests.
Withdraw consent at any time—this will not affect the lawfulness of prior processing.
Lodge a complaint with the Information Commissioner’s Office (ICO).
7. Data Retention
We retain personal data collected via tracking tools for [e.g., 26 months / specify your retention policy], after which it is aggregated or deleted.
8. Security & Accountability
We implement appropriate technical and organisational measures to protect your data. As the data controller, I am responsible for ensuring compliance with UK GDPR and PECR.
9. Changes to This Policy
Updates to this policy will be posted here with an updated “Last updated” date.
10. Getting in Touch
For questions about privacy, your rights, or this policy, contact:
Jason McCarthy – Jason [@] f7.uk.
Key Reminders
Consent first, tracking later: Do not trigger any pixels before consent is granted—ensures both PECR and GDPR compliance and avoids enforcement risks The Guardian.
Cookie banner: Must allow granular opt-in/opt-out for each category.
Visibility: The cookie banner must be unmissable and each page using tracking must clearly reference the Privacy Policy and opt-out options TermsFeed.