Privacy notice

Who is responsible?

The data controller is Jonatan Martin Santos, trading as ClearPend. Contact hello@clearpend.co.uk or use the postal address in our legal notice.

Information we use and why

Enquiries and project discussions

When you email us, we receive your address, name if supplied, message and any information or attachments you choose to include. We use these to respond, assess your request and prepare a proposal. Where you are a prospective contracting party, the basis is taking steps at your request before entering into a contract (GDPR Article 6(1)(b)). For business representatives and other correspondence, the basis is our legitimate interest in handling relevant business enquiries (Article 6(1)(f)).

Website delivery and security

Our hosting and security provider processes technical information such as IP addresses, requested URLs, request times and browser or device information to serve and protect the website. The basis is our legitimate interest in maintaining a secure, functioning website (Article 6(1)(f)).

Legal obligations and disputes

Where required, we retain or disclose relevant records to meet legal obligations (Article 6(1)(c)) or to establish, exercise or defend legal claims (Article 6(1)(f)).

Please send only the information needed for your enquiry. Avoid confidential client records, identity documents, financial account details or other sensitive information in a first message. Providing enquiry information is voluntary, but without a way to contact you and enough detail we may be unable to respond meaningfully.

Who receives information?

Cloudflare provides website hosting, delivery and security. Zoho provides our email service using the EU service region. These providers process information needed to operate their services. Information may also be shared with public authorities or professional advisers where legally required or necessary to handle a legal matter. We do not sell personal information.

These providers operate internationally, so service delivery or support may involve processing outside the European Economic Area. Their published data-processing terms describe the applicable transfer safeguards, including standard contractual clauses where relevant. You can request information about the safeguards applicable to your data by contacting us. See Cloudflare’s privacy policy, Cloudflare’s data-processing terms and Zoho’s privacy information.

How long is information kept?

For an enquiry that does not become a project, our policy is to delete the correspondence within 12 months of the last substantive exchange, unless you ask for earlier deletion and there is no overriding reason to retain it. If a project proceeds, the agreement and related records are kept for the relationship and any applicable legal retention or claims periods; project-specific arrangements will be explained before work starts.

Technical information is retained according to the hosting provider’s service settings and the operational or security purpose of the record. We do not maintain a separate visitor-tracking database. Records needed for a legal obligation or dispute may be retained with restricted access for as long as that obligation or dispute requires.

Cookies and website features

The website code does not add advertising cookies, analytics trackers, embedded social-media widgets or external fonts. Cloudflare may use technical security mechanisms when necessary to protect and deliver the site. Email links open your email application; pressing them does not send a message automatically. The copy-address button copies the public ClearPend email address only when you choose to use it.

Client materials and access

Project materials, access permissions, external service providers and any processing on a client’s behalf will be addressed separately before access is provided. Identifiable client information is handled only within the arrangements agreed for the project. We do not use this website to make automated decisions about individuals with legal or similarly significant effects.

Your rights

Depending on the circumstances, you may request access, correction, deletion, restriction or portability of your personal information, or object to processing based on legitimate interests. Where processing is based on consent, you may withdraw it without affecting earlier lawful processing.

Send your request to hello@clearpend.co.uk. We may ask for proportionate information to verify your identity; please do not send a copy of your ID unless it is necessary and specifically requested. We normally respond within one month; if a lawful extension is needed, we will explain it within that period.

You can complain to the Spanish Data Protection Agency (AEPD) or another competent supervisory authority. We welcome the opportunity to address a concern directly, but contacting us first is not a condition of making a complaint.

Changes to this notice

We will update this notice if our processing changes. The date above identifies the current version.