This privacy policy applies between you, the User of this Website and Paul Kirkin, the owner and provider of  this Website. Paul Kirkin takes the privacy of your information very seriously. This privacy policy applies to  our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully

Definitions and interpretation 

  1. In this privacy policy, the following definitions are used:


collectively all information that you submit to Paul Kirkin via the  Website. This definition incorporates, where applicable, the  definitions provided in the Data Protection Laws;


a small text file placed on your computer by this Website when you  visit certain parts of the Website and/or when you use certain  features of the Website. Details of the cookies used by this Website  are set out in the clause below ( Cookies);

Data Protection  Laws

any applicable law relating to the processing of personal Data,  including but not limited to the GDPR, and any national  implementing and supplementary laws, regulations and secondary  legislation;


the UK General Data Protection Regulation;


Kirkin, we or us

Paul Kirkin of 4 The Saltings, Birdham, West Sussex, PO20 7JA;

UK and EU  

Cookie Law

the Privacy and Electronic Communications (EC Directive)  Regulations 2003 as amended by the Privacy and Electronic  Communications (EC Directive) (Amendment) Regulations 2011 &  the Privacy and Electronic Communications (EC Directive)  (Amendment) Regulations 2018;

User or you 

any third party that accesses the Website and is not either (i)  employed by Paul Kirkin and acting in the course of their  employment or (ii) engaged as a consultant or otherwise providing  services to Paul Kirkin and accessing the Website in connection with  the provision of such services; and


the website that you are currently using,, and  any sub-domains of this site unless expressly excluded by their own  terms and conditions.

  1. In this privacy policy, unless the context requires a different interpretation: 
  2. the singular includes the plural and vice versa; 
  3. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or  appendices of this privacy policy; 
  4. a reference to a person includes firms, companies, government entities, trusts and partnerships; d. “including” is understood to mean “including without limitation”; 
  5. reference to any statutory provision includes any modification or amendment of it; f. the headings and sub-headings do not form part of this privacy policy. 

Scope of this privacy policy 

  1. This privacy policy applies only to the actions of Paul Kirkin and Users with respect to this Website. It  does not extend to any websites that can be accessed from this Website including, but not limited to, any  links we may provide to social media websites. 
  2. For purposes of the applicable Data Protection Laws, Paul Kirkin is the “data controller”. This means  that Paul Kirkin determines the purposes for which, and the manner in which, your Data is processed. 

Data collected 

  1. We may collect the following Data, which includes personal Data, from you: 
  2. name; 
  3. contact Information such as email addresses and telephone numbers; 
  4. demographic information such as postcode, preferences and interests; 

in each case, in accordance with this privacy policy. 

How we collect Data 

  1. We collect Data in the following ways: 
  2. data is given to us by you ; and 
  3. data is collected automatically. 

Data that is given to us by you 

  1. Paul Kirkin will collect your Data in a number of ways, for example: 
  2. when you contact us through the Website, by telephone, post, e-mail or through any other means; b. when you use our services; 

in each case, in accordance with this privacy policy. 

Data that is collected automatically

  1. To the extent that you access the Website, we will collect your Data automatically, for example: 
  2. we automatically collect some information about your visit to the Website. This information helps us  to make improvements to Website content and navigation, and includes your IP address, the date,  times and frequency with which you access the Website and the way you use and interact with its  content. 
  3. we will collect your Data automatically via cookies, in line with the cookie settings on your browser.  For more information about cookies, and how we use them on the Website, see the section below,  headed “Cookies”. 

Our use of Data 

  1. Any or all of the above Data may be required by us from time to time in order to provide you with the  best possible service and experience when using our Website. Specifically, Data may be used by us for  the following reasons: 
  2. internal record keeping; 
  3. improvement of our products / services; 

in each case, in accordance with this privacy policy. 

  1. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate  interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the  section headed “Your rights” below). 

Who we share Data with 

  1. We may share your Data with the following groups of people for the following reasons: a. relevant authorities – to facilitate the detection of crime or the collection of taxes or duties; in each case, in accordance with this privacy policy. 

Keeping Data secure 

  1. We will use technical and organisational measures to safeguard your Data, for example: a. access to your account is controlled by a password and a user name that is unique to you. b. we store your Data on secure servers. 
  2. Technical and organisational measures include measures to deal with any suspected data breach. If  you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by  contacting us via this e-mail address: 
  3. If you want detailed information from Get Safe Online on how to protect your information and your  computers and devices against fraud, identity theft, viruses and many other online problems, please visit Get Safe Online is supported by HM Government and leading businesses. 

Data retention

  1. Unless a longer retention period is required or permitted by law, we will only hold your Data on our  systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request  that the Data be deleted. 
  2. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory  purposes. 

Your rights 

  1. You have the following rights in relation to your Data: 
  2. Right to access – the right to request (i) copies of the information we hold about you at any time, or  (ii) that we modify, update or delete such information. If we provide you with access to the  information we hold about you, we will not charge you for this, unless your request is “manifestly  unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we  refuse your request, we will tell you the reasons why. 
  3. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete. c. Right to erase – the right to request that we delete or remove your Data from our systems. 
  4. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the  way in which we can use it. 
  5. Right to data portability – the right to request that we move, copy or transfer your Data. 
  6. Right to object – the right to object to our use of your Data including where we use it for our  legitimate interests. 
  7. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the  processing of your Data (where consent is our legal basis for processing your Data), please contact us via  this e-mail address: 
  8. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us,  you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the  Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at 
  9. It is important that the Data we hold about you is accurate and current. Please keep us informed if  your Data changes during the period for which we hold it. 

Links to other websites 

  1. This Website may, from time to time, provide links to other websites. We have no control over such  websites and are not responsible for the content of these websites. This privacy policy does not extend to  your use of such websites. You are advised to read the privacy policy or statement of other websites prior  to using them. 

Changes of business ownership and control 

  1. Paul Kirkin may, from time to time, expand or reduce our business and this may involve the sale  and/or the transfer of control of all or part of Paul Kirkin. Data provided by Users will, where it is  relevant to any part of our business so transferred, be transferred along with that part and the new owner 

or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the  purposes for which it was originally supplied to us. 

  1. We may also disclose Data to a prospective purchaser of our business or any part of it. 24. In the above instances, we will take steps with the aim of ensuring your privacy is protected. 


  1. This Website may place and access certain Cookies on your computer. Paul Kirkin uses Cookies to  improve your experience of using the Website and to improve our range of services. Paul Kirkin has  carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected  at all times. 
  2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law. 
  3. Before the Website places Cookies on your computer, you will be presented with a message bar  requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are  enabling Paul Kirkin to provide a better experience and service to you. You may, if you wish, deny  consent to the placing of Cookies; however certain features of the Website may not function fully or as  intended. 
  4. This Website may place the following Cookies: 

Type of Cookie 


Strictly necessary cookies 

These are cookies that are required for the operation of our  website. They include, for example, cookies that enable you to  log into secure areas of our website, use a shopping cart or make  use of e-billing services.

Analytical/performance  cookies

They allow us to recognise and count the number of visitors and  to see how visitors move around our website when they are using  it. This helps us to improve the way our website works, for  example, by ensuring that users are finding what they are looking  for easily.

  1. You can find a list of Cookies that we use in the Cookies Schedule. 
  2. You can choose to enable or disable Cookies in your internet browser. By default, most internet  browsers accept Cookies but this can be changed. For further details, please consult the help menu in your  internet browser. 
  3. You can choose to delete Cookies at any time; however you may lose any information that enables  you to access the Website more quickly and efficiently including, but not limited to, personalisation  settings. 
  4. It is recommended that you ensure that your internet browser is up-to-date and that you consult the  help and guidance provided by the developer of your internet browser if you are unsure about adjusting  your privacy settings. 
  5. For more information generally on cookies, including how to disable them, please refer to You will also find details on how to delete cookies from your computer. 


  1. You may not transfer any of your rights under this privacy policy to any other person. We may  transfer our rights under this privacy policy where we reasonably believe your rights will not be affected. 
  2. If any court or competent authority finds that any provision of this privacy policy (or part of any  provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required,  be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy  will not be affected. 
  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be  deemed a waiver of that, or any other, right or remedy. 
  4. This Agreement will be governed by and interpreted according to the law of England and Wales. All  disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and  Welsh courts. 

Changes to this privacy policy 

  1. Paul Kirkin reserves the right to change this privacy policy as we may deem necessary from time to  time or as may be required by law. Any changes will be immediately posted on the Website and you are  deemed to have accepted the terms of the privacy policy on your first use of the Website following the  alterations. You may contact Paul Kirkin by email at 


  1. This privacy policy was created using a document from Rocket

Lawyer ( 

02 April 2021


Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you  think that we have missed a cookie or there is any discrepancy, please let us know. 

Strictly necessary 

We use the following strictly necessary cookies: 

Description of Cookie Purpose

Session Cookie 

We use this session cookie to remember you  and maintain your session whilst you are  using our website


We use the following analytical/performance cookies:

Description of Cookie Purpose


We use this cookie to help us analyse how  users use the website