Privacy Policy — Data Watch

Issued pursuant to Article 13 of the UK General Data Protection Regulation and Section 1 of the Data Protection Act 2018. Last reviewed: May 2026.

1. Identity and Contact Details of the Controller

The data controller for personal information processed via this website is AvonPunt, operating as an independent editorial publication under the laws of England and Wales. Enquiries relating to the processing of personal data may be directed to our Data Watch Officer via the Signal Centre contact form. We will acknowledge all data-related correspondence within five working days.

2. Categories of Personal Data and Purposes of Processing

AvonPunt processes the following categories of personal data:

  • Usage data: IP address (anonymised to /24 subnet), pages visited, session duration, referring URL, browser type, and device class. Collected automatically via server logs and, where consent is granted, via analytics cookies. Lawful basis: legitimate interests (Article 6(1)(f) UK GDPR) for server-log data; consent (Article 6(1)(a)) for cookie-based analytics.
  • Contact data: Name, email address, and message content submitted via the Signal Centre contact form. Lawful basis: performance of a pre-contractual step or legitimate interests in responding to enquiries.
  • Consent preferences: Records of your cookie consent choices (accept all / reject all / granular preferences), stored in your browser's localStorage. Lawful basis: legal obligation (Regulation 6 of the Privacy and Electronic Communications Regulations 2003).
  • Age verification data: A sessionStorage flag recording that you have confirmed you are 18 or over. No personally identifiable information is associated with this flag; it is destroyed when the browser session ends.

3. Legal Bases for Processing

Processing is carried out on one or more of the following lawful bases under Article 6 UK GDPR:

  • Consent (Art. 6(1)(a)): Analytics and marketing cookies, where you have affirmatively selected "Accept all" or granted granular consent in the cookie settings panel.
  • Legitimate interests (Art. 6(1)(f)): Server-log data collection for security monitoring, fraud prevention, and site-performance analysis. We have conducted a legitimate-interests assessment; a copy is available on request.
  • Legal obligation (Art. 6(1)(c)): Retention of consent records as required by PECR Regulation 6.

4. Recipients and Transfers

Personal data processed by AvonPunt may be shared with the following categories of recipient:

  • Hosting provider: Server infrastructure and log-file storage. Data is processed within the UK or EEA. Data processing agreement in place.
  • Analytics provider (Google Analytics): Only where you have granted analytics consent. Google LLC, headquartered in the United States, acts as a data processor under a standard contractual clauses arrangement. IP anonymisation is enabled by default.
  • Affiliate network partners: When you click a tracked link to an operator, the affiliate network records a click event linked to an anonymous click ID. No personal data collected by AvonPunt is transmitted to affiliate partners.

No personal data is sold, rented, or disclosed to third parties for their own marketing purposes.

5. Retention Periods

Server log files are retained for a maximum of 90 days before automatic deletion. Contact form submissions are retained for 12 months from the date of final correspondence, then securely deleted. Consent records are retained for three years to demonstrate compliance, in accordance with ICO guidance. Analytics data retained by Google Analytics is subject to Google's data-retention settings, which we have configured to 14 months.

6. Your Rights Under UK GDPR

You have the following rights in relation to personal data we hold about you:

  • Right of access (Art. 15): To receive a copy of personal data we hold about you within one calendar month of a verified request.
  • Right to rectification (Art. 16): To require correction of inaccurate personal data without undue delay.
  • Right to erasure (Art. 17): To request deletion of personal data where the data is no longer necessary, consent is withdrawn, or the processing is unlawful.
  • Right to restriction (Art. 18): To restrict processing pending verification of a rectification or objection request.
  • Right to data portability (Art. 20): To receive personal data you have provided to us in a structured, commonly used, machine-readable format.
  • Right to object (Art. 21): To object at any time to processing based on legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds.
  • Rights related to automated decision-making (Art. 22): AvonPunt does not engage in automated individual decision-making or profiling that produces legal or similarly significant effects.
  • Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time via the cookie settings panel accessible from any page footer.
  • Right to lodge a complaint (Art. 77): You have the right to lodge a complaint with the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; telephone 0303 123 1113; website ico.org.uk.

To exercise any of the above rights, please submit a request via the Signal Centre. We will verify your identity before processing the request.

7. Cookies

AvonPunt uses strictly necessary cookies (session management, age-gate state, consent preferences) and, where consent is granted, analytics cookies. A full description of cookies used, their purposes, and their retention periods is provided in the Cookie Policy.

8. Security

AvonPunt implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include TLS encryption for all data in transit, access controls limiting log-file access to authorised personnel, and regular security reviews. In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with Article 34 UK GDPR.

9. Changes to This Policy

We may update this policy to reflect changes in law, our processing activities, or ICO guidance. Material changes will be signalled by updating the "Last reviewed" date at the head of this document. We encourage you to review this policy periodically. Continued use of the website following a policy update constitutes acknowledgment of the revised policy, subject always to your rights to object or withdraw consent.