Privacy Policy


By using this Agreement, you agree to the following:

No Lawyer-Client Relationship

This document has been prepared by [insert] for general informational purposes only and do not constitute advertising, a solicitation or legal advice. Neither the availability, transmission, receipt nor use of this document is intended to create, or constitutes formation of, a lawyer-client relationship or any other special relationship or privilege. You should not rely upon this document for any purpose without seeking legal advice.

Disclaimer of Liability

This document is provided as-is with no representations or warranties (express or implied), including (but not limited to) implied warranties of merchantability, fitness for a particular purpose and non-infringement. You assume complete responsibility and risk for use of this document.

[insert] expressly disclaims all liability, loss or risk incurred as a direct and/or indirect consequence of the use of this document. By using this document, you waive any rights and/or claims you may have against [insert] in connection therewith.
The information contained in this document is provided only as general information and may not reflect the most current market and legal developments and may not address all relevant business or legal issues; accordingly, information in this document is not promised or guaranteed to be correct or complete. Further, [insert] does not necessarily endorse, and is not responsible for, any third-party content that may be accessed through this document.


1.1 We take your privacy seriously. These terms explain the basis upon which we collect, process, store, use, share and disclose data and personal data (i.e. data that identifies you, or from which you are identifiable) (“Data”) that is yours (“Privacy Policy”). If you access, download, browse, register an account with and/or use (“Use”) this [NOTE: insert url] website (including its content) [and any App for this website][NOTE: Delete any references to App and definition below if web app only.] (“Site”) in any way, you confirm that you accept our Privacy Policy and that you agree to comply with it.

1.2 “App” means the mobile application software made available to you by us through an [NOTE: Insert app type e.g. Apple iOS and/or Android OS)] device, any upgrades and/or any other related software or documentation which help you to use the mobile application software.

1.3 Our Privacy Policy forms part of, and is subject to, the [(a)] End-User Terms of Use, [and (b) Business Terms of Use][NOTE: Only insert if we have B2B terms e.g. businesses advertising on the platform.].


2.1 Your Data will be collected, processed, stored and used by us, and other data processors acting under our instructions or those of one of our affiliates, business partners and/or suppliers. These data processors may be engaged in, among other things, helping us maintain the integrity and security of our Site.


[NOTE: You need to review the Data types and confirm whether you will be collecting them. Is there any other Data you will be collecting?]

3.1 Every time you visit our Site, we may collect Data about you. This includes (but is not limited to):

3.1.1 the Internet protocol (“IP”) address you used to connect your computer or other device to the Internet;

3.1.2 your login Data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

3.1.3 >Data about your visit, including (but not limited to) the full Uniform Resource Locators (“URL”) clickstream to, through and from our Site (including date and time), what you earched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;

3.1.4 Data from your mobile provider if you download or use our App over a mobile device e.g. Data about your location and your mobile device, including a unique identifier for your device;

3.1.5 >Data from a third party such as social media or [Note: insert relevant example] websites; and

3.1.6 Data about you provided by you, by filling in forms on our Site or by communicating with us by phone, e-mail or otherwise. This includes (but is not limited to) Data (e.g.   your name, address, e-mail address etc.) you provide
us when you register to Use our Site.

3.2 Please note that we may also collect Data about you from other sources. For example, we may collect Data about you:

3.2.1  If and when you Use any of any other websites or and/or Apps we operate or other services we provide. If this applies, we will have informed you when we collected that Data that it may be shared internally and combined with data collected on our Site  [NOTE: Will this take place?];

3.2.2  from third parties (including, for example, our affiliates, business partners and/or suppliers with whom we work. [NOTE: Please provide a full list of such business partners and suppliers.]

3.3 We may combine Data about you which we receive from other sources with Data you give to us. We may use this Data and the combined Data information for the purposes set out in Section 4 below.


4.1 We use Data about you in order to (without limitation):

4.1.1   manage your account and to notify you about any changes to our Site or otherwise;

4.1.2   administer our Site, for internal operations and to keep our Site safe and secure;

4.1.3   help us deliver our services and products to you.  This is done by sharing your Data with our suppliers that help us. Examples include (without limitation) hosting our web servers, analysing Data, providing marketing assistance, and providing customer service. These third parties will have access to your Data as necessary to perform their functions, but they may not use that Data for any other purpose. We will remain responsible for any Data shared in this way;

4.1.4   improve our Site to ensure that content is presented in the most effective manner for you and for your computer or other device (see our Cookies Policy here [insert hyperlink]);

4.1.5   carry out surveys with our users to evaluate potential features and services (we use such surveys to improve our services) and to respond to your questions, queries and comments;

4.1.6   be able to share your Data with third parties e.g. Facebook, if you have asked us to connect with your Facebook account;

4.1.7   allow you to participate in interactive features of our Site and sign up for any newsletters that we may introduce, if you choose to do so;

4.1.8   provide you with location-based services, such as advertising, search results, and other personalised content;

4.1.9   provide you with the information, products and services that you request from us and, if appropriate, other goods and services we, our affiliates and/or business partners offer;

4.1.10  provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;

4.1.11  detect, investigate and prevent activity we think may be potentially illegal, unlawful or harmful and to enforce our Privacy Policy and/or our Terms of Use or any other purpose set out in this Section 4;

4.1.12  help us meet our legal and compliance obligations;

4.1.13  help us effect a potential sale or asset transfer of [NOTE: Insert name of start-up.] to a third party, part of which will include your Data. Potential purchasers and their advisers may have access to your Data as part of the sale process. However, use of your Data will remain subject to this Privacy Policy. Similarly, your Data may be passed on to a successor in interest in the unlikely event of a liquidation, bankruptcy or administration. Our customer database could be sold separately from the rest of the business, in whole or in a number of parts. It could be that the purchaser’s business is different from ours too.


5.1 Data contributed by or collected from you may be stored, processed and transferred in the United Kingdom, the European Economic Area, or any other country in which we or our affiliates, business partners and/or suppliers maintain facilities. By submitting your Data, you agree to this transfer, storing and/or processing. If we transfer your Data outside the European Economic Area, we will comply with Data Protection Act by ensuring any such country has adequate data protection processes in place.


6.1 We take appropriate technical and organisational measures to guard against unauthorised or unlawful processing of your Data and against accidental loss or destruction of, or damage to, your Data. While no system is completely secure, we believe the measures implemented by our Site reduce our vulnerability to security problems to a level appropriate to the type of Data involved. We have security measures in place to protect our user database and access to this database is restricted internally. However, it remains your responsibility to (a) protect against unauthorised access to your use of our Site, (b) ensure no-one else uses our Site through your device while your device is logged on to our Site (including by logging on to your device through a mobile, Wi-Fi or share access connection you are using), (c) log off or exit from our Site when not using it, (d) where relevant, keep your password or other access information secret. Your password and log in details are personal to you and should not be given to anyone else or used to rovide shared access for example over a network. You should use a password which is unique to your use of our Site (do not use the same password as you use for another site or email account), and (e) maintain good internet security. For example if your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. You should keep all of your account details secure. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. You should also tell us as soon as you can so that we can try to help you keep your account secure and if necessary warn anyone else who could be affected.

6.2 If you have asked us to share Data with third party sites (such as Facebook), their servers may not be secure. Credit card information is generally stored by our credit card processing partners and we ask them to keep that Data secure. We also use third parties to help us optimise our website flow, content and advertising. Note that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result, others may nevertheless unlawfully intercept or access private transmissions or Data.

6.3 We will retain your Data only as long as is necessary for the purposes for which you have provided your consent in our Privacy Policy or as is required by applicable law. Once it is no longer necessary to store your Data, we will delete it.


7.1 We allow you to change or modify Data you have previously provided if it is incorrect or out of date. This may be done by sending the request to [NOTE: Insert chosen email address.].

7.2 You may opt-out of receiving marketing communications from us by the following means: (a) contact us at [NOTE: Insert chosen email address.], (b) follow the instructions included in each communication or newsletter, (c) use the Unsubscribe function, or (d) mail the request to us at: [NOTE: Insert the address the start-up wants to use.].

7.3 Please remember that if you change your preference it may take a short time for those preferences to become effective.


8.1 When you share Data about you on our Site, it may be indexable by search engines (e.g. Google) which may mean that the Data becomes public. For example, if you [Note: insert relevant example].

8.2 Our Site may also use Google Analytics to gather statistics on site usage. This may involve the use of cookies. There are more details in our Cookies Policy [insert hyperlink] and in Google’s own privacy policy. Google may aggregate data they collect form their various services including Google Analytics, Google Translate, Google Maps and YouTube. You acknowledge and accept that we have no control over Google’s data collection. We strongly advise that you look at Google’s privacy policy for details of their data collection practices. [NOTE: Will you be using Google Analytics or any other similar service?]


9.1 Our Site may, from time to time, contain links to and from the websites of our affiliates and business partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Data to these websites.


10.1    If you have any questions about this Privacy Policy, the practices of our Site, or your dealings with our Site, we encourage you to contact us at