Privacy Policy

1. Introduction and scope

This Privacy Policy describes how The Steerway ("The Steerway", "we", "us" or "our") collects, uses, stores, discloses and protects personal information in connection with the website located at thesteerway.com (the "Website") and the services we provide to clients (the "Services"). It applies to visitors of the Website, prospective clients who contact us, and client personnel we interact with in the course of an engagement.

By using the Website or providing personal information to us, you acknowledge the practices described in this Policy. If you do not agree with it, please do not use the Website or provide personal information to us.

2. Information we collect

2.1 Information you provide voluntarily. When you contact us through the Website or by email, we receive the information you choose to include: typically your name, email address, company name, and the description of your project or enquiry. When we enter into an engagement, we additionally collect the information reasonably required to contract and invoice, such as billing details and the names and business contact details of relevant personnel.

2.2 Information collected automatically. Our hosting infrastructure maintains standard server logs, which may include IP address, browser type and version, operating system, referring URLs, pages requested and timestamps. These logs exist for security, abuse prevention and reliability purposes.

2.3 Cookies and similar technologies. The Website does not set advertising or cross-site tracking cookies. Only technically necessary storage may be used (for example, to remember that an intro animation has already played within a session). If we introduce analytics in the future, we will prefer privacy-respecting tooling and update this Policy before doing so.

2.4 Information we do not seek. We do not ask for and do not wish to receive special categories of personal data (such as health, biometric or political information) through the Website. Please do not include such data in an enquiry.

3. How we use personal information

We use the information described above to:

(a) respond to enquiries and correspond with you; (b) prepare proposals, contracts and invoices; (c) perform and manage engagements; (d) maintain the security, integrity and availability of the Website and our systems; (e) comply with legal, accounting and tax obligations; and (f) establish, exercise or defend legal claims where necessary.

We do not sell or rent personal information. We do not use personal information for third-party advertising, profiling or automated decision-making that produces legal or similarly significant effects.

4. Legal bases

Where applicable data protection law requires a legal basis for processing, we rely on: performance of a contract or steps taken at your request prior to a contract; our legitimate interests in operating, securing and improving the Website and Services and in communicating with prospective clients; compliance with legal obligations; and consent, where we ask for it specifically.

5. Client data processed during engagements

Engagements may give us access to systems and datasets controlled by the client, such as CRM records, analytics properties, advertising accounts or databases. In respect of such data, the client remains the controller and The Steerway acts on the client's documented instructions. Such data remains in the client's own accounts wherever practicable, is used solely to perform the agreed work, is not reused for any other purpose, and our access is removed at handover unless continuing support is agreed. We execute non-disclosure and data processing agreements where required.

6. Disclosure of personal information

We disclose personal information only to: (a) service providers that support our operations, such as hosting, email and payment providers, limited to what is necessary for their function; (b) professional advisers such as accountants and lawyers, under duties of confidentiality; (c) public authorities where disclosure is required by applicable law, regulation or valid legal process; and (d) a successor entity in the event of a merger, acquisition or transfer of business assets, subject to this Policy.

7. International transfers

Our service providers may store or process information in jurisdictions other than your own. Where such transfers occur, we take reasonable steps to ensure an adequate level of protection consistent with applicable law, including contractual safeguards offered by the providers concerned.

8. Retention

We retain personal information only for as long as necessary for the purposes described in this Policy: enquiry correspondence for the duration of the exchange and a reasonable period thereafter; contractual and financial records for the periods required by applicable company, tax and accounting law; and server logs for short, rolling periods determined by our hosting providers. Information no longer required is deleted or irreversibly anonymised.

9. Security

We apply technical and organisational measures appropriate to the risk, including encryption of data in transit (HTTPS with HSTS), access on a need-to-know basis, segregated client accounts, reputable infrastructure providers, and prompt revocation of access at the end of engagements. No method of transmission or storage is completely secure; we cannot guarantee absolute security, but we review our measures on an ongoing basis.

10. Your rights

Subject to applicable law, you may have rights to: access the personal information we hold about you; request correction of inaccurate information; request deletion; object to or request restriction of processing; withdraw consent where processing is based on consent; and lodge a complaint with a supervisory authority in your jurisdiction.

To exercise any of these rights, write to legal@thesteerway.com. We may need to verify your identity before acting on a request, and we will respond within the timeframe required by applicable law.

11. Children

The Website and Services are directed at businesses and are not intended for children under 18. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact us and we will delete it.

12. Third-party websites

The Website may link to third-party websites. We are not responsible for the privacy practices or content of those websites. Review the privacy policies of any website you visit.

13. Changes to this Policy

We may update this Policy from time to time. The current version will always be published on this page with its effective date. Material changes will be highlighted on this page for a reasonable period. Continued use of the Website after changes take effect constitutes acceptance of the revised Policy.

14. Contact

For any privacy or data protection query, including requests under Section 10: legal@thesteerway.com.