Privacy Notice

This notice explains how Tommy Lee, trading as 121 Net Design (“121”, “I”, “me” or “my”), handles personal information when you visit this website, make an enquiry, become a client or supplier, or communicate with me about my services.

Who we are

121 Net Design is the trading name of Tommy Lee, a sole trader based in Godalming, Surrey. Tommy Lee is the data controller for the personal information covered by this notice. You can contact me at tommy@121netdesign.com or by post at 121 Net Design, 121 Summers Road, Godalming, Surrey GU7 3BJ. This is a business contact address; it is not a registered office.

This notice covers personal information I handle for my own business purposes. When I process personal information solely on a client’s documented instructions while providing website, hosting or support services, the client is the controller for that processing and I act as its processor under our service arrangements. My role may differ for information I use for my own business purposes; this notice explains that processing.

Information we collect

I collect information that is reasonably needed to respond to enquiries, provide and support services, manage my business and operate this website securely. This may include:

• Contact information, such as your name, business or organisation, email address, telephone number and postal or billing address where relevant.
• Enquiry and project information, such as your requirements, website or domain details, project instructions, content you provide, correspondence and support requests.
• Client and supplier records, such as proposals, agreements, invoices, payment status and business correspondence.
• Website and technical information, such as IP address, browser and device details, pages visited, cookie choices, and security or anti-spam information generated when the site or its forms are used.

I usually receive this information directly from you. I may also receive relevant information from someone who refers you, from publicly available business sources, or from another person involved in a project, where this is reasonably necessary.

Please avoid sending sensitive personal information through the website or by email unless it is necessary for the work. I do not intentionally collect special category or criminal offence information for this website. If you provide such information, I will handle it only where necessary and where data protection law permits.

How and why we use information

I use personal information only where there is a lawful basis to do so. The main purposes and lawful bases are:

• Responding to enquiries and preparing proposals or quotations — to take steps at your request before entering into a contract and, where appropriate, for my legitimate interests in responding to prospective clients.
• Providing website design, hosting and support services — to perform a contract with you, take steps you request before entering into a contract, and manage the client relationship.
• Managing invoices, payments, tax and business records — to meet legal obligations and for my legitimate interests in managing and protecting my business.
• Maintaining and securing this website, its forms and communications — for my legitimate interests in keeping the website reliable, preventing spam and misuse, and protecting the business and its users.
• Measuring use of this website — with your consent, where non-essential analytics cookies or similar technologies are used.
• Establishing, exercising or defending legal claims — where necessary for my legitimate interests or to meet a legal obligation.

If information is needed to respond to your request or provide a service, and you do not provide it, I may be unable to proceed. This website does not make decisions about you solely by automated means that have legal or similarly significant effects. Where I rely on consent, you can withdraw it at any time; this will not affect processing carried out before you withdrew consent.

Sharing your information

I do not sell personal information. I share it only when reasonably necessary for the purposes described in this notice, including with:

• Website hosting and technical service providers, including 20i and providers used to deliver email, storage, security and website support.
• Google, if you consent to analytics. Google Analytics and Google Tag Manager are used to measure website use and manage analytics tags.
• Cloudflare, whose Turnstile service helps protect website forms from automated spam and misuse.
• Professional advisers, payment services, insurers or suppliers, where they need information to support the business or a project.
• Public authorities, regulators, courts or law enforcement, where disclosure is required or permitted by law.

Some service providers may process information outside the United Kingdom. Where personal information is transferred internationally, I use an appropriate transfer mechanism and safeguards required by data protection law.

I use reasonable technical and organisational measures to protect personal information. No internet transmission or storage system can be guaranteed to be completely secure.

How long I keep information

I keep personal information only for as long as reasonably necessary for the purpose for which it was collected. The period depends on the type of information and why I hold it. In general:

• Enquiries and proposals are kept while they are active and for a reasonable period afterwards in case you follow up or a related issue arises.
• Client, project, contract and support records are kept while I provide the service and for a reasonable period afterwards to manage the relationship, deal with queries or disputes, and meet legal obligations.
• Invoices and accounting records are kept for the period required by tax and accounting law.
• Website security and technical records are kept for the period reasonably needed to secure the site, investigate misuse or resolve technical incidents.
• Cookie and analytics consent records are kept for the period needed to record and respect your choices.

I may retain information for longer where necessary to comply with a legal obligation or to establish, exercise or defend legal claims. When information is no longer needed, I will securely delete it or anonymise it where appropriate.

Your data protection rights

Depending on the circumstances and the lawful basis for using your information, you may have the right to:

• ask for access to the personal information I hold about you;
• ask me to correct inaccurate or incomplete information;
• ask me to erase your information;
• ask me to restrict how I use your information;
• object to processing based on legitimate interests;
• receive certain information you provided in a portable format, where the right applies; and
• withdraw consent where consent is the lawful basis.

These rights are not absolute and may not apply in every situation. You can make a request using the contact details below. I may need to confirm your identity before responding. I aim to respond within one month, subject to any extension permitted by law. There is usually no fee unless a request is manifestly unfounded or excessive.

Cookies and analytics

This website uses essential technologies needed for normal operation, security, forms and remembering your cookie choices. With your consent, it also uses Google Analytics, managed through Google Tag Manager, to understand how visitors use the site and help improve it.

Cloudflare Turnstile helps protect forms from automated spam and misuse and may process technical information for that purpose. Analytics and other non-essential cookies or similar technologies are not activated unless you consent.

You can accept, reject or change your non-essential cookie choices using the cookie controls on the website. More detail is available in the Cookie Policy.

Contact and complaints

To ask a question, exercise a data protection right or raise a concern about how your information is used, contact Tommy Lee, trading as 121 Net Design:

• Email: tommy@121netdesign.com
• Post: 121 Net Design, 121 Summers Road, Godalming, Surrey GU7 3BJ

If you are unhappy with how I handle your personal information, please contact me first so I can try to resolve the issue. You can also complain to the Information Commissioner’s Office (ICO). Information about making a complaint is available at ico.org.uk.