1. Scope and Identity of the Data Controller
This policy applies to all interactions with the togetherlyvaultbx online portal. The data controller responsible for personal information processed through this website is Togetherly Vault Ltd, St Dunstan's House, 133–137 Fetter Lane, Holborn, London, EC4A 1BT, United Kingdom. We operate in strict conformity with the United Kingdom Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), and, where applicable to international visitors, the European Union General Data Protection Regulation (EU GDPR) and the California Consumer Privacy Act (CCPA).
2. Information We Collect and Lawful Grounds for Processing
We process personal data only when an explicit, lawful basis exists under applicable data protection statutes:
- Direct Communications: When you submit our editorial contact form, we collect your name, email address, inquiry topic, and message text. We process this information under our legitimate interest in responding to editorial queries and research communications.
- Technical and Server Telemetry: When you access our static server assets, automated access logs record your IP address, browser user-agent string, referring URL, and access timestamps. This processing is necessary for our legitimate interests in securing network infrastructure, mitigating denial-of-service attempts, and verifying server health.
- Client-Side Preferences: We record your cookie consent choice locally within your browser's localStorage. This is processed to comply with our statutory legal obligations under Privacy and Electronic Communications Regulations (PECR).
3. Third-Party Data Processors and Transfers
We do not sell, rent, lease, or monetize your personal data to advertisers, data brokers, or commercial marketing enterprises. We engage carefully vetted infrastructure providers to deliver our online services, including domestic hosting providers and secure cloud content delivery networks based in the United Kingdom and European Economic Area. Where data is processed outside the United Kingdom, transfers occur exclusively under approved International Data Transfer Agreements (IDTA) or standard contractual clauses providing equivalent protections.
4. Data Retention Periods
Personal data is retained only for the minimum duration required to satisfy the operational purpose for which it was gathered. Technical server connection logs are purged automatically after a standard rolling retention window of thirty days. Correspondence submitted via our contact form is retained for up to twenty-four months to maintain institutional records of editorial correspondence, after which records are permanently deleted unless ongoing legal obligations require longer preservation.
5. Your Statutory Rights Under UK GDPR and CCPA
Depending on your geographic residency, you maintain distinct statutory rights regarding your personal information:
- Right of Access: You may request confirmation of whether we process your personal data and obtain a copy of such information.
- Right to Rectification: You may request the correction of inaccurate or incomplete personal records.
- Right to Erasure: You may request the deletion of your personal data where retention is no longer justified.
- Right to Restrict or Object: You have the right to object to processing grounded in legitimate interests or request temporary restriction of processing.
- Right to Non-Discrimination: We do not discriminate against any user who exercises statutory privacy rights under the CCPA or UK data protection laws.
6. Privacy Contact and Supervisory Authorities
If you wish to exercise your data protection rights or have inquiries regarding our data processing policies, you may contact our designated privacy officer via email at [email protected] or via postal dispatch to Togetherly Vault Ltd, St Dunstan's House, 133–137 Fetter Lane, Holborn, London, EC4A 1BT. If you believe your data has been handled unlawfully, you have the statutory right to lodge a formal complaint with the UK Information Commissioner's Office (ICO) at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.