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Privacy Policy

Special EFX Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website, www.efx.co.uk, and will only collect and use personal data in ways described here, consistent with our obligations and your rights under the law.

 

1. Definitions

Account

means an account required to access and/or use certain areas and features of our Site.

Cookie

means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14 below.

Cookie Law

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

 

2. Information About Us

Our Site is owned and operated by Special EFX Ltd, a limited company registered in England under company number 05027569.

Registered address: Ettington Park Business Centre, Stratford upon Avon, CV37 8BT.

VAT number: GB 834 3566 20

 

Data Protection Contact: Holly McLeish

Email: holly@efx.co.uk

Telephone: +44 (0)1789 450005

 

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site. Our Site may contain links to other websites. We have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

4. What Is Personal Data?

Personal data is defined by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025 (collectively, “the Data Protection Legislation”), as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

This covers obvious information such as your name and contact details, but also less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us using the details in Part 15.
  • The right to access the personal data we hold about you. Part 13 explains how to do this.
  • The right to have your personal data rectified if it is inaccurate or incomplete.
  • The right to be forgotten – the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to withdraw consent at any time where we are relying on your consent as the legal basis for using your personal data.
  • The right to data portability. Where we process your data by automated means on the basis of consent or contract, you can ask for a copy of that personal data to re-use with another service or business.
  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

 

For more information about exercising your rights, contact us using the details in Part 15. Further information is available from the ICO at www.ico.org.uk or your local Citizens Advice Bureau.

 

6. What Data Do You Collect and How?

Depending on your use of our Site, we may collect and hold some or all of the personal data below:

 

Analytics Cookies (Google Analytics)

  • _ga, _ga_* – stores and counts page views – retained 1 year 1 month
  • _gid – calculates visitor, session and campaign data – retained 1 day
  • _gat_UA-* – used for user behaviour tracking – retained 1 minute

 

Analytics Cookies (Hotjar)

  • _hjFirstSeen, _hjAbsoluteSessionInProgress – session identification – retained 30 minutes
  • _hjRecordingLastActivity, _hjRecordingEnabled – recording session data – retained for session

 

7. How Long Will You Keep My Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Retention periods for data collected via cookies are set out in Part 6 above.

 

8. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

  • If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner may continue to use your personal data in the same way as specified in this Privacy Policy.
  • In some limited circumstances, we may be legally required to share certain personal data if we are involved in legal proceedings, complying with a legal obligation, a court order, or the instructions of a government authority.

 

9. How Do You Keep My Data Secure?

We take data security seriously. We use appropriate technical and organisational measures to safeguard your personal data, including antivirus and malware protection on all machines and drive encryption. If any of your personal data is shared with a third party, we will take steps to ensure it is handled safely, securely, and in accordance with your rights and our obligations under law.

 

10. How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails).

You may also wish to sign up to the Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS), and/or the Mailing Preference Service (MPS) to help prevent unsolicited marketing.

 

11. Can I Withhold Information?

You may access our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data. You may also restrict our use of Cookies – for more information see Part 14.

 

12. How Can I Make a Data Protection Complaint?

Under the Data (Use and Access) Act 2025, you have the right to make a formal data protection complaint directly to us. We take all complaints seriously and will investigate them fully and fairly.

 

Complaining to us:

Please contact Holly McLeish using the details in Part 15. You can complain by email, post, or telephone. Please include your name, a description of your concern, and what outcome you are seeking.

 

How we will handle your complaint:

  • We will acknowledge your complaint within 30 days of receiving it, confirming who is handling it and the expected timeframe for our response.
  • We will investigate thoroughly and keep you informed of progress, including the reason for any delays.
  • We will provide a full written response setting out the outcome and any action taken.

 

Escalating to the ICO:

If you remain dissatisfied with our response, or wish to raise your complaint directly with the data protection regulator, you have the right to contact the Information Commissioner’s Office:

 

Information Commissioner’s Office (ICO)

Website: www.ico.org.uk

Helpline: 0303 123 1113

Post: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

 

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can make a subject access request (SAR). All SARs should be made in writing and sent to the email or postal address in Part 15. There is normally no charge. We will respond within one calendar month of receiving your request. In some cases, particularly if the request is complex, we may require up to three months from the date of receipt.

 

14. How Do I Opt Out of Cookies?

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. You can also delete Cookies at any time from your browser’s settings. Please note that disabling Cookies may affect your experience of our Site.

For more information about controlling and deleting Cookies, including in browsers not described above, visit www.aboutcookies.org.

 

15. Contact Details

Holly McLeish

Special EFX Ltd

Ettington Park Business Centre, Stratford upon Avon, Warwickshire, CV37 8BT

Email: holly@efx.co.uk

Telephone: +44 (0)1789 450005

 

16. Changes to This Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary due to changes in the law or how we operate. Any significant changes will be communicated on our website. This policy was last updated in June 2026.

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