DRAFT. Not legal advice. Chris Kirby must review this, ideally with a solicitor check, before going live. Items in [brackets] need completing.
Last updated: [date] (draft revised 13 October 2026: newsletter section added)
Controller: Chris Kirby, a sole trader operating Tidy Cyber (tidycyber.co.uk). Contact address: Chris Kirby, trading as Tidy Cyber, 9 Appledore Road, Brighton, BN2 4PT. Contact: [email]. ICO registration number: [ZAxxxxxxx] (data protection fee paid).
What we collect - Your email address and the domain(s) you submit. - Scan results: public DNS, certificate and HTTP header information about the domain you check. A free check of a domain you don't own only processes information that domain already publishes publicly. - Payment details are handled by Stripe. We receive only limited details (name, email, billing country, last 4 card digits), never full card numbers. - Basic server logs (IP address, time, pages requested) for security, kept for up to [30] days. - Free check log: for each free summary check we record the domain checked, the time, and a keyed hash of your IP address (not the IP itself), so we can enforce fair-use limits and spot abuse. Kept for [90] days.
Why we use it, and our lawful basis (UK GDPR Art. 6) - To provide checks, reports and monitoring alerts: contract. - Payments, invoices and accounting records: legal obligation (HMRC requires business records to be kept for 6 years). - Security, fraud and abuse prevention, including the free check log and rate limits: legitimate interests (keeping a free service available and preventing misuse). [Chris: record a short legitimate interests assessment.] - The monthly security tips newsletter and any other marketing emails: only with your consent (UK GDPR Art. 6(1)(a) and PECR reg. 22). You can withdraw consent at any time. See below.
Who we share it with (processors): Stripe (payments), Fly.io (hosting), Supabase (database), Resend (email delivery, once enabled) [confirm processors], and Google Public DNS (domain lookups only; no personal data). Some processors are outside the UK. Transfers rely on UK adequacy regulations or the International Data Transfer Addendum.
Retention: scan results for 12 months after your last activity; subscription records for the life of the subscription plus 6 years (accounting).
Your rights: access, rectification, erasure, restriction, objection and portability. Contact [email]. You can complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113).
Cookies: we use only strictly necessary cookies. Stripe sets its own cookies on the checkout page. [Update if analytics are added.]