Who we are
Tract is a trading name of Ethan Hewat, a sole trader based in the United Kingdom. We are the controller of the personal information described in this policy, which means we decide how and why it is used.
You can contact us about anything in this policy at info@ontract.co, or by post at Tract, 16 Lafitte House, London N19 3UE.
What we collect and why
We collect only what we need. The list below sets out what we hold, why, and the legal basis we rely on under UK GDPR.
- Name and email address, when you request a free resource such as our Black Friday cheat sheet. We use it to send you the resource and, because we say so when you sign up, the occasional useful email about marketing for home and furniture businesses. Legal basis: your consent.
- Booking details (name, email, phone number, business name and anything you write), when you book a call. We use them to arrange and run the call and to follow up about it. Legal basis: our legitimate interest in responding to enquiries, or taking steps you ask for before a contract.
- Enquiry and correspondence, when you email, call or message us. We use it to reply and keep a record. Legal basis: legitimate interests.
- Client information, such as business details, customer lists you share so that we can run campaigns for you, invoices and payment records. We use it to deliver our services, get paid and meet legal and tax obligations. Legal basis: contract, and legal obligation.
- Website and advertising data, such as pages viewed, device and approximate location, collected through cookies and similar technologies including the Meta Pixel. We use it to understand how our pages perform and to measure and improve our advertising. Legal basis: legitimate interests, and consent where the law requires it.
Customer lists you share with us
If you are a client and give us a list of your customers so that we can contact them on your behalf, you remain the controller of that data and we act as your processor. We will only use it to run the work you have asked for, keep it secure, and delete or return it when the work ends. We will put the details in your written agreement.
Who we share it with
We do not sell your personal information. We use a small number of trusted providers to run the business, and they only handle your information on our instructions:
- GoHighLevel (LeadConnector), which hosts our forms, booking calendar, CRM and email sending.
- Netlify, which hosts our website.
- Meta Platforms and Google, whose advertising and analytics tools we use.
- Our accountant and professional advisers, and our email and file storage providers.
- Authorities, where we are legally required to share information.
International transfers
Some of these providers are based in, or process data in, the United States. Where that happens we rely on appropriate safeguards, such as the UK’s International Data Transfer Agreement or Addendum, or the UK–US data bridge, so your information stays protected.
How long we keep it
- Marketing contacts: until you unsubscribe, or about two years after you last engaged with us, whichever is sooner.
- Enquiries and booking records: up to two years from our last contact, unless you become a client.
- Client and accounting records: up to six years after the work ends, as required for tax purposes.
- Website and advertising data: in line with the retention settings of the tools we use.
Marketing emails and your choices
We only send marketing emails to people who have asked for them, or where the law otherwise allows. Every email has an unsubscribe link, and you can also tell us at info@ontract.co. If you unsubscribe we will keep your email address on a suppression list so that we do not contact you again by mistake.
Cookies and the Meta Pixel
Our site and landing pages use cookies and similar technologies, including the Meta Pixel, to measure visits and the performance of our advertising. You can block or delete cookies in your browser settings, and manage how Meta uses your data for advertising in your Facebook and Instagram ad preferences.
Your rights
Under UK data protection law you have the right to:
- ask for a copy of the personal information we hold about you;
- ask us to correct anything that is wrong;
- ask us to delete your information;
- ask us to restrict, or object to, how we use it, including for marketing;
- ask for your information in a portable format; and
- withdraw consent at any time, without affecting what we did before you withdrew it.
Making a request or complaint
To use any of these rights, email info@ontract.co. We will reply within one month. If you are unhappy with how we have handled your information, you can complain to the Information Commissioner’s Office at ico.org.uk. We would appreciate the chance to put things right first.
Changes to this policy
We may update this policy from time to time. The date at the top shows when it was last changed.