Privacy Policy
Last Updated: 22nd September 2025
Who We Are
Digital Web Media Limited, trading as CTO Mark, is a limited company registered in England and Wales. We provide fractional CTO and technology consultancy services to businesses worldwide.
Company Details:
- Legal Name: Digital Web Media Limited
- Trading As: CTO Mark
- Registered Address: Barn Owl Cottage, Chapel Hill, Ponsanooth, Cornwall, UK, TR3 7ET
- Email: [email protected]
- Phone: 01326 536077
What Information We Collect
Information You Provide to Us
When you use our contact forms or get in touch with us, we may collect:
- Your name
- Email address
- Phone number
- Business name
- Nature of your enquiry
- Any other information you choose to share with us
Information We Collect Automatically
We use Google Analytics to understand how visitors use our website. This collects anonymous information about:
- Pages you visit on our site
- How long you spend on each page
- How you arrived at our site
- Your approximate location (country/city level only)
- Device and browser information
We only use essential cookies that are necessary for the website to function properly. We do not use marketing or tracking cookies.
How We Use Your Information
We use your personal information to:
- Respond to your enquiries and provide our services
- Communicate with you about your project requirements
- Improve our website and services
- Comply with legal obligations
We do not send marketing emails or use your information for advertising purposes unless you specifically request this.
Legal Basis for Processing
Under UK GDPR, we process your personal data on the following legal bases:
- Legitimate Interest: To respond to enquiries and provide our services
- Contract: To fulfill our contractual obligations when you engage our services
- Legal Obligation: To comply with legal and regulatory requirements
How We Store and Protect Your Information
Data Storage
We store your information using secure cloud services:
- Google Drive: For document storage and file sharing with appropriate access controls
- iCloud: For secure backup and synchronisation
- Our secure servers: For website data and contact form submissions
All data is stored with appropriate security measures including encryption and access controls.
Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. However, no internet transmission is completely secure, and we cannot guarantee absolute security.
Data Retention
We keep your personal information only as long as necessary for the purposes outlined in this policy:
- Enquiry data: Up to 2 years after initial contact
- Client project data: Up to 7 years after project completion (for legal and business purposes)
- Website analytics: 26 months (Google Analytics default retention)
Sharing Your Information
We do not sell, trade, or otherwise transfer your personal information to third parties except:
- Service Providers: We may share information with trusted third-party services (like Google Drive) that help us operate our website and conduct business
- Legal Requirements: We may disclose information if required by law or to protect our rights and safety
- Business Transfers: In the unlikely event of a business sale or merger
All third-party providers are carefully selected and required to maintain appropriate data protection standards.
International Transfers
We work with clients worldwide, which may involve transferring your data outside the UK/EU. When this happens, we ensure appropriate safeguards are in place, including:
- Adequacy decisions by the UK/EU authorities
- Standard contractual clauses approved by regulatory authorities
- Other legally recognised transfer mechanisms
Your Rights
Under UK GDPR, you have the following rights regarding your personal data:
- Access: Request a copy of the personal data we hold about you
- Rectification: Ask us to correct inaccurate or incomplete data
- Erasure: Request deletion of your personal data in certain circumstances
- Restriction: Ask us to limit how we use your data
- Portability: Request your data in a portable format
- Objection: Object to our use of your data for legitimate interests
- Withdraw Consent: Where we rely on consent, you can withdraw it at any time
To exercise any of these rights, please contact us at [email protected].
Google Analytics
We use Google Analytics to understand how our website is used. This service:
- Collects anonymous usage data
- Uses cookies to track website interactions
- Provides insights to help us improve our website
You can opt out of Google Analytics by:
- Using browser settings to block cookies
- Installing the Google Analytics opt-out browser add-on
- Using privacy-focused browsers or extensions
For more information, see Google’s Privacy Policy at https://policies.google.com/privacy
Contact Form Data
When you submit our contact form, your information is:
- Stored securely on our servers
- Used only to respond to your enquiry
- Not shared with third parties for marketing purposes
- Retained for up to 2 years or until you request deletion
Changes to This Policy
We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by updating the “Last Updated” date at the top of this policy.
Contact Us
If you have any questions about this privacy policy or how we handle your personal data, please contact us:
Email: [email protected]
Phone: 01326 536077
Address: Barn Owl Cottage, Chapel Hill, Ponsanooth, Cornwall, UK, TR3 7ET
You also have the right to complain to the Information Commissioner’s Office (ICO) if you believe we have not handled your personal data properly. Visit https://ico.org.uk for more information.