Introduction

Welcome to the 07 Heaven Systems privacy policy (trading name of 07 Heaven Design Ltd). 07 Heaven Systems respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how 07 Heaven Systems collects and processes your personal data through your use of this website, including any data you may provide when you sign up to our newsletter, purchase a product or service, take part in a competition, or fill out any form on the website. This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions so that you are fully aware of how and why we are using your data. This policy supplements other notices and is not intended to override them.

Controller

07 Heaven Systems is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this policy). We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

Contact details

• Full legal name: 07 Heaven Design Ltd (trading as 07 Heaven Systems)
• Email: dpo@07hs.co.uk
• Postal address: Suite 2 Elgor House, Westcliff-on-Sea, Essex, SS0 9HQ
• Telephone: 01702 410663

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues: www.ico.org.uk. We would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 02/05/26. Historic versions can be obtained by contacting us. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you, grouped as follows:

• Identity data: first name, maiden name, last name, username, marital status, title, date of birth, gender
• Contact data: billing address, delivery address, email address, telephone numbers
• Financial data: bank account and payment card details
• Transaction data: details about payments to and from you and details of products and services you have purchased
• Technical data: IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
• Profile data: username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
• Usage data: information about how you use our website, products and services
• Marketing and communications data: your preferences in receiving marketing from us and third parties, and your communication preferences

We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data is not considered personal data in law as it will not directly or indirectly reveal your identity. We do not collect any Special Categories of Personal Data (race, ethnicity, religious beliefs, health, biometric data, etc.) or information about criminal convictions.

If you fail to provide personal data

Where we need to collect personal data by law or under a contract with you, and you fail to provide it when requested, we may not be able to perform the contract. We will notify you if this is the case at the time.

How is your personal data collected?

Direct interactions

You may give us your Identity, Contact and Financial data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes personal data provided when you apply for our products or services, subscribe to our service, request marketing, use our chat feature, enter a competition or survey, or give us feedback.

Automated technologies or interactions

As you interact with our website, we automatically collect Technical data about your equipment, browsing actions and patterns using cookies, server logs and similar technologies. Please see our Cookies Policy for further details.

Third parties or publicly available sources

• Technical data from analytics providers (Google) and advertising networks
• Contact, Financial and Transaction data from payment service providers (PayPal)
• Identity and Contact data from publicly available sources (Companies House, Electoral Register)

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use it in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests do not override those interests
• Where we need to comply with a legal obligation

Generally, we do not rely on consent as a legal basis except for third-party direct marketing communications to you via email or text message. You may withdraw marketing consent at any time by contacting us.

Purposes for which we will use your personal data

Purpose / Activity	Type of data	Lawful basis
Register you as a new customer	Identity; Contact	Performance of a contract with you
Process and deliver your order; manage payments, fees and charges; collect and recover money owed	Identity; Contact; Financial; Transaction; Marketing and Communications	Performance of a contract with you; Legitimate interests (to recover debts)
Manage our relationship with you: notify of policy changes, ask you to leave a review or survey	Identity; Contact; Profile; Marketing and Communications	Performance of a contract; Legal obligation; Legitimate interests (to keep records updated)
Enable you to take part in a competition or survey	Identity; Contact; Profile; Usage; Marketing and Communications	Performance of a contract; Legitimate interests (to study how customers use our products)
Administer and protect our business and website (troubleshooting, IT services, network security, fraud prevention)	Identity; Contact; Technical	Legitimate interests (running our business); Legal obligation
Deliver relevant website content and advertising and measure its effectiveness	Identity; Contact; Profile; Usage; Marketing and Communications; Technical	Legitimate interests (to study how customers use our products and grow our business)
Use data analytics to improve our website, products, marketing, customer relationships and experiences	Technical; Usage	Legitimate interests (to define types of customers for our products and keep our website relevant)
Make suggestions and recommendations to you about goods or services that may interest you	Identity; Contact; Technical; Usage; Profile; Marketing and Communications	Legitimate interests (to develop our products and grow our business)

Marketing

We use HubSpot CRM to manage personal data. You will receive marketing communications from us if you have requested information or purchased goods or services from us and have not opted out. We will obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes.

You can ask us or third parties to stop sending marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us directly. Opting out does not apply to personal data provided as a result of a product or service purchase.

For information about the cookies we use, please see our Cookies Policy.

Disclosures of your personal data

We may share your personal data with:

• Internal group companies providing IT and system administration services
• External service providers, professional advisers, HMRC, regulators and other authorities
• Third parties to whom we may choose to sell, transfer or merge parts of our business or assets

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes.

International transfers

We do not routinely transfer your personal data outside the European Economic Area (EEA). Where transfers are necessary, we ensure a similar degree of protection is in place by using European Commission-approved safeguards, including adequacy decisions and model contractual clauses. Please contact us if you want further information on the specific mechanisms we use.

How long we keep your personal data

We retain personal data only as long as necessary to fulfil the purposes we collected it for, including legal, regulatory, tax, accounting and reporting requirements. By law we are required to keep basic information about customers (including Contact, Identity, Financial and Transaction data) for six years after they cease being customers. In some circumstances you may request deletion of your data (see your legal rights below). We may anonymise personal data for research or statistical purposes, in which case it may be used indefinitely without further notice.

Your legal rights

Under data protection laws you have the following rights:

• Request access to your personal data (a subject access request)
• Request correction of any incomplete or inaccurate data we hold about you
• Request erasure of your personal data where there is no good reason for continued processing
• Object to processing where we rely on legitimate interests and you feel it impacts your fundamental rights
• Request restriction of processing your personal data in certain circumstances
• Request transfer of your personal data to you or a third party in a structured, machine-readable format
• Withdraw consent at any time where we rely on consent to process your data

You will not usually be charged a fee to exercise these rights. We may need to verify your identity before fulfilling a request. We aim to respond to all legitimate requests within one month. To exercise any of these rights, contact us at dpo@07hs.co.uk.

Glossary

Lawful basis

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal third parties: other companies in the 07 Heaven group acting as joint controllers or processors and who provide IT and system administration services.

External third parties: service providers acting as processors (including IT and system administration), professional advisers acting as processors or joint controllers (lawyers, bankers, auditors, insurers), HMRC, regulators and other authorities who require reporting of processing activities in certain circumstances.