Privacy Policy
Last updated: August 2026 · DKT Digital, St Peter Port, Guernsey GY1 · Controller: Daniel Thomas, [email protected]
1. Who we are
DKT Digital is a business automation consultancy based in St Peter Port, Guernsey (GY1), Channel Islands. We act as the data controller for personal data collected via this website. We will register with the Office of the Data Protection Authority (ODPA), Guernsey, before processing any client personal data. Contact: [email protected].
2. What data we collect
- Name, email address, business name, phone number (submitted via our contact form)
- Technical data: IP address, browser type, pages visited, time on site (via server logs only, no analytics cookies)
- Communications: emails and messages you send us
- Client data: billing information and business details provided during onboarding (processed under contract)
3. Why we collect it (lawful basis)
- Contact form submissions: Legitimate interest (responding to enquiries) / pre-contractual steps
- Client onboarding data: Performance of a contract
- Marketing (newsletter): Consent. You can unsubscribe at any time
- We do not sell your data to third parties
4. How we use your data
- Respond to enquiries within one business day
- Deliver agreed automation services
- Send invoices and service updates
- Send our newsletter if you subscribed (unsubscribe link in every email)
5. Who we share it with
We do not sell your data. To deliver the service we use the processors below, each under its own data-protection terms; we share only the data each needs for its purpose:
- Hetzner Online GmbH: hosts the server our automation platform and database run on, in Falkenstein, Germany — this is where your data is stored.
- Cloudflare: website and client-portal hosting, CDN, access control, bot protection, and encrypted off-site backup storage; all site traffic passes through it.
- Resend (with Brevo as a secondary path): sending your transactional emails (welcome messages, reminders, reports, invoice reminders).
- Stripe and GoCardless: card and Direct Debit payment processing (payer name, bank/card details, payment reference), each subject to its own GDPR-compliant privacy policy.
- Google (Workspace / Cloud): calendar bookings (name, email, time) and, where enabled, spreadsheet sync, via a service account.
- Calendly: appointment booking (name, email); Crisp: website live chat (your messages and email address).
- TrueLayer: read-only open-banking verification for clients who connect a bank feed as part of our tax-audit service, with your explicit authorisation (FCA-regulated).
- Xero: your own accounting data, accessed only under your authorisation.
- Telegram: operational alerts to us that may contain your name or email.
- AI providers (Groq, Cerebras, Google Gemini, OpenRouter): used to draft and summarise (for example proposals, pre-meeting research, reports and outreach). We send only the least data needed for each task, and we never send personal or financial data to AI services in jurisdictions we do not trust for it. Your data is never used to train AI models. Where something you receive from us was written or drafted by AI — a report, an audit, a chat reply, a quote — it says so on the item itself, and a person is responsible for anything you act on.
- Beehiiv: newsletter platform (your name and email), only if you subscribed.
We do not use advertising trackers, and we do not sell your data to anyone. The full list of the outside services we use is kept written down, not hidden — see the sub-processor schedule in our Data Processing Agreement and Security Overview.
5a. Where your data is stored
DKT Digital is based in St Peter Port, Guernsey. Our automation platform and the database holding client data run on a dedicated server operated by Hetzner Online GmbH in Falkenstein, Germany (European Union), reachable only through Cloudflare. Nightly backups are replicated, encrypted, to Cloudflare R2 storage.
Some of the services listed above are based outside the UK and EEA — notably Stripe, Google, Calendly, Apollo, Telegram and the AI providers. Where personal data reaches them, the transfer relies on the provider's own approved transfer mechanism (such as standard contractual clauses or an adequacy decision). We do not send personal or financial data to AI providers in jurisdictions we do not trust for it. Our Security Overview lists every provider, what it does, and where it is.
6. Data retention
- Enquiry data: 12 months from last contact if no contract formed
- Client data: 6 years, running from the end of the year in which the relevant tax return is submitted (Guernsey record-keeping requirement under the Income Tax Law) — not from the end of the contract
- Newsletter data: until you unsubscribe
How that is actually done, stated plainly: these are the periods we work to. For a client we are still working with, deletion is carried out by hand — when you ask, or on offboarding — and no scheduled job removes your data.
One automatic deletion now runs, and only one. Once a client has left us, the customer data they brought us is deleted 90 days after they leave. We switched that on on 2 August 2026, having previously said here that it was built but switched off. Being exact about it matters more than the headline:
- It applies only to a client whose engagement has ended and whose leaving date we hold. If we have no recorded leaving date, nothing is ever purged — we do not treat an unknown date as a distant one.
- It covers the customer contacts and customer replies that a client brought into our system. It does not touch invoices, payment records or anything else we keep for legal or tax reasons, which are retained for the statutory period and are outside the purge entirely.
- Nothing is deleted outright. Rows are held recoverably for 30 days first, so a mistake can be undone, and only then permanently removed.
- It has not yet deleted anything, because no client has left. It is a rule now in force, not a description of something that has already happened.
We would rather set it out at this length than let “we have an automatic purge” stand for something broader than what actually runs. You can ask us to delete your data at any point inside these periods and we will, except where the law requires us to keep a record (principally invoices and payment records).
What deletion does not reach, said plainly. When you ask us to delete your data we erase it from the live system. Backups taken before you asked still contain it, and we do not edit them — they expire on their own. Measured on 5 September 2026: the off-site backup set holds the 14 most recent nightly archives, so a copy of your data sitting in a backup is gone within 14 days of your request; the copy held on the server itself is kept for 2 days. Two other places also age out on their own rather than on request: the automation engine keeps the details of a failed run for about 72 hours, and server and network logs are held for the provider’s own short window. We would rather give you a narrower promise we can keep than a total one we cannot.
7. Your rights (Guernsey DP Law 2017, Part 3 — and UK GDPR if you are in the UK)
We are based in Guernsey, so the Data Protection (Bailiwick of Guernsey) Law 2017 applies to us. Most of our clients and enquirers are in the UK, where the UK GDPR applies. The rights below exist under both regimes and we do not ask which one you are relying on before honouring them — if you are a UK data subject, treat the list as your UK GDPR rights under Articles 15–22.
- Access: request a copy of your data
- Rectification: correct inaccurate data
- Erasure: request deletion (subject to legal retention requirements)
- Restriction: limit how we process your data
- Objection: object to processing based on legitimate interest
- Portability: receive your data in a portable format
- Automated decisions: not to be subject to a decision based solely on automated processing that produces a legal or similarly significant effect. We do not make any such decision — where we use automated tools, a person decides and is responsible for anything you act on.
- Withdraw consent: where we rely on your consent (our newsletter, and the non-essential cookies in §8), withdraw it at any time without affecting anything done before you did
To exercise any right, email [email protected]. We respond within 30 days (one month under the UK GDPR, which is the shorter of the two, so that is the one we work to).
If you are unhappy with how we handle a request, you can complain — to us or to a regulator. See §10. You do not have to come to us first.
8. Cookies and browser storage
We do not run our own analytics, advertising cookies, Google Analytics, or Facebook Pixel. We use browser localStorage (not a traditional cookie) to remember the choice you make below — that is strictly necessary to honour your decision, so it is not something you can be asked to consent to.
Nothing non-essential loads until you accept it. These tools stay switched off — not merely unused, but never requested — unless you press Accept on the banner:
- Crisp (live chat): sets a session cookie and local storage so your chat stays connected across pages.
- Calendly (appointment booking): sets cookies to run the booking widget. If you decline, the page shows you a direct link and our email address instead, so you can still book.
- Google Fonts: may log your IP address when web fonts load. Declining costs you nothing but a slightly different typeface.
One thing stays on either way: Cloudflare Turnstile, the bot protection on our contact and onboarding forms. It sets a short-lived challenge token and processes your IP address and browser signals to check you are human. We treat it as strictly necessary because it exists to protect a form you have chosen to use — switching it off would either leave the form open to abuse or make it unusable. It does not track you across sites, and we store nothing from it.
You can change your mind at any time: . Declining, or simply never answering, has the same effect — the tools do not load.
9. Security
All data is transmitted over encrypted HTTPS. Our automation platform is self-hosted and reachable only through Cloudflare (which provides TLS, access control, rate-limiting and bot protection); administrative access is not publicly exposed. Sensitive credentials are stored encrypted and never in source files.
10. Complaints
To us: email [email protected] with "COMPLAINT" in the subject. We acknowledge within one working day, tell you who is handling it, and respond in writing within 10 working days — or tell you why we need longer and give you a date. There is one person here, so that person is Daniel Thomas.
To a regulator — you can do this at any time and do not have to come to us first:
- Office of the Data Protection Authority (ODPA), the independent supervisory authority for the Bailiwick of Guernsey, where we are established: Block A, Lefebvre Court, Lefebvre Street, St Peter Port, GY1 2JP · odpa.gg · [email protected] · +44 (0)1481 742074.
- Information Commissioner's Office (ICO) if you are in the UK: ico.org.uk · 0303 123 1113.
11. Changes
We may update this policy. Material changes will be communicated by email to active clients. Last updated: August 2026.