1. Data Controller Identification
This Privacy Policy details how Britain Portcullis ("we", "us", or "our") collects, manages, and safeguards personal data obtained through your interactions with britainportcullis.com.
For the purposes of the UK GDPR and the Data Protection Act 2018, the designated Data Controller is:
Britain Portcullis Governance Office
The Heron, 5 Moor Lane
London, EC2Y 9AP
United Kingdom
Official Telephone: +44 7724 819305
Designated Privacy Desk: contact@britainportcullis.com
2. Data We Collect & Collection Methods
We follow a strict policy of data minimization. The categories of data we may collect include:
- Direct Inquiries & Dispatches: When you submit a transmission via our London Bureau contact desk, we collect your name, email address, topic selection, and the contents of your message.
- Editorial Subscriptions: When subscribing to our weekly technical dispatch, we record your email address.
- Technical & Telemetry Logs: Our web servers automatically log anonymized connection telemetry (IP address, operating system, browser user-agent, requested URL, and timestamp) for cybersecurity auditing, ModSecurity WAF inspection, and denial-of-service mitigation.
- Client Storage Data: We utilize browser LocalStorage solely to record your chosen cookie preferences and search filtering states locally on your device.
3. Lawful Bases for Processing
Under Article 6 of the UK GDPR, we process personal information under the following lawful grounds:
- Legitimate Interests (Art. 6(1)(f)): To maintain web infrastructure security, prevent cyber threats, audit server performance, and maintain the integrity of our benchmarking index.
- Consent (Art. 6(1)(a)): For processing non-essential analytical cookies (managed via Google Consent Mode v2) and voluntary newsletter communications. You may withdraw consent at any time.
- Contractual / Pre-Contractual Steps (Art. 6(1)(b)): To respond to developer benchmark inquiries and studio submissions sent to our London Bureau.
4. Data Sharing & Third-Party Disclosure
We do not sell, rent, monetize, or trade personal data to marketing brokers or commercial advertising networks under any circumstance. Data may only be shared with:
- Authorized infrastructure providers (hosting facilities in the United Kingdom conforming to ISO 27001 standards).
- Statutory law enforcement or judicial bodies if strictly required by the laws of England and Wales.
5. Data Retention Schedules
Server log entries are purged automatically on a rolling 30-day schedule. Contact transmissions received by our London Bureau are retained for a maximum of 12 months to maintain record accuracy before permanent cryptographic deletion.
6. Your Statutory Data Protection Rights
Under UK data protection legislation, you are entitled to exercise the following rights regarding your personal information:
- Right of Access: Request a confirmation and copy of any personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete personal records.
- Right to Erasure: Request the deletion of your personal records where there is no overriding legal reason for retention.
- Right to Restriction of Processing: Request suspension of data processing under specific statutory circumstances.
- Right to Object: Object to processing based on legitimate interests.
- Right to Lodge a Complaint: You have the right to lodge a formal complaint with the UK supervisory authority: Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (ico.org.uk).
7. Data Protection Office Contact
To exercise any of your statutory rights or submit privacy-related questions, please address our compliance officer:
Data Protection Officer
Britain Portcullis
The Heron, 5 Moor Lane, London, EC2Y 9AP, United Kingdom
Email: contact@britainportcullis.com • Phone: +44 7724 819305