We last updated this notice on 26 August 2026.
This notice explains what personal information Fresh Digital Holdings Ltd collects about you, why we hold it, who sees it and what you can ask us to do about it. We have written it to describe what our business and our website actually do, rather than to cover every situation we can imagine, so it is shorter and plainer than most notices of this kind. If anything in it is unclear, ask us and we will explain it properly.
Who we are
We are Fresh Digital Holdings Ltd, a company registered in England and Wales under company number 12708654, with its registered office at 34 Altrincham Rd, Wilmslow, Cheshire SK9 5ND. In this notice we call ourselves “we”, “us” and “our”.
We are the data controller for the personal information described here. That means we decide what is collected and why, and we are the ones answerable for it.
How to contact us
Any question about this notice, or any request about your own information, can come to us in whichever way suits you:
- by email at hello@freshdigital.agency
- by telephone on 01625 532 125
- by post at 34 Altrincham Rd, Wilmslow, Cheshire SK9 5ND
We are not required to appoint a data protection officer and we have not appointed one. Enquiries go to the address above and are handled by a director.
The information we collect
When you contact us
If you complete the contact form on this website, we receive the name, email address, telephone number and message you provide. Our website also records the internet protocol (IP) address and browser identification string of the device used to send it, and stores that alongside the message. We keep those two technical details so that we can investigate abuse of the form, and for no other purpose.
If you email, telephone or write to us instead, we hold whatever you choose to tell us, together with our record of the exchange.
When you use this website
Our web server keeps standard access logs. Those logs contain IP addresses, the pages requested, the time of the request and the browser identification string. They are produced automatically by the hosting software and are used for security and fault finding.
We also run our own visitor counter on our own server. It records the page visited, the page you arrived from, the browser identification string, which kind of interaction it was (a page view, or a click on something like a call to action or a telephone number), and a one way cryptographic hash of the IP address rather than the address itself. We cannot reverse that hash back into an IP address, but we treat it as personal information anyway, because it can still distinguish one visitor from another. The counter stores nothing at all on your device and sends nothing to anyone else. It runs whether or not you accept analytics, because it does not read or write anything on your device and does not follow you to other websites.
Google Analytics
Our website loads Google Analytics 4 (measurement identifier G-9R6KJNHTH9) from googletagmanager.com. The script is requested on every page, before you have made any choice about analytics, and that request on its own tells Google your IP address and which page you are on. Google is the only third party our website contacts.
What the script is then allowed to do depends on your choice. Until you accept analytics we hold it in a denied state, using Google Consent Mode, which means it sets no cookies on your device and Google receives only basic cookieless signals rather than a record of your visit. If you accept, Google Analytics sets the cookies listed in our cookie policy, records your visit properly, and acts as a separate controller of that information under Google’s own terms. If you decline, it stays in the denied state for as long as you leave that choice in place.
We rely on your consent for the analytics itself. For loading the script before you have chosen, in its restricted state, we rely on our legitimate interests in running a website we can measure. Our cookie policy sets out exactly what is stored and when.
Your choice itself is remembered in your browser’s local storage under the name fd_consent_v1. That record stays on your device, is not a cookie, and is never sent to us.
When we work together
If you become a client, or work for one, we hold business contact details, correspondence, billing contacts and the records of the work itself. Where you ask us to work on a system you control, such as a website, an advertising account or an analytics property, we hold the access we need to do that work and nothing further.
We do not buy personal information from data brokers or list sellers, we do not scrape it, and we have never sold or rented personal information to anyone. We do not use your information to make automated decisions that produce legal effects or similarly significant effects for you, and we do not profile you.
Information we get from somewhere other than you
Before we approach a business we think we can help, we sometimes research it using sources that are already public, such as the company’s own website, its Companies House record and its LinkedIn presence. That research can include the name and job title of the person we would be writing to, and their work contact details. We rely on our legitimate interests in identifying businesses that may want our services, and we hold no more than we need to make the approach.
If we contact you this way, we will tell you where we got your details when we first write, and you can tell us to stop and delete them, which we will do without argument. We do not send marketing by email or text message to individuals who are not acting for a business.
Why we use your information, and our lawful basis
Data protection law requires us to have a lawful basis for each use. Ours are set out below.
| What we use it for | Our lawful basis |
|---|---|
| Replying to an enquiry and discussing whether we can help | Our legitimate interests, namely responding to people who approach us about our services. Where the discussion is about entering into a contract, we also rely on taking steps at your request before entering into that contract. |
| Carrying out the work we have agreed, and managing our contract with you | Performance of our contract with you, or our legitimate interests in managing the relationship where the contract is with the organisation you work for rather than with you personally. |
| Keeping our accounts and business records, and meeting tax and company law duties | Compliance with our legal obligations. |
| Keeping this website available and secure, and investigating misuse of our contact form | Our legitimate interests in protecting our systems and the people who use them. |
| Counting visits to our own website using our own first party counter | Our legitimate interests in understanding how our website is used, in a way that does not track you across other websites. |
| Google Analytics, and any other non-essential technology described in our cookie policy | Your consent, which you may withdraw at any time. Loading the script before you choose, in the restricted state described above, relies on our legitimate interests in running a website we can measure. |
| Sending marketing emails about our services | Your consent, or our legitimate interests where you are an existing client and the message concerns similar services. Every message carries an unsubscribe link. |
| Establishing, exercising or defending legal claims | Our legitimate interests in protecting our position, and compliance with our legal obligations. |
Where we rely on legitimate interests, we have considered whether our interest is overridden by your interests and rights, and we have concluded that it is not. You can ask us to explain that assessment, and you can object to the use, as described under your rights below.
You are not obliged by law or by contract to give us any personal information through this website. If you choose not to complete the contact form, we simply will not be able to reply to an enquiry we have not received.
Who we share it with
We keep the number of people and organisations who see your information as small as we can. Your information may be handled by:
- the people at Fresh Digital Holdings Ltd who need it to do their work;
- our hosting provider, which stores this website and the enquiries sent through it;
- Microsoft, which provides our email through Microsoft 365;
- Google, if you have accepted analytics, as described above;
- our accountants, and our professional advisers where we need advice;
- a purchaser, if we ever sell or reorganise the business; and
- a court, regulator or public authority where the law requires us to disclose information.
The suppliers in that list act on our instructions as our processors, apart from Google Analytics, where Google acts as a separate controller in its own right. We put a written contract in place with our processors requiring them to keep your information secure and to use it only as we direct.
Sending information outside the United Kingdom
Some of our suppliers, including Microsoft and Google, are able to process information outside the United Kingdom. Where information is transferred out of the United Kingdom, we rely on one of the protections that data protection law provides, which will be either:
- a decision by the UK government that the destination country provides an adequate level of protection; or
- a contract on approved terms, being the International Data Transfer Agreement or the UK Addendum to the European Commission’s standard contractual clauses, along with any additional safeguards the transfer requires; or
- for transfers to the United States, the UK Extension to the EU to US Data Privacy Framework, where the receiving organisation is certified under it.
You can ask us for a copy of the safeguards that apply to a particular transfer.
How long we keep it
| What | How long we keep it |
|---|---|
| Enquiries that do not become work | Two years from our last contact with you, so that we recognise you if you come back to us. |
| Client records and correspondence | Six years from the end of our relationship, which is the period in which a claim under the contract could still be brought. |
| Accounting and tax records | Six years from the end of the accounting period, as company and tax law requires. |
| Website server access logs | Up to twelve months. |
| Our own visit counter records | Twenty six months. |
| Google Analytics data, if you accepted analytics | Held by Google, for the period set on our Analytics property and under Google’s own terms. |
| Marketing consents and unsubscribe records | For as long as we send marketing, and then as long as we need to show that we honoured your choice. |
At the end of these periods we delete the information, or keep it only in a form that no longer identifies you. Where we have to keep something longer because of a legal claim or a legal duty, we keep only what that requires.
How we keep it safe
This website is served only over an encrypted connection. Access to our systems is restricted to the people who need it and is protected by multi-factor authentication. Client credentials are held in controlled storage rather than in email or in chat. We record IP addresses in a hashed form wherever we reasonably can, so that our own records reveal less about you.
No system is perfect. If a breach of security affects your personal information and is likely to result in a risk to your rights and freedoms, we will report it to the Information Commissioner’s Office within seventy two hours of becoming aware of it, and we will tell you directly where the risk to you is high.
Your rights
Under UK data protection law you have the following rights, free of charge:
- To be told how we use your personal information, which is what this notice is for.
- To see it. You can ask for a copy of the personal information we hold about you.
- To correct it. If something we hold is wrong or incomplete, you can ask us to put it right.
- To have it deleted. You can ask us to erase your personal information where we no longer have a good reason to keep it.
- To restrict how we use it while a question about its accuracy or our use of it is resolved.
- To object. You can object to any use we base on our legitimate interests. If you object to marketing, we will stop, without exception and without asking why.
- To take it with you. Where we rely on your consent or on a contract, and handle the information by automated means, you can ask for it in a portable format or ask us to send it to someone else.
- To withdraw consent at any time, where our use is based on consent. Withdrawing it does not affect anything we did lawfully beforehand. You can change your analytics choice at any time using the cookie settings button in the bottom left corner of any page.
Write to us at hello@freshdigital.agency to use any of these rights. We will respond within one month. If your request is unusually complex we may extend that by up to two further months, and we will tell you if that happens and why. We may need to confirm who you are before we act, so that we do not disclose your information to somebody else.
Complaints
If you are unhappy with how we have handled your personal information, please tell us first, because we would rather put it right. You also have the right to complain to the Information Commissioner’s Office, which regulates data protection in the United Kingdom, at any time.
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Helpline 0303 123 1113. Website ico.org.uk.
Changes to this notice
When we change how we use personal information, we update this notice and change the date at the top. Where a change matters to you, we will bring it to your attention rather than rely on you noticing it.