1. Who is responsible for your information?
The controller responsible for personal information processed through this website and in connection with JTWS services is JTWS Web Solutions (“JTWS”, “we”, “us” or “our”).
2. Information we collect
Depending on how you interact with us, we may collect:
- your name, email address, company or organisation and any other contact details you provide;
- information contained in enquiries, project briefs, correspondence, contracts and support requests;
- commercial and transaction information relating to quotations, invoices and services;
- technical information such as IP address, browser type, device information, request logs and security events;
- website usage information where analytics or similar technologies are enabled; and
- any other information you choose to provide.
Please do not include sensitive personal information in the contact form unless it is genuinely necessary. If a project requires such information, suitable safeguards and contractual arrangements should be agreed first.
3. How and why we use personal information
| Purpose | Typical lawful basis |
|---|---|
| Responding to enquiries and discussing potential work | Legitimate interests; or steps requested before entering into a contract |
| Preparing quotations, contracts and project plans | Steps requested before entering into a contract; performance of a contract |
| Providing, administering and supporting services | Performance of a contract; legitimate interests |
| Managing invoices, tax and accounting records | Legal obligation; legitimate interests |
| Protecting the website, systems and communications from misuse, fraud and spam | Legitimate interests |
| Improving website performance and understanding usage | Consent where non-essential cookies or tracking technologies are used; otherwise legitimate interests where lawful |
| Establishing, exercising or defending legal claims | Legitimate interests; legal obligation |
Where we rely on legitimate interests, those interests include operating and protecting the business, responding to genuine enquiries, improving services and maintaining appropriate business records. We consider whether those interests are overridden by your rights and interests.
4. Contact-form screening and automation
Contact-form submissions may be processed through automated workflow services to validate the submission, detect abuse or spam, route the enquiry and send notifications.
If automated or AI-assisted classification is enabled, it will be used only to assist with identifying likely spam or categorising an enquiry. It will not be used to make a decision that produces legal or similarly significant effects on you. A genuine enquiry may be reviewed manually.
Do not state that a particular provider is used unless it has actually been configured. Where services such as n8n, an email provider or an AI model provider process form data on our behalf, they will be treated as processors or independent controllers as applicable and assessed before use.
5. Cookies and similar technologies
Strictly necessary technologies may be used to operate and secure the website. Non-essential analytics, advertising or similar technologies will not be placed or accessed before valid consent is obtained, where consent is required.
If the website does not use non-essential cookies or tracking technologies, no cookie banner is required merely for appearance. If analytics or other non-essential technologies are added, the website should provide clear information and a genuine accept/reject choice.
6. Who we share information with
We do not sell personal information. We may disclose it where reasonably necessary to:
- hosting, infrastructure, email, workflow, security, analytics, accounting and professional-service providers;
- subcontractors or collaborators engaged for a project, where appropriate safeguards are in place;
- banks, payment providers, insurers, accountants, legal advisers and public authorities; and
- a purchaser or successor in connection with a genuine sale, transfer or reorganisation of the business.
Providers receive only the information reasonably necessary for their role and are required to protect it through contractual, technical or legal safeguards where applicable.
7. International transfers
Some service providers may process information outside the United Kingdom. Where a restricted transfer occurs, we will use an applicable UK adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful transfer mechanism. Additional technical or organisational safeguards may also be used where appropriate.
8. How long we keep information
We retain personal information only for as long as reasonably necessary for the relevant purpose, including legal, accounting and dispute-resolution requirements. Our normal retention approach is:
| Information | Indicative retention |
|---|---|
| Unsuccessful or inactive enquiries | Up to 24 months after the last meaningful contact |
| Spam, abuse-prevention and security logs | Normally up to 12 months, unless required for an investigation |
| Client project and contractual records | Normally 6 years after the end of the client relationship |
| Invoices, tax and accounting records | As required by applicable tax and accounting law, commonly at least 6 years |
| Analytics information | According to the configured analytics retention period and no longer than necessary |
Specific records may be kept for longer where reasonably necessary for legal claims, regulatory requirements, fraud prevention or an ongoing dispute.
9. Security
We use proportionate technical and organisational measures intended to protect personal information, including access controls, secure communications, software maintenance, backups and appropriate provider due diligence. No internet service can guarantee absolute security.
10. Your data-protection rights
Subject to the applicable conditions and exemptions, you may have rights to:
- be informed about how your information is used;
- request access to your personal information;
- request correction of inaccurate or incomplete information;
- request erasure or restriction of processing;
- object to processing based on legitimate interests;
- receive certain information in a portable format;
- withdraw consent at any time where processing relies on consent; and
- complain to a supervisory authority.
To exercise a right, contact us using the details in section 1. We may need to verify your identity. There is normally no fee, although a reasonable fee may be charged or a request refused where the law permits this.
11. Complaints
Please contact us first so that we can try to resolve your concern. You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection. Information about making a complaint is available from the ICO website.
12. Third-party websites
This website may link to third-party websites. Their privacy practices are governed by their own notices, and JTWS is not responsible for their content or handling of personal information.
13. Changes to this policy
We may update this policy to reflect changes in law, technology, providers or business practices. The current version will be published on this page with a revised “last updated” date. Material changes may also be communicated by another appropriate method.