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Privacy Policy

​Effective Date: 17 August 2026

Last Updated: August 2026
 

This Privacy Policy explains how Agency Adventure (a trading name of Be Digital Ltd, referred to as "we", "us", or "our") collects, uses, stores, and protects personal data when you interact with our website, use our commercial consultancy services, or engage with us.
 

We operate as a Data Controller under UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR), and the Data Use and Access Act (DUAA) 2025.
 

1. Information We Collect

We collect and process different types of personal information depending on how you interact with us:

  • Contact & Identity Data: Full name, business email address, phone number, job title, and company name.

  • Commercial & Contractual Data: Billing details, contract information, transaction history, and communications relating to commercial engagements or consulting services.

  • Marketing & Communications Data: Your preferences for receiving marketing communications and event updates.

  • Technical & Usage Data: IP address, browser type, operating system, and website usage details collected via essential and analytics cookies.
     

2. Legal Basis for Processing Personal Data

Under UK GDPR and the DUAA 2025, we process your personal data under the following legal bases:

  • Contractual Necessity: To perform services requested under a contract or to take pre-contractual steps (e.g., providing quotes or proposals).

  • Standard Legitimate Interests: To manage and grow our commercial business, secure our systems and network, manage client relationships, and send B2B commercial communications. We conduct Legitimate Interests Assessments to ensure our commercial priorities do not override your individual privacy rights.

  • Recognised Legitimate Interests: Where processing is required for specific statutory public interest activities permitted under the DUAA 2025 without a separate balancing test (e.g., crime prevention, public safety, or emergency response).

  • Consent: Where you have explicitly opted in (e.g., subscribing to newsletters or opting into optional tracking). You can withdraw consent at any time.

  • Legal Obligation: To comply with UK statutory obligations, such as tax and financial reporting.


3. Cookies and Website Tracking

In accordance with PECR and the updated DUAA 2025 provisions:

  • Essential Cookies: Necessary for basic website functionality, security, and performance; these do not require prior consent.

  • Analytics & Performance Cookies: We process low-risk, first-party website analytics solely to measure site performance and improve user experience. These tools do not profile you, enable cross-site tracking, or share data with third parties for commercial advertising. You can opt out at any time via our Cookie Settings banner.


4. How Long We Keep Your Data

We retain personal data only as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements:

  • Client & Commercial Records: Retained for 6 years following the end of the commercial relationship (in line with UK statutory limitation periods).

  • Marketing Contacts: Retained until you unsubscribe or request erasure.

  • Website Analytics Data: Retained for up to 14 months.


5. International Data Transfers

If personal data is transferred outside the United Kingdom, we ensure equivalent protection by utilizing UK Government adequacy decisions or standard legal safeguards under the DUAA Data Protection Test framework, such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses.


6. Your Statutory Data Protection Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

  • Right of Access: Request copies of the personal data we hold about you, subject to reasonable and proportionate searches.

  • Right to Rectification: Request correction of inaccurate or incomplete data.

  • Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data where there is no legal requirement for us to keep it.

  • Right to Restrict or Object: Object to or restrict processing based on legitimate interests or direct marketing.

  • Right to Data Portability: Request transfer of your data to another controller in a structured, commonly used format.

  • Automated Decision-Making Safeguards: We do not engage in solely automated decision-making that produces legal or significant effects without human oversight. Where automated systems are used, you have the right to request human intervention, express your view, or contest decisions.


7. Statutory Right to Complain (DUAA 2025 Procedure)

In accordance with Section 164A of the Data Protection Act 2018 (introduced by the DUAA 2025), you have the statutory right to lodge a data protection complaint directly with us.

How to submit a complaint:

  1. Via Email: Email us directly at chris@bedigital.co or enquiries@bedigital.co with the subject line "Formal Data Protection Complaint".

  2. Written Mail: Send written complaints to our registered office address listed below.

Our Statutory Commitment:

  • Acknowledgement: We will acknowledge receipt of your complaint within 30 calendar days.

  • Investigation & Response: We will conduct necessary enquiries, keep you updated without undue delay, and formally inform you of the outcome and any remedial actions taken.

Escalation to the ICO:

If you remain unsatisfied with our response or how your complaint was handled, you have the right to lodge a complaint with the UK supervisory authority:

  • Information Commissioner’s Office (ICO)

    Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
    Website: https://ico.org.uk | Helpline: 0303 123 1113


8. Contact Details

If you have questions regarding this Privacy Policy or wish to exercise your rights, please contact our Data Protection lead:

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