Privacy Policy

Last updated: 23 July 2026. This policy applies to the website vitalelbowstrain.world operated by Brighton Daily Ltd.

1. Who We Are (Data Controller)

The data controller for personal data collected through this website is:

Brighton Daily Ltd
14 Gardner Street, Brighton, BN1 1UP, United Kingdom
Company No. 15847213 · VAT GB 398 7214 01
Email: info@vitalelbowstrain.world
Tel: +44 20 7946 0321

We are registered with the Information Commissioner's Office (ICO) as a data controller. You have the right to lodge a complaint with the ICO at any time: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; telephone 0303 123 1113; website ico.org.uk.

2. Legal Framework

This Privacy Policy is governed by:

  • The UK General Data Protection Regulation (UK GDPR) as retained in domestic law by the European Union (Withdrawal) Act 2018
  • The Data Protection Act 2018
  • The Privacy and Electronic Communications Regulations 2003 (PECR) as amended

3. What Personal Data We Collect

We collect the following categories of personal data:

Category Examples Source
Identity data Full name Order form, contact form
Contact data Phone number, email address, postal address Order form, contact form
Transaction data Product ordered, quantity, price, UTM parameters, order reference Order form, URL parameters
Technical data IP address, browser type, device type, pages visited, time on site Cookies, analytics (with consent)
Communications data Messages sent via our contact form Contact form

We do not collect special category data (health, biometric, etc.) through this website. We do not knowingly collect data from persons under 18 years of age.

4. How and Why We Use Your Personal Data

Purpose Lawful Basis (UK GDPR Art. 6)
Processing and fulfilling your order for Wellaray Coffee Art. 6(1)(b) - performance of a contract
Responding to contact form enquiries Art. 6(1)(b) - performance of a contract / Art. 6(1)(f) - legitimate interests
Processing returns and refunds Art. 6(1)(b) - performance of a contract; Art. 6(1)(c) - legal obligation
Website analytics (understanding visitor behaviour) Art. 6(1)(a) - consent (via cookie banner)
Advertising and remarketing Art. 6(1)(a) - consent (via cookie banner)
Compliance with legal obligations (tax, fraud prevention) Art. 6(1)(c) - legal obligation

5. Cookies and Tracking Technologies

We use cookies and similar technologies on this website. Analytics and advertising cookies are deployed only with your explicit consent via our cookie consent banner (Google Consent Mode v2). Essential and functional cookies are used without consent where strictly necessary for the site to operate. For full details see our Cookie Policy.

We use Google Analytics 4 and Google Ads (including Google Consent Mode v2). When you decline cookies, ad_storage, ad_user_data, ad_personalization and analytics_storage are set to denied and no personal data is sent to Google for these purposes.

6. Data Sharing and Third-Party Processors

We do not sell your personal data. We share your data only with the following categories of third parties where necessary:

  • Order fulfilment and courier services - to deliver your order (name, address, phone number)
  • Google LLC - analytics and advertising (technical data, with consent; Google Consent Mode v2 applies)
  • Hosting and infrastructure providers - to operate this website
  • Professional advisors - legal, accounting, and audit purposes where required by law
  • Law enforcement and regulatory authorities - where required by law or court order

Where third-party processors are based outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR Chapter V (e.g. Standard Contractual Clauses or adequacy decisions).

7. Data Retention

  • Order records: retained for 7 years from the date of transaction to comply with HMRC record-keeping requirements
  • Contact form messages: retained for 12 months from the date of receipt, then deleted unless ongoing correspondence requires longer retention
  • Analytics data: retained for up to 26 months in Google Analytics (default retention period)
  • Cookie consent records: stored in browser localStorage; cleared when the user clears browser data

8. Your Rights Under UK GDPR

You have the following rights in relation to your personal data:

  • Right of access - to obtain a copy of your personal data (Subject Access Request)
  • Right to rectification - to correct inaccurate or incomplete data
  • Right to erasure - to request deletion of your data in certain circumstances
  • Right to restriction - to restrict processing in certain circumstances
  • Right to data portability - to receive your data in a structured, machine-readable format
  • Right to object - to object to processing based on legitimate interests or for direct marketing
  • Rights relating to automated decision-making - we do not make solely automated decisions with legal or significant effects
  • Right to withdraw consent - where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, contact us at info@vitalelbowstrain.world. We will respond within one calendar month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at any time - ico.org.uk or 0303 123 1113.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. This website is served over HTTPS (TLS encryption). Access to order data is restricted to authorised personnel on a need-to-know basis.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, notify affected individuals without undue delay.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page will reflect any changes. Material changes will be notified via a notice on this website. Continued use of our website after changes constitutes acceptance of the updated policy.

11. Contact the Data Controller

For any privacy-related query or to exercise your rights, contact us at:

Brighton Daily Ltd · 14 Gardner Street, Brighton, BN1 1UP, UK
Email: info@vitalelbowstrain.world · Tel: +44 20 7946 0321