Last updated: 24 September 2026
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies to websites, brands and services operated by The Sortino Group Ltd, including The Sortino Group and Sortino Create, where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to The Sortino Group Ltd.
2. The personal data that we collect
2.1 In this Section 2 we have set out the categories of personal data that we process.
2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, postal address and any other contact details you choose to provide when you contact us using our website contact form. The source of the contact data is you and/or your employer.
2.3 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the content of your message and metadata associated with the communication, such as the date and time it was sent. Our website will generate the metadata associated with communications made using the website contact form.
2.4 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website use. The source of the usage data is our website analytics system.
2.5 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Website operation and enquiries – We may process your personal data for the purposes of operating our website, receiving and responding to enquiries submitted through our website contact form, and managing communications with you. The personal data processed for this purpose may include contact data and communication data. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and responding to enquiries from website users.
3.3 Website analytics – We may process usage data for the purposes of analysing the use of our website and improving its performance, usability and content. This processing is carried out using website analytics tools. The legal basis for this processing is your consent, given through our cookie consent mechanism.
3.4 Security and technical administration – We may process personal data where necessary for the purposes of maintaining the security of our website and information systems, preventing unauthorised access, and detecting or preventing malicious activity. The legal basis for this processing is our legitimate interests, namely protecting our website, systems and business.
3.5 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.6 Legal compliance and claims – We may process personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or for the establishment, exercise or defence of legal claims. The legal basis for this processing is compliance with legal obligations and our legitimate interests in protecting and asserting our legal rights.
3.7 Email newsletters and marketing communications – We may process your contact data for the purposes of sending email newsletters, updates, insights and other marketing communications that you have requested or agreed to receive. The personal data processed for this purpose may include your name, email address and preferences relating to communications. The legal basis for this processing is your consent. You may withdraw your consent and unsubscribe from marketing communications at any time by using the unsubscribe link included in our emails or by contacting us.
4. Providing your personal data to others
4.1 We may disclose your personal data to third parties where this is necessary for the purposes set out in this policy, and on the legal bases identified in Section 3.
4.2 Our website is hosted by third‑party service providers who may process personal data on our behalf in order to provide hosting, maintenance and technical support services. Personal data processed for this purpose may include contact data, communication data and usage data.
4.3 We use third‑party analytics services to analyse the use of our website. These services process usage data in order to help us understand how visitors use our website and to improve its performance and usability. This processing is carried out subject to your consent, given through our cookie consent mechanism.
4.4 We may disclose personal data to third-party email marketing service providers for the purpose of managing newsletter subscriptions and distributing email communications. Personal data processed for this purpose may include your name, company name, email address and communication preferences.
4.5 We may disclose personal data to our professional advisers, including lawyers, accountants and insurers, insofar as reasonably necessary for obtaining professional advice or complying with legal obligations. We may also disclose personal data where such disclosure is required by law, or for the establishment, exercise or defence of legal claims.
5. International transfers of your personal data
5.1 In this Section 5, we explain when personal data may be transferred, stored or processed in countries other than the country in which it was collected, including countries outside the United Kingdom.
5.2 Some of the third parties with whom we share personal data, including providers of website analytics services, may process personal data outside the United Kingdom.
5.3 In particular, we use Google Analytics to analyse the use of our website. Data collected through Google Analytics may be transferred to and processed in countries outside the United Kingdom, including the United States. We use EmailOctopus to manage newsletter subscriptions and distribute email communications. Where you subscribe to our newsletter, your personal data may be processed by EmailOctopus on our behalf in accordance with its privacy and security practices.
5.4 Where personal data is transferred to a country outside the United Kingdom, we ensure that appropriate safeguards are in place to protect that data, in accordance with UK data protection law. These safeguards may include the use of standard contractual clauses approved for use under UK data protection law, or reliance on adequacy regulations where applicable.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we retain personal data only for as long as is necessary for the purposes for which it is processed.
6.2 We will not retain your personal data for longer than is necessary to achieve the purposes set out in this policy.
6.3 Contact and communication data
Contact data and communication data submitted through our website contact form will be retained for as long as is necessary to respond to your enquiry and for our internal business records. Such data is typically retained for a limited period following the conclusion of the relevant communication, unless a longer retention period is required or permitted by law.
6.4 Usage data
Usage data collected through website analytics services is retained for the period specified by the relevant analytics provider, subject to our configuration of those services and applicable data protection law.
6.5 Newsletter subscription data
Personal data collected for email newsletter subscriptions will be retained for as long as you remain subscribed to our communications and for a reasonable period thereafter to maintain suppression records and demonstrate compliance with applicable legal requirements.
6.6 In some cases, it is not possible to specify in advance the exact period for which personal data will be retained. In such cases, we determine retention periods based on factors such as the nature and sensitivity of the personal data, the purposes for which it is processed, and any applicable legal or regulatory requirements.
6.7 Notwithstanding the other provisions of this Section 6, we may retain personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or for the establishment, exercise or defence of legal claims.
7. Security of personal data
7.1 We take appropriate technical and organisational measures to secure your personal data and to prevent unauthorised access to, or the accidental loss, misuse or alteration of, personal data.
7.2 Personal data is processed using secure information systems and infrastructure. Access to personal data is restricted to those persons who require access for the purposes set out in this policy.
7.3 Data transmitted between your web browser and our website is protected using encryption technology where appropriate.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and while we take reasonable steps to protect your personal data, we cannot guarantee the security of data transmitted over the internet.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under United Kingdom data protection law. Some of these rights are complex and may be subject to limitations and exceptions. Further information can be found in guidance published by the UK Information Commissioner’s Office (ICO). Depending on where you are located, local laws may provide you with additional privacy rights.
8.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8.4 Complaints and concerns
We are committed to resolving concerns relating to the processing of personal data fairly and promptly. If you have any complaint or concern regarding our handling of your personal data, please contact us using the details set out in this policy. We will investigate the matter and respond in accordance with applicable data protection legislation. If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
8.5 International Visitors
Our website is operated from the United Kingdom. By using the website, you acknowledge that your personal data may be processed in the United Kingdom and in other countries where our service providers operate. We will take appropriate steps to protect personal data in accordance with applicable data protection laws.
9. Third party websites
9.1 Our website may contain links to websites, services and resources operated by third parties.
9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Personal data of children
10.1 Our website and services are targeted at persons over the age of 18.
10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
11. Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. About cookies
12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page.
12.2 Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie will be stored by a web browser and will remain valid until its expiry date, unless deleted by the user before that date. A session cookie will expire at the end of the user session, when the browser is closed.
12.3 Cookies do not typically contain information that directly identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
13. Cookies that we use
13.1 We use cookies on our website for the following purposes:
(a) essential cookies – cookies that are necessary for the operation of our website and to enable basic functionality; and
(b) analytics cookies – cookies that help us analyse how visitors use our website so that we can improve its performance and usability.
14. Cookies used by our service providers
14.1 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered is used to create reports about the use of our website. The cookies used by Google Analytics include _ga and _ga_*. Data collected using these cookies may be processed in countries outside the United Kingdom and outside the country in which the user is located.
14.2 You can find information about Google’s use of information by visiting https://policies.google.com/technologies/partner-sites. You can review Google’s privacy policy at https://policies.google.com/privacy.
14.3 Analytics cookies will only be set if you give your consent through our cookie consent mechanism.
15. Managing cookies
15.1 You can control and delete cookies through your web browser settings. Most web browsers allow you to refuse cookies, delete existing cookies and configure cookie preferences. You can also manage your cookie preferences on our website using the cookie settings available on the site. Please note that disabling certain cookies may affect the functionality of the website.
16. Cookie preferences
16.1 You can manage your preferences relating to the use of cookies on our website at any time by accessing the cookie preferences settings available on our website.
16.2 You can also manage cookies through your web browser settings, as explained in Section 15.
17. Amendments
17.1 We may update this policy from time to time by publishing a new version on our website.
17.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
18. Our details
18.1 This website is owned and operated by The Sortino Group Ltd.
18.2 We are registered in England and Wales under registration number 10609813, and our registered office is at 1-5 Clerkenwell Road, 2nd Floor, London, EC1M 5PA.
18.3 We are registered as a data controller with the UK Information Commissioner’s Office. Our data protection registration number is ZA269283.
18.4 You can contact us by post, to the postal address given above, or by using our website contact form.