Privacy Policy

133 Strategy Co. Privacy Policy (Effective: N/A)

1. Introduction

133 Strategy Co. (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how
we collect, use, and safeguard information when you interact with us through our website, email, or services.

2. Data Controller

The data controller is 133 Strategy Co.

• Contact email: Enquiries@133strategy.com

• Contact phone: +447771203210

• Postal address: available on request.

• No Data Protection Officer has been appointed.

3. What Data We Collect

We may collect and process the following types of personal data:

• Website forms: name, email, phone, company, project brief, budget, message.

• Uploads: files submitted through enquiry forms.

• Bookings: information provided in booking requests.

• Client projects: contact information, operations documents, customer lists, internal SOPs, branding assets, performance data, and other business-related information needed to deliver services.

We do not accept payments directly through our website. Invoices are issued separately, and payment may be made by bank transfer or PayPal.

4. Special Category Data

We do not intentionally collect or process special category data (such as health, religion, or political opinions). If such data is provided, it will be deleted unless its processing is strictly necessary, and a lawful basis applies.

5. How We Use Data (Lawful Bases)

We rely on the following lawful bases under UK GDPR:

• Contract: to respond to enquiries, provide quotes, deliver services, and issue invoices.

• Legitimate interests: to manage website functionality, respond to non-contract enquiries, and maintain business operations.

• Consent: required for any future email marketing communications or non-essential cookies (not in use at launch).

6. Cookies and Tracking

We do not use non-essential cookies or tracking technologies at this time. If this changes, we will update this Privacy Policy and display a cookie banner for consent.

7. Marketing

We do not operate an email marketing list at this time. If this changes, we will obtain clear opt-in consent before sending any marketing communications.

8. Data Sharing

We only share personal data with trusted processors necessary for business operations, including:

• Google Workspace (Gmail, Drive, Docs)

• Canva

• Loom

• Framer

Other processors may be added in future, and this Privacy Policy will be updated accordingly.

Some providers may store or process data outside the UK/EEA under approved safeguards (such as Standard Contractual Clauses).

9. Data Retention

We retain personal data only as long as necessary:

• General enquiries not converted: 12 months

• Client project files: 6 years

• Invoices and financial records: 6 years (to comply with HMRC)

10. Security

We use appropriate measures to protect data, including:

• Google Workspace with 2FA enabled

• Encrypted storage and device passcodes

• Access restricted on a need-to-know basis

We review our security measures regularly to ensure ongoing protection of personal data.

11. Children

Our services are directed to businesses and adults. We do not knowingly collect data from children under 16.

12. Your Rights

Under UK GDPR, you have the right to:

• Access your personal data

• Request correction or deletion

• Restrict or object to processing

• Data portability

• Withdraw consent (where consent applies)

You may exercise these rights by contacting us at Enquiries@133strategy.com

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):https://ico.org.uk.

You can find more details on your rights at the ICO website: https://ico.org.uk.

13. Updates

We may update this Privacy Policy to reflect changes in our services, legal requirements, or data practices. The revised version will apply from the effective date stated above.