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Policy summary

Personal Data is processed for the following purposes using the following services:

Analytics:

Google Analytics (Universal Analytics) (if still in use — note: deprecated in favour of GA4 as of July 2023)
Personal Data processed: Cookies; Usage Data
Purpose: To monitor and analyse website traffic and user behaviour.

Note: If you have transitioned to GA4 or are using another analytics tool, this should be updated accordingly.

 

Content Commenting

No active content commenting system is currently in use.
Note: If Disqus or a similar system is manually embedded in the future, this section can be reinstated.

<!-- Remove this if not used: --> <!-- **Disqus** **Personal Data processed:** Cookies; Usage Data; various types of Data as specified in the privacy policy of the service **Purpose:** To enable users to comment on published content. -->

 

Platform Services and Hosting

Kartra (Genesis Digital LLC)
Personal Data processed: Name; email address; contact details; payment information (if applicable); Cookies; Usage Data; and other information as specified in Kartra’s privacy policy.

Purpose: To host the Website, manage user interactions, capture leads, and provide digital content and services.
Place of Processing: United States – Privacy Policy

 

Traffic Optimisation and Distribution

Cloudflare
Personal Data processed: Cookies; IP address; Usage Data; and other data as specified in the Cloudflare privacy policy.
Purpose: To secure and optimise the delivery of content via a global content delivery network (CDN).
Place of Processing: United States – Privacy Policy


User Database Management and Email Automation

ActiveCampaign (ActiveCampaign LLC)
Personal Data processed: Email address; Cookies; Usage Data; and various other data types as specified in the service’s privacy policy.
Purpose: To manage email marketing, user segmentation, behavioural triggers, and contact database.
Place of Processing: United States – Privacy Policy

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

 

Contact information
Owner and Data Controller
Digital Topics Limited Trading As Digital Leaders, 239 Old Street, London EC1V 9EY United Kingdom

Owner contact email: [email protected]

Full Policy

Owner and Data Controller

 

Digital Topics Limited Trading As Digital Leaders, 239 Old Street, London EC1V 9EY United Kingdom

Owner contact email: [email protected]

 

Types of Data collected

 

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; email address.

 

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.


Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.


Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

 

Users are responsible for any third-party Personal Data obtained, published or shared through this Website.

Mode and place of processing the Data

 

Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.


The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

 

Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

 

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

 

Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

 

Methods of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Content commenting, Analytics, Traffic optimization and distribution, User database management and Platform services and hosting.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Platform services and hosting

These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

 

Kartra (by Genesis Digital LLC)


Kartra is a platform provided by Genesis Digital LLC that allows the Owner to build, manage, and host this Website. Kartra offers a comprehensive suite of marketing and automation tools, supporting everything from landing pages and email campaigns to membership sites and e-commerce functionality.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

 

Google Analytics (Universal Analytics)


Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.


Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In order to understand Google's use of Data, consult Google's partner policy.


Personal Data processed: Cookies; Usage Data.

 

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Content commenting

This Website, built and hosted on the Kartra platform, does not include a public content commenting feature. Users are not able to post comments on pages or content hosted on this site.

Kartra is designed primarily for marketing automation, landing pages, membership areas, and sales funnels, and does not provide a built-in system for public comment submissions. If commenting functionality is introduced in the future through a third-party integration, the Privacy Policy will be updated accordingly to reflect any changes in data collection or processing related to that feature.

Traffic optimization and distribution

This type of service allows this Website to deliver content efficiently by using servers distributed across multiple geographic locations. These services help optimise website performance, improve load times, and enhance security.

The specific types of Personal Data processed depend on how the service is configured, but typically include information transmitted between the User’s browser and the Website. These services act as intermediaries, filtering and routing traffic to ensure faster and safer access to the Website’s content.

Because of the globally distributed nature of the network, it may be difficult to determine the exact jurisdictions where content — including data that may contain Personal Information — is transmitted.

 

Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimisation and security service provided by Cloudflare Inc. It acts as a reverse proxy, routing all website traffic through its global network to provide performance improvements and protection against malicious activity. Cloudflare may also collect analytical data related to site usage.

 

Personal Data processed: Cookies; IP address; usage data; and various types of Data as specified in the service’s privacy policy.


Place of processing: United States – Privacy Policy

User database management

This Website may use third-party services to create and manage user profiles based on information voluntarily provided by the User (such as name, email address, or other contact details) as well as behavioural data collected through interactions with the Website (e.g. email opens, link clicks, and page visits).

These services may use tracking technologies and analytics to monitor user behaviour and segment audiences. In some cases, the data may be enriched by matching it with publicly available information (such as social media profiles) to create more detailed private user profiles. This data may be used to personalise content, improve communication strategies, and automate marketing flows.

Some services also enable automated or scheduled messages to be sent to Users, triggered by specific actions (e.g. visiting a page or completing a form).

 

ActiveCampaign (ActiveCampaign, LLC)
ActiveCampaign is a customer experience automation platform that provides email marketing, CRM, and user behaviour tracking services.
Personal Data processed: Email address; cookies; usage data; and various types of data as specified in the service’s privacy policy.
Place of processing: United States – Privacy Policy

Information on opting out of interest-based advertising

 

This Website, built and hosted on the Kartra platform, may use tracking technologies (such as cookies, pixels, and tags) to support interest-based advertising and behavioural targeting, either through Kartra’s native tools or via third-party integrations.

In addition to any opt-out settings provided within individual emails or subscription forms, Users can manage their advertising preferences more broadly by referring to the [Cookie Policy] section of this Website.

For general control over interest-based advertising across multiple platforms, Users may also opt out using the following industry-standard tools:

  • YourOnlineChoices (EU)

  • Network Advertising Initiative (NAI)

  • Digital Advertising Alliance (DAA)

Please note that opting out of interest-based advertising does not eliminate ads entirely — it means that any ads you see may no longer be personalised based on your browsing behaviour or preferences.

 

Cookie Policy

 

This Website uses cookies and other tracking technologies (“Trackers”) to enhance user experience, analyse website traffic, and support marketing activities, including interest-based advertising and behavioural analytics.

To learn more about the types of cookies used, the purposes for which they are employed, and how to manage or withdraw consent, Users may refer to the [Cookie Policy].

Further Information for Users

 

Legal Basis for Processing Personal Data

The Owner processes Personal Data lawfully, fairly, and in a transparent manner, in accordance with applicable data protection laws, including the UK GDPR. The legal bases for processing may include:

  • The User’s consent;

  • The performance of a contract with the User;

  • Compliance with a legal obligation;

  • Legitimate interests pursued by the Owner or a third party, provided such interests are not overridden by the User’s rights and freedoms.

Security Measures

The Owner implements appropriate technical and organisational measures to safeguard Personal Data against unauthorised access, disclosure, alteration, or destruction. Data processing is carried out using secure IT systems and tools, following internal procedures aligned with the purpose of data collection.

Access to Personal Data may be granted, where necessary, to individuals involved in the operation of this Website (such as administrative, marketing, or technical staff), or to authorised external parties (such as hosting providers, email delivery platforms, IT services, or legal consultants). Where applicable, such third parties are appointed as Data Processors under a data processing agreement that ensures compliance with data protection regulations.

An up-to-date list of these third parties can be requested from the Owner at any time.

 

Data Retention

Unless otherwise specified in this Privacy Policy, Personal Data will be retained only for as long as necessary to fulfil the purposes for which it was collected. This includes:

  • Contractual purposes: Data will be retained until the agreement between the Owner and the User has been fully performed.

  • Legitimate interests: Data will be retained for as long as is reasonably necessary to fulfill those interests.

  • Legal obligations: Data may be retained for a longer period if required by law or by order of a competent authority.

  • User consent: Where processing is based on consent, data will be retained until consent is withdrawn.

Once the applicable retention period has expired, the Personal Data will be securely deleted or anonymised. After this point, rights such as access, rectification, erasure, and data portability can no longer be exercised.

The purposes of processing

 

The Personal Data concerning the User is collected and processed by the Owner for the following purposes:

  • To provide and operate the Website and its related services;

  • To fulfil contractual obligations or pre-contractual requests;

  • To comply with applicable legal obligations;

  • To respond to lawful enforcement or data access requests;

  • To protect the Owner’s legal rights and the interests of Users or third parties;

  • To prevent and detect unauthorised, malicious, or fraudulent activity;

  • To support marketing automation and communication workflows;

  • To perform web analytics and monitor user engagement;

  • To manage the User database and maintain service performance;

  • To ensure website security and performance optimisation through global distribution networks.

Processing is carried out using secure IT systems and tools, following procedures strictly related to the stated purposes. In addition to the Owner, Personal Data may be accessible to authorised individuals and service providers who support the Website’s technical, operational, marketing, or administrative functions.

For detailed information about the categories of Personal Data processed in connection with each purpose, Users may refer to the section titled “Detailed Information on the Processing of Personal Data.”

Additional information about Data collection and processing

 

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

 

Additional Information on Data Collection and Processing (UK GDPR)

 

Your Data Protection Rights (Under the UK GDPR)

As a data subject under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, you have the following rights with respect to your Personal Data:

  • Right to withdraw consent
    You may withdraw your consent at any time where processing is based on your prior consent.

  • Right to object to processing
    You have the right to object to processing where it is based on legitimate interests or carried out in the public interest. If your data is processed for direct marketing, you may object at any time without providing any reason.

  • Right of access
    You may request confirmation that we process your Personal Data and obtain a copy of that data, along with additional information about how and why it is used.

  • Right to rectification
    You may request that we correct or complete your Personal Data if it is inaccurate or incomplete.

  • Right to restrict processing
    In certain cases, you may ask us to temporarily suspend processing of your Personal Data (for example, while we verify accuracy or resolve an objection).

  • Right to erasure ("right to be forgotten")
    You may request deletion of your Personal Data where there is no legal basis for us to continue processing it.

  • Right to data portability
    Where processing is based on consent or contract and is carried out by automated means, you may request a copy of your Personal Data in a structured, commonly used, and machine-readable format. You may also request that we transmit the data directly to another controller, where technically feasible.

  • Right to lodge a complaint
    You have the right to complain to the Information Commissioner's Office (ICO) if you believe your data has been processed unlawfully or in breach of your rights. You can find more information at
    https://ico.org.uk.

 

International Data Transfers

Where Personal Data is transferred outside of the UK, we ensure such transfers are carried out in accordance with UK data protection laws, using appropriate safeguards such as UK Addendum to the EU Standard Contractual Clauses or international data transfer agreements (IDTAs).

You may request more information on these safeguards by contacting the Data Controller.

 

Right to Object – Further Detail

If your Personal Data is processed for purposes of public interest or legitimate interests pursued by the Owner, you may object to such processing by providing a reason relating to your particular situation.

If your data is used for direct marketing purposes, you have the absolute right to object at any time. In this case, your data will no longer be processed for such marketing.

 

How to Exercise Your Rights

You may submit a request to exercise any of your rights by contacting the Owner using the contact information provided in this Privacy Policy.

 

Requests are free of charge and will be responded to within one month, in line with UK GDPR requirements. In complex cases, this period may be extended by an additional two months, in which case you will be informed of the reason and duration.

If we have shared your Personal Data with third parties, we will take reasonable steps to inform them of your request—unless doing so proves impossible or would involve disproportionate effort.

 

Definitions (UK GDPR-Aligned)

  • Personal Data: Any information relating to an identified or identifiable natural person.

  • Usage Data: Automatically collected data, such as IP addresses, browser type, time spent on pages, and interaction details, used for analytics or functionality.

  • Data Subject: The individual to whom the Personal Data relates.

  • Data Controller (Owner): The entity that determines the purposes and means of processing Personal Data.

  • Data Processor: A party that processes Personal Data on behalf of the Data Controller.

  • Service: The digital services or content provided through this Website.

  • Cookies & Trackers: Technologies used to collect and store information on the User’s device for functionality, analytics, or marketing.

 

Legal Information

This Privacy Policy has been prepared in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, and applies solely to this Website, unless otherwise stated.

Privacy Policy Terms of Use

Copyright © 2025 Digital Topics Ltd

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