Privacy Policy

Last Updated: 28 April 2026 | Effective Date: 28 April 2026

1. Background

True9 Limited (“we,” “us,” or “our”) understands that your privacy is important to you. We respect and value the privacy of everyone who visits www.true9.co.uk (“Our Site”) and will only collect and use personal data in ways that are consistent with our obligations and your rights under the UK GDPR, the Data Protection Act 2018, and the Data Use and Access Act 2025.

2. Information About Us

Our Site is owned and operated by True9 Limited, a limited company registered in England under company number 09270250.

Registered Address: Salts Mill, Victoria Road, Saltaire, West Yorkshire BD18 3LA.
VAT Number: 272893172.
Email: hello@true9.co.uk | Phone: 0330 043 1989

3. What Data Do We Collect?

Depending upon your use of Our Site, we collect the following:

Identity & Contact: Name, email, and telephone number.
Business Information: Business name and project requirements (including PHP platform details).
Recruitment Data: CVs, cover notes, and employment history.
Technical & Usage Data: IP addresses, browser types, geographic location, and behavioural data (mouse movements/scrolls) via Contentsquare and Google Tag Manager.

Special Category Data: We do not actively seek sensitive data (e.g., health or ethnicity). However, we acknowledge that you may voluntarily include such information in a CV or free-text form. We process this only where necessary for employment law or with your explicit consent.

4. How We Use Your Data

We use your data under the legal bases of Contractual Necessity, Legitimate Interests, or Consent to:

Provide support and correspond regarding our services (Magento, Symfony, Laravel, etc.).
Improve Our Site and internal business processes.
Process recruitment applications and manage our "Talent Pool."
Send industry insights via Mailchimp (where you have opted in).

5. Data Retention

General Enquiries: 2 years from last communication.
Analytics (GA4): User and event-level data is retained for 18 months.
Recruitment (Unsuccessful): 6–12 months, or 2 years if you consent to remain in our talent pool.
Successful Applicants: Duration of employment plus 6 years.

6. Sharing and International Transfers

We share data with trusted sub-processors: Directus Cloud (storage), Mailchimp (email), Contentsquare (behavioural analytics), and Google (analytics). For US-based transfers, we rely on the UK-US Data Bridge or ICO-approved Standard Contractual Clauses (SCCs).

7. Your Rights

You have the right to access, rectify, or erase your data. You may also object to or restrict certain processing.

Subject Access Requests (SAR): While the legal limit is 30 days, we aim to provide a complete response within 14 days. Email hello@true9.co.uk to make a request.
Data Accuracy: It is important that your personal data is kept accurate. Please keep us informed if your details change while we hold your data.
Marketing: You can opt out of our emails at any time. You may also register with the Telephone Preference Service (TPS) or Mailing Preference Service (MPS) to restrict unsolicited marketing.

8. Automated Decision-Making

Our recruitment and service processes are human-led. We do not use your personal data for solely automated decision-making or profiling that produces legal or similarly significant effects.

9. Security

We take essential measures to protect your data, including limiting access to employees with a legitimate "need to know" and using Multi-Factor Authentication (MFA) and encryption. However, please remember that no transmission over the internet is 100% secure.

10. Complaints

If you have a cause for complaint, please contact us first at hello@true9.co.uk. We will acknowledge formal complaints within 30 days. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).