Legal
Privacy Policy
This policy explains how Hooksology collects, uses and protects personal information when you visit our website, enquire about our services, work with us as a client or take part in our campaigns as a creator.
Who we are
Hooksology is the trading name of Beatrice Wagstaff, a sole trader based in England. Hooksology plans and manages creator-led marketing campaigns for consumer mobile apps.
Beatrice Wagstaff is the controller of the personal information described in this policy. This means she decides how and why it is used and is responsible for protecting it.
This policy covers:
- people who visit our website;
- people who send us an enquiry, book a call or write to us;
- people who work for our clients and prospective clients;
- creators we consider for, or work with on, our campaigns.
Information we collect
Website enquiries
When you use our enquiry form, we receive your name, work email address, app name and message, plus your app link and app category if you choose to add them. Our form provider also records technical details, such as your IP address and the time you sent the form, and checks your IP address and email address against spam-filtering services.
Discovery-call bookings
If you book a call through Calendly, we receive your name, email address, your chosen time and any answers you give on the booking page.
Business correspondence
When you email us, we receive your name, email address and anything you include in your message or attachments, and we keep our replies.
Client relationships
If your business works with us, we hold the names, job titles and business contact details of the people we deal with, our correspondence, the information needed to agree and invoice our services, and the product, audience and campaign information you share with us.
Creators
When we look for creators for a campaign, we review publicly available social media profiles. From these, we may note your name or handle, your public content, publicly visible audience and engagement figures, and any contact details you publish for business enquiries.
If we work together, we also hold:
- your contact details and your social media handles, including any account you create for a campaign;
- your signed creator agreement;
- the payment and tax details we need to pay you;
- the content you create for campaigns, which may include your image, voice and performance;
- performance data for that content, such as views and engagement;
- our correspondence and the feedback we give you.
We need the information in your creator agreement and your payment details to work with you and pay you. Without them, we can’t engage you for a campaign.
Website visits
Our web host records technical information about visits, such as your IP address, browser type and the pages requested, so that it can deliver the site and protect it from misuse.
We don’t ask for sensitive information, such as health details. Please don’t include it in enquiries, emails or campaign materials.
How we use your information
UK data protection law requires a lawful basis for each way we use personal information. Where we rely on legitimate interests, we’ve weighed our interests against yours and only use information in ways you’d reasonably expect.
| Purpose | Information used | Lawful basis |
|---|---|---|
| Replying to enquiries, arranging and holding calls | Enquiry, booking and correspondence details | Legitimate interests in responding to business enquiries. If you’re a sole trader asking about our services for yourself, taking steps at your request before a contract. |
| Delivering services to clients and managing the relationship | Client contact, correspondence, contract and campaign information | Legitimate interests in managing our client relationships, or performing our contract where the client is an individual |
| Finding and assessing creators for campaigns | Public profile information | Legitimate interests in finding suitable creators for our clients’ campaigns |
| Engaging, briefing, managing and paying creators | Creator contact, agreement, payment, content and performance information | Performing our contract with you |
| Delivering campaign content and performance reporting to clients | Creator name, handle, content and content performance | Performing our contracts with creators and clients, and our legitimate interests in delivering client campaigns |
| Keeping business, tax and contract records | Contract, invoice and payment records | Legal obligation, and our legitimate interests in being able to show the rights granted under our agreements |
| Running the website securely and preventing spam and misuse | Technical visit data and form metadata | Legitimate interests in keeping our website and inbox secure |
| Establishing, exercising or defending legal claims | Any relevant records | Legitimate interests |
We don’t sell personal information, use it for automated decision-making or profiling with legal or similarly significant effects, or add you to a mailing list. We won’t send you marketing emails unless you ask us to.
Disclosure and sharing
We share personal information only where we need to. Our service providers process it on our behalf, under written data processing terms and only on our instructions.
| Recipient | Information | Purpose |
|---|---|---|
| Web3Forms (operated by Web3Creative, India) | Enquiry form details, IP address and submission time | Delivering form submissions to our inbox and filtering spam. It uses sub-processors including Amazon Web Services, Cloudflare and Hetzner. |
| Calendly LLC (United States) | Booking details | Scheduling discovery calls |
| Google LLC: Google Workspace (United States) | Emails and attachments | Hosting our business email |
| Netlify, Inc. (United States) | Technical visit data | Hosting this website |
| Our clients | Creator name, handle, campaign content and its performance | Delivering the campaign content and reporting our clients have engaged us for |
| Social media platforms | Content and account information published on the platform | Publishing campaign content. Platforms use this information under their own terms and privacy policies. |
| Banks and payment providers | Payment details | Making and receiving payments |
| Professional advisers | Information relevant to the advice | Accounting and legal advice, under a duty of confidentiality |
| Authorities, such as HM Revenue & Customs | Information the law requires | Meeting our legal obligations |
If we start using other service providers to store creator agreements or track campaign performance, we’ll update this policy to name them.
International data transfers
Some recipients process personal information outside the UK. Where they do, the transfer is protected as follows:
- Calendly, Google and Netlify are certified under the UK Extension to the EU–US Data Privacy Framework. Transfers to them are covered by the UK’s adequacy regulations for the United States, often called the UK–US “data bridge”.
- Web3Forms operates from India and uses providers in other countries, including the United States and the European Union. Transfers are covered by the standard contractual clauses and the UK International Data Transfer Addendum in its data processing agreement.
- Clients outside the UK: some of our clients are based elsewhere, including the United States. Where we share creator information with them to deliver a campaign, we use a transfer mechanism recognised under UK law, such as the UK International Data Transfer Agreement, where one is required.
You can ask us for more information about these safeguards.
Your data protection rights
Under UK data protection law, you have the right to:
- access: ask for a copy of the personal information we hold about you;
- rectification: ask us to correct information that is wrong or incomplete;
- erasure: ask us to delete your information;
- restriction: ask us to limit how we use it;
- portability: receive information you gave us in a portable format, where we use it to perform a contract with you.
Your right to object. Where we rely on legitimate interests, including when we’ve found you through a public profile, you can object to our use of your information at any time. We’ll stop unless we have compelling legitimate grounds to continue, or need the information for legal claims.
How to make a request
Email bea@hooksology.com. We may ask you to confirm your identity before we act. We’ll respond within one month. If your request is complex, or you make several, we may extend this by up to two further months, and we’ll tell you why within the first month. There’s normally no charge.
Some rights have limits. For example, we may need to keep signed agreements and tax records even if you ask us to delete them. If we can’t fully meet a request, we’ll explain why.
Data security and retention
Security
Our website and enquiry form use encrypted (HTTPS) connections. Access to personal information is limited to Beatrice Wagstaff and the service providers listed in section 04, and we choose providers that commit to appropriate security measures in their data processing terms.
How long we keep information
| Information | How long we keep it |
|---|---|
| Enquiries, call bookings and correspondence that don’t lead to working together | 12 months after our last contact |
| Notes on creators we consider but don’t work with | 12 months after we last considered or contacted them |
| Client records | For as long as we work together, then for as long as UK tax and accounting rules require us to keep business records |
| Creator agreements and records of the rights granted | For as long as we may need to show the rights granted under the agreement |
| Creator payment records | For as long as UK tax and accounting rules require |
| Campaign content and performance data | For the length of the campaign and the client relationship, and afterwards only where we need it for records or legal claims |
Our service providers keep some data under their own retention settings. For example, Web3Forms’ systems keep form submission data for up to three years, and our web host keeps technical logs for a limited period to operate and secure the site.
Cookies and tracking
This website doesn’t set cookies or store anything on your device. It doesn’t use analytics, advertising pixels or other tracking technologies, so we don’t ask for cookie consent.
Our fonts and all other website files are hosted on our own site, so your browser doesn’t contact other services to display our pages. When you send the enquiry form, your details go to Web3Forms, as described in section 04.
If you follow a link to Calendly, LinkedIn, X or Substack, those sites apply their own cookie and privacy policies.
Data protection complaints
If you’re unhappy with how we’ve handled your personal information, please tell us first. Email bea@hooksology.com with “Data protection complaint” in the subject line. We’ll acknowledge your complaint within 30 days, look into it, keep you informed and tell you the outcome without undue delay.
You can also complain to the UK’s data protection regulator, the Information Commissioner’s Office (ICO), at ico.org.uk/make-a-complaint (opens in a new tab) or on 0303 123 1113.
Contact and updates
For any question about this policy or your personal information, contact Beatrice Wagstaff trading as Hooksology at Postling Green, Roman Road, Aldington, or email bea@hooksology.com.
We’ll update this policy when the way we use personal information changes, and show the date of the latest version at the top of this page. If a change significantly affects clients or creators we work with, we’ll also tell them directly.
When we first contact a creator we found through a public profile, we include a link to this policy.