Privacy policy
Privacy policy
October 24, 2022
Last Updated: August 22, 2025
Drewl is committed to protecting the privacy of its users’ personal data. We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Company Information
Luna Digital Ltd (T/A Drewl)
Limited company registered in England under company number 11803243.
Registered address: 1a The George, 45 Guildford Street, Chertsey, Surrey, United Kingdom, KT16 9BA.
Trading address: 1a The George, 45 Guildford Street, Chertsey, Surrey, United Kingdom, KT16 9BA,
Bermondsey, London, UK
VAT number: GB340484317.
Person responsible for Data Protection: Tayo Onabule.
Email address: hello@drewl.com.
Telephone number: 020 4538 0234.
Postal address: 1a The George, 45 Guildford Street, Chertsey, Surrey, United Kingdom, KT16 9BA
We abide by the guidelines from the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
2. What does this policy cover?
This Privacy Notice details how we use your personal data: how it is collected, how it is held, and how it is processed. It also details your rights under the law relating to your personal data.
3. What is personal data?
Personal data is defined by the GDPR and the Data Protection Act (2018) as “any information relating to an identified or identifiable natural person.” Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers and electronic location data.
4) What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to if you become aware of any inaccuracies or gaps in your personal data that we hold.
- The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e., prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office.
5) What Personal Data Do You Collect and How?
| Data collected | How we collect data |
| Contact information: name, email address and telephone number(s). | You will provide this information when you contact us via the “Contact Us” page on our website and/or make a telephone enquiry and/or when we meet (at a trade show for example) and/or when you become a customer. |
| Company / business information: Company name, company addresses (e.g., trading, registered, postal), company registration number, and telephone number/s. | You will provide this information when you become a customer with us. |
| Usage data including unique identifiers such as cookies, web beacons and IP addresses. | This is collected through automated means when you interact with our website and/or marketing emails and/or social media pages (please refer to our Cookie Policy for more information on the unique identifiers we use). |
| Payment information: bank details. | You will provide this information when you become a customer / place an order / open an account with us. |
| Profile information: Purchase history. | When you place an order with us, details of the order are retained within our Customer Relationship Management (CRM) system. |
| Contact information and work history: name, email address, postal address, telephone number/s, previous employers, job titles and dates of employment. | You will provide this information when you apply for a job with Luna Digital Ltd (Drewl). If you subsequently become an employee of Luna Digital Ltd (Drewl), you will be required to provide further personal information (via our HR platform onboarding forms). Details of the information we collect, how it’s processed and for what purpose are included in our employee data protection policy, a copy of which will be provided to you along with the forms mentioned above. |
| Identity information / proof of accreditation / membership number. | You will provide this information when you are working on something for us, and if the type of work you’re undertaking demands it. |
6) How Do You Use My Personal Data?
| What We Do | What Data We Use | Our Lawful Bases |
| Administering our business. | Company / business information and financial transactions. | Legal Obligation. |
| Supplying our services to you. | Contact and company / business information. | Contract. |
| Managing payments for our services. | Payment information. | Contract. |
| Communicating with you. | Contact information. | Legitimate Interests. |
| Marketing our services to you. | Contact and business information. | Legitimate Interests. |
| Improving our services. | Usage data and unique identifiers. | Consent. |
| Tailoring our marketing / marketing relevant services to you. | Usage data and unique identifiers. | Consent. |
| Managing, supporting and safeguarding our employees and contractors. | Please refer to employee data protection policy. | Contract, Legal Obligation, Legitimate Interests. |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will never share your personal data with third parties for marketing purposes.
7) How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
| Type of Data | How Long We Keep It |
| Contact information: name, postal address, email address and telephone number(s). (sales enquiries / prospects) | For as long as there’s the potential for us to work together, though we’ll endeavour to verify this at least every 12 months. |
| Company / business information: Business name, job title. (sales enquiries / prospects) | For as long as there’s the potential for us to work together, though we’ll endeavour to verify this at least every 12 months. |
| Usage data and unique identifiers. | Various (please refer to our Cookie Policy for more information on the usage data and unique identifiers we use including their retention periods / lifespan / expiry). |
| Contact information: name, postal address, email address and telephone number(s). (customers) | For as long as you’re a customer + for as long as there’s the potential for us to work together again, though we’ll look to verify this every 12 months (12 months from date of project completion). |
| Company / business information: Business name, job title. (customers) | For as long as you’re a customer + 10 years (10 years from date of project completion). |
| Profile information: Purchase history. (customers) | For as long as you’re a customer + 10 years (10 years from date of project completion). |
| Contact information and work history: name, email address, postal address, telephone number/s, previous employers, job titles and dates of employment. (job applicants) | Details of unsuccessful candidates deleted / shredded within 3 months of application, unless there is potential to work together in the future, with consent of the customer. |
| Identity information / proof of accreditation / membership number. | 12 months. |
8) How and Where Do You Store or Transfer My Personal Data?
We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so
- the implementation and maintenance of appropriate technology solutions such as firewall/s, anti-virus software, and encryption.
9) Do You Share My Personal Data and/or Use Other Organisations to Process My Personal Data?
| Recipient | Activity Carried Out / Service Provided | Location |
| IT support providers (Processors). | IT infrastructure provision and support. Software support. | UK. |
| Third-party web developers / contractors (Processors) | Web development. | UK. |
| Google Analytics (Controller) | Usage analytics. | US. |
| Google Ads (Controller) | Usage analytics. | US. |
| LinkedIn (Controller) | Marketing, advertising and Usage analytics. | US. |
| Instagram (Controller) | Marketing, advertising and Usage analytics | US |
| Higher Pixels (Buzzsprout) (Processor) | Podcast hosting and usage analytics. | US. |
| HubSpot (Processor) | CRM, email, lead management, marketing automation, user tracking and profiling, usage analytics. | US. |
| Hotjar (Processor) | Usage analytics. | EU (Malta) |
If any of your personal data is shared with and/or processed by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10) How Can I Access My Personal Data?
If you want to retrieve personal data we have on you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
We will respond to your subject access request within 20 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11) How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Tayo Onabule):
Email address: hello@drewl.com
Telephone number: 020 4538 0234
Postal Address: 1a The George, 45 Guildford Street, Chertsey, Surrey, United Kingdom, KT16 9BA.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available via our website. This Privacy Notice was last updated on 30th October 2024.
12) How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at hello@drewl.com.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Helpline number: 020 4538 0234