Privacy & Cookie Policy
Introduction
Launch Online Limited (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Data (Use and Access) Act 2025 and the Privacy and Electronic Communications Regulations 2003 (together, the “Data Protection Legislation”), the data controller is Launch Online Limited, a limited company registered in England & Wales with company number 08184190 whose registered office address is at C/o Kirk Hills Chartered Accountants, 5 Barnfield Crescent, Exeter, England, EX1 1QT
Your personal data
Personal data is any information about you that enables you to be identified. Personal data covers your name and contact details, but also information such as electronic location data and other online identifiers. It does not include data where your identity has been removed (anonymous data). 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 let us know.
Our lawful bases for processing
The law requires us to have a lawful basis for processing your personal data. Depending on the circumstances, we may rely on:
- the performance of a contract with you;
- our legitimate interests (such as administering and improving our website, developing our business, keeping our website secure and marketing our services), provided your interests and rights do not override those interests;
- compliance with a legal obligation;
- your consent (for example, to certain marketing or to the setting of non-essential cookies), which you may withdraw at any time.
More information about the lawful bases we rely on is set out in the How we use your personal data section below.
What data we collect
This section explains the personal data we collect about you when you visit our website, enquire about our services, become a client, work with us as a supplier, or apply for a job with us.
Data we handle for our clients
Launch Online is a digital marketing agency. When we run advertising, analytics, tracking or email campaigns for our clients, we do so on their instructions and on their behalf. That activity is governed by the client’s own privacy policy, not this one. If you have received marketing from one of our clients, or visited a client’s website, and you want to know how your data is used, please contact that organisation directly.
Categories of personal data we collect
Contact and identity data. Your name, job title, employer, email address, telephone number and postal address. We collect this when you complete a form on our website, email or call us, book a call or meeting with us, download a resource, or sign up to receive our updates.
Client and supplier data. Where you are a contact at one of our clients or suppliers, we hold the information needed to run the relationship, including correspondence, project records, meeting notes and the contact details we use for billing.
Billing data. Where you engage us, we hold the details needed to invoice you, including billing contact name, email address and address. Most clients pay by bank transfer. If you pay by card, payment is handled by a third party payment provider and we do not receive or store your full card details.
Communications data. Emails, messages, enquiries and call notes or transcripts recording communications between you and us.
Marketing engagement data. Whether you open our emails and which links you click, which of our resources you download, and which events or webinars you register for or attend.
Assessment and scorecard data. Where you complete an online assessment, quiz or scorecard on our website, we collect the answers you provide together with the contact details you submit in order to receive your results. We use this to send you your results and, where you have agreed, to contact you about our services. Your answers are stored by our assessment provider and copied into our customer relationship management system.
Website usage data. Pages you view, how long you spend on them, the website or search that brought you to us, the search terms you used, links you click, how far you scroll, page response times and any download errors and how you navigate away from our website.
If you complete a form on our website, our customer relationship management system may connect your earlier activity on our website to your contact record, so that we hold a single view of your interactions with us. This means browsing that was previously not linked to you by name may become associated with your contact details from that point.
Session recording data. We use Clarity, a tool that creates a replay of your visit, showing the pages you viewed, where you moved your cursor, what you clicked, how far you scrolled, and what you enter into a form on our website. This helps us understand how people use our website and where it can be improved.
Technical data. Your Internet Protocol (IP) address, browser and browser plug-in types and versions, device type, operating system and platform, screen size, and your language and time zone settings.
Advertising and measurement data. Where you reach our website by clicking one of our adverts, and you consent to the relevant cookies (see Use of cookies below) we receive an identifier from the advertising platform which allows us to see which advert brought you here and whether you went on to contact us. We also use technologies that allow us to show our adverts to people who have visited our website before.
Social media data. Your handle and any public interaction, where you comment on, message or otherwise engage with our social media accounts, or use a social media feature on our website.
Security data. We use tools that help us tell human visitors apart from automated traffic and protect our website from spam and abuse. These assess the technical and behavioural information described above to calculate a score indicating whether you are likely to be a genuine visitor. This happens on every visit, whether or not you are asked to complete a visible challenge such as a reCAPTCHA.
Recruitment data. Where you apply for a role with us, your curriculum vitae, work history, qualifications, references and right to work information.
Special category data. We do not ask you for information about your health, racial or ethnic origin, religious or philosophical beliefs, political opinions, sex life, sexual orientation, trade union membership, genetics or biometrics, and we ask that you do not send such information to us. Where you provide it without being asked, we delete it unless we need it for a specific purpose and have a lawful basis for keeping it.
Where we obtain data from other sources
We sometimes obtain business contact details from sources other than you. These include third party business data providers, including Amplemarket and LinkedIn Sales Navigator, professional networking platforms such as LinkedIn, publicly available sources such as company websites and Companies House, and referrals from our clients and partners.
The information we obtain from these sources is limited to business contact details: your name, job title, employer, business email address and business telephone number. We do not obtain personal or home contact details in this way.
We use this information to contact organisations we believe may benefit from our services. Our lawful basis for doing so is our legitimate interest in marketing our business to relevant organisations. You can object to this at any time and we will stop contacting you.
Where we obtain your details in this way, we will tell you within one month, or at the point we first contact you if that is sooner, and we will tell you the specific source we obtained them from. We keep this information for three years and delete it if you have not engaged with us during that time.
How we use your personal data
Under the Data Protection Legislation, we must always have a lawful basis for using personal data.
The table below sets out what we use your personal data for (depending on your relationship with us) and the lawful basis we rely on in each case.
Where we rely on our legitimate interests, we have considered whether those interests are outweighed by your rights, and you can ask us for more information about that assessment at any time.
Where we handle personal data on behalf of our clients as part of the services we provide to them, we do so on their instructions. That activity is governed by the client’s own privacy notice and is not covered by this section.
| What we use your personal data for | Our lawful basis |
|---|---|
| Responding to your enquiry and sending you information you have asked us for | Our legitimate interest in responding to people who contact us, or taking steps at your request before entering into a contract |
| Delivering our services and managing our relationship with you | Performance of our contract with you, where you contract with us as an individual. Where you are a contact at a client organisation, our legitimate interest in managing that client relationship |
| Invoicing, taking payment and chasing unpaid invoices | Performance of our contract, and our legitimate interest in recovering sums owed to us |
| Keeping accounting, tax and business records | Compliance with a legal obligation, and our legitimate interest in maintaining proper records |
| Operating, maintaining and securing our website, including telling human visitors apart from automated traffic | Our legitimate interest in keeping our website available, working correctly and protected from abuse |
| Understanding how our website is used, including analytics and session replay, so that we can improve it | Your consent to the technologies used to collect the information, and our legitimate interest in improving our website once it has been collected |
| Advertising our own services, showing our adverts to people who have visited our website, and measuring which adverts lead to enquiries | Your consent to the technologies used to collect the information, and our legitimate interest in promoting our business |
| Providing you with the results of an online assessment or scorecard you have completed | Our legitimate interest in responding to your request, and your consent where you have asked us to contact you about our services |
| Sending you marketing emails about our services | Your consent, or where you have previously enquired about or bought our services, our legitimate interest in marketing similar services to you |
| Contacting organisations we believe may benefit from our services, using business contact details obtained from other sources | Our legitimate interest in marketing our business to relevant organisations |
| Considering your application if you apply to work with us | Taking steps at your request before entering into a contract, and our legitimate interest in recruiting suitable people. Checking your right to work is a legal obligation |
| Dealing with complaints, disputes and legal claims | Our legitimate interest in defending our position, and compliance with a legal obligation where one applies |
| Complying with requests from regulators, or with other legal and regulatory duties | Compliance with a legal obligation |
| Transferring our business, or part of it, to someone else | Our legitimate interest in being able to sell or restructure our business |
Marketing
If you have enquired about or bought our services, we may email you about services similar to those you enquired about or bought. Every message we send includes a link to unsubscribe, and you can also tell us to stop at any time by emailing [email protected].
Where we contact you at a business email address on behalf of your employer, we rely on our legitimate interest in marketing our services to organisations that may benefit from them. If you are a sole trader or in a partnership, we will only send you marketing emails or text messages where you have consented to receive them.
We will only make marketing telephone calls to you where you have agreed to this, and we screen numbers against the Telephone Preference Service and Corporate Telephone Preference Service before calling.
We do not sell your personal data, and we do not share it with third parties so that they can market their own products or services to you.
Profiling and automated decisions
Some of the tools we use in our business analyse information automatically. None of them make decisions about you on their own. Where anything is decided that affects you, a person is involved and makes the final judgement. This means we do not carry out what the Data Protection Legislation calls ‘solely automated decision-making with legal or similarly significant effects’.
We do carry out some limited automated analysis which does not have these effects:
Grouping and analysis. We analyse how visitors use our website, which involves grouping visits and looking at patterns of behaviour rather than assessing you individually.
Advertising audiences. Advertising platforms may use information collected on our website to include you in audiences of people shown our adverts, or people similar to those who have contacted us.
Contact records. Our customer relationship management system records your interactions with us, such as pages viewed and emails opened, and may rank enquiries so that our team knows who to follow up. A person always decides whether and how to respond.
Security scoring. The tools that protect our website calculate a score indicating whether a visitor is likely to be a person rather than automated software. If the score suggests automated traffic, access may be challenged or blocked. If you think you have been blocked incorrectly, please contact us and we will look into it.
You can object to any of this at any time by contacting us.
Using your data for a new purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will tell you and explain the lawful basis that allows us to do so.
In some circumstances we may process your personal data without your knowledge or consent, where this is permitted or required by law. We will only ever do this within the limits set by the Data Protection Legislation and your legal rights.
Disclosure of your information
We do not sell your personal data. We share it only in the ways described below.
Providers who handle personal data on our behalf
We use external providers to supply the systems and support we need to run our business. These providers process personal data on our instructions and are not permitted to use it for their own purposes. We have written agreements in place with each of them requiring them to keep your personal data secure and to use it only as we have told them to.
Amplemarket provides our prospect relationship management system and the platform we use to create and manage prospect lists and send marketing emails.
HubSpot provides our customer relationship management system and the platform we use to create, manage and send marketing emails.
Google provides email, document storage, productivity and collaboration tools, the analytics we use to understand how our website is used, and our security reCAPTCHA tool.
Microsoft provides file storage, productivity and collaboration tools, including email and Teams, and the Clarity tool we use to understand how visitors interact with our website.
Cloudflare provides the security and performance layer that sits in front of our website and helps protect it from automated abuse.
CookieYes provides the tool that records and manages your cookie preferences.
Basecamp and Accelo provide the systems we use to plan and manage our projects and our work for clients.
Granola provides the tool we use to take notes and produce transcripts of meetings and calls.
GoCardless, our payment processor, administers payments where you pay us by card. Your payment details are transmitted directly to GoCardless and we do not receive or store your full card details.
Xero provides the online accounting system we use for invoicing and accounting.
ScoreApp provides the online assessment and scorecard tool used on our website
Google Gemini, OpenAI and Anthropic provide the artificial intelligence tools we use to support our work. We only use these tools in line with our internal AI policy and the Data Protection Legislation, on terms which prevent your personal data being used to train their models.
Providers who also use data for their own purposes
Some of the technologies on our website are operated by companies that use the information they collect for their own purposes as well as ours. Where that happens we are not able to control what they do with it, and their own privacy notice applies alongside this one. These technologies only operate where you have accepted them in our cookie settings, and you can withdraw that consent at any time.
Meta operates a tracking technology on our website. It loads on the pages you visit and sends Meta the address of the page, information about your browser and device, your IP address, and a record of certain actions you take, such as submitting a form. Where you submit your details, it may also send a scrambled version of your email address or telephone number so that Meta can recognise you. If you are signed in to a Meta account, Meta can link this activity to that account. We use this to measure how our advertising performs and to show adverts to people who have visited our website. Meta also uses the information for its own purposes, including its advertising services. You can access Meta’s privacy notice here: LINK.
LinkedIn operates a similar technology on our website, which works in the same way and which we use for the same purposes. We also use it to see which organisations have visited our website. LinkedIn also uses the information for its own purposes. You can access LinkedIn’s privacy notice here: LINK.
Google receives information about your visit through the advertising technologies on our website, including the page you viewed, your device and browser details, and an identifier recording whether you arrived by clicking one of our adverts. We use this to measure which adverts lead to enquiries and to show adverts to people who have visited our website. Google also uses the information for its own purposes.
YouTube (a Google entity) provides the video player embedded on some pages of our website. Where you view one of those pages, YouTube may receive your IP address and information about the page, whether or not you play the video.
Google’s Privacy notice, which also covers YouTube, can be found at this LINK.
These technologies operate on every page you visit once you have accepted them in our cookie settings, whether or not you have seen one of our adverts. You can switch them off at any time by clicking the Consent Preferences icon in the footer of our website.
Work we do for our clients
The tools described above are the ones we use to run our own business. When we deliver services to our clients we also use other platforms on their instructions and on their behalf, including advertising, analytics and data warehousing tools. That activity is governed by the relevant client’s privacy notice rather than this one.
Other people we may share your personal data with
We may also share your personal data:
- with our professional advisers, such as our lawyers, accountants, auditors, bankers and insurers, where they need it to advise us;
- with HM Revenue & Customs, regulators and other authorities where they are entitled to ask for it;
- with a third party who buys our business, or part of it, in which case any new owner may continue to use your personal data as set out in this notice;
- where we are required to do so by law, including in connection with legal proceedings, a court order, or the instructions of a government authority;
- where we need to establish, exercise or defend legal claims;
- with anyone else you ask us to share it with, or have agreed that we can share it with; and
- in exceptional circumstances, where we believe there is a real risk of harm to you or to someone else.
Where we share your personal data with anyone, we take steps to make sure it is handled securely and in line with our obligations and yours.
Where we store and transfer your personal data
The data we collect from you may be transferred to, and stored at, a destination outside the United Kingdom, and may be processed by staff operating outside the UK who work for us or for one of our suppliers or third party processors listed above. Where your personal data is transferred outside the UK, we ensure a similar degree of protection by making sure at least one of the following safeguards is in place:
- the transfer is to a country the UK has deemed to provide an adequate level of protection;
- the transfer is made under the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment where required;
- for US-based providers, the provider participates in the UK Extension to the EU-US Data Privacy Framework (the UK-US Data Bridge)
- or another safeguard permitted by the Data Protection Legislation applies.
Information you provide to us is stored on servers operated by us or by the providers described above. Connections to our website are encrypted in transit, and we require our providers to maintain appropriate technical and organisational measures to protect personal data.
No method of transmitting information over the internet is completely secure. While we take appropriate steps to protect your personal data, we cannot guarantee the security of information you send to us over the internet. Once we receive it, we apply appropriate procedures and security measures to protect it against unauthorised access.
Use of cookies
What cookies are
Cookies are small text files placed on your device when you visit a website. Our website also uses other technologies that work in comparable ways, including pixels, tags and browser storage. In this policy we refer to all of these together as cookies.
Some cookies are placed by us. Others are placed by third parties whose technology we use on our website, including the providers listed in the Disclosure of Your Information section above. Third party cookies may track your activity across different websites in order to measure advertising, analyse traffic or deliver personalised content. Where a third party uses the information it collects for its own purposes, its own privacy notice applies alongside this one.
What we use them for
We use cookies for:
- keeping our website secure and working properly, and protecting it from automated abuse
- remembering your choices and preferences, including the cookie preferences you have set
- understanding how our website is used, so that we can improve it
- measuring how our advertising performs, and showing our adverts to people who have visited our website
When we need your consent
Our use of cookies is governed by the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426), the UK GDPR and the Data Protection Act 2018, each as amended, including by the Data (Use and Access) Act 2025.
Strictly necessary cookies are set without your consent, because our website cannot work properly without them. These cookies keep our website secure, tell human visitors apart from automated traffic, remember what you have entered into a form, and record the cookie preferences you have chosen.
All other cookies are only set where you have given your consent. This includes cookies used for analytics, advertising, and any additional functional features on our website which are not strictly necessary but which may enhance your user experience.
How to manage your preferences
When you first visit our website you will be shown a banner allowing you to accept or reject non-essential cookies by category. Rejecting non-essential cookies will not prevent you from using our website, although some features may not work as well.
The Consent Preferences section of our website, which can be accessed via the cookie icon in the website footer, also lists the specific cookies and similar technologies in use on our website, grouped by category, together with what each one does, who provides it and how long it lasts. That list is generated automatically so that it stays current, which is why we do not reproduce it in this policy.
You can change your mind about any of the above at any time in the Consent Preferences section of our website. Withdrawing your consent is as straightforward as giving it.
Managing cookies in your browser
You can also control cookies through your browser settings, including blocking or deleting them. This works separately from our cookie settings, and blocking cookies at browser level may affect how our website and other websites work.
How we use the information collected
Once information has been collected through these technologies, we use it for the purposes set out in the table in the How we use your personal data section above, relying on the lawful basis shown there.
Your rights
You have the right to ask us not to process your personal data for marketing purposes, and you can exercise this at any time by contacting us at [email protected] or by using the unsubscribe link in our emails.
Under the Data Protection Legislation you also have the right:
- to be informed about our use of your personal data;
- to access your personal data;
- to have inaccurate or incomplete data corrected;
- to request erasure in certain circumstances;
- to restrict or object to processing in certain circumstances;
- to data portability; and
- where we rely on consent, to withdraw that consent at any time.
You also have rights under the Data Protection Legislation in relation to automated decision making. However, we do not make decisions that produce a legal or similarly significant effect about you based solely on automated processing.
You can exercise any of the above rights by contacting us at [email protected].
Access to information and data retention
You have the right to access the personal data we hold about you (a subject access request). There is not normally any charge, unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline to act on it. We will respond within one month of receiving your request, extendable by up to two further months for complex or numerous requests, and we may pause that period where we need further information from you. We are only required to carry out searches that are reasonable and proportionate in the circumstances.
We may retain information about you, including personal information, for the period necessary to fulfil the purposes set out in this policy unless a longer retention period is required or permitted by law.
How to complain
If you have a complaint about how we handle your personal data, please contact us first at [email protected] so that we can try to resolve it. We will acknowledge your complaint within 5 business days, investigate it without undue delay, keep you informed of our progress and let you know the outcome. If you are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO) at www.ico.org.uk, though we would appreciate the chance to address your concerns first.
Changes to our Privacy & Cookie Policy
Any changes we may make to our Privacy & Cookie policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this Privacy & Cookie policy should be addressed to [email protected].
This Privacy & Cookie Policy was last updated on .