Data Protection Policy

Last updated 24/09/2025

Definitions

GDPR means the General Data Protection Regulation.
Register of Systems means a register of all systems or contexts in which personal data is processed by Samuel Leeds Ltd.

1.⁠ ⁠Our Commitment

Samuel Leeds Ltd is the Data Controller. We are committed to protecting personal data and handling it lawfully, fairly, securely, and transparently in line with the UK GDPR and Data Protection Act 2018.

2.⁠ ⁠Principles We Follow

We ensure that personal data is:

Lawful & Fair – processed on a valid legal basis (consent, contract, legal obligation, or legitimate interests).

Limited – we only collect what we need.

Accurate – kept up to date where possible.

Secure – protected against loss, misuse, or unauthorised access.

Retained Only As Needed – deleted or anonymised once no longer required.

3.⁠ ⁠People’s Rights

Anyone whose data we hold has the right to:

Access their data

Correct inaccurate data

Request deletion (“right to be forgotten”)

Object to certain uses (like marketing)

Restrict or limit processing

Receive a copy of their data in a portable format

Requests will be responded to within one month.

4.⁠ ⁠Security Measures

We protect data by using:

Passwords, encryption, and secure systems

Limited access for staff who need it

Antivirus, firewalls, and regular backups

Secure deletion when data is no longer needed

5.⁠ ⁠Sharing and Transfers

We may use trusted third-party service providers (e.g., cloud platforms, payment processors) under written agreements.

If data is transferred outside the UK, we ensure safeguards are in place (such as Standard Contractual Clauses).

6. Samuel Social

Please note that, due to the nature of our platform, individual chat messages and content shared within the app cannot be deleted by users. However, you have the right to request the deletion of your entire account at any time. Upon receipt of such a request, we will delete your account and all associated personal data, subject to our legal obligations and legitimate interests.

7.⁠ ⁠Data Breaches

All data breaches are logged.

Serious breaches will be reported to the ICO within 72 hours.

If individuals are affected, we will notify them promptly.

8.⁠ ⁠Staff Responsibility

All staff and contractors handling data must follow this policy and complete basic data protection training.

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