Privacy, AI & Cookies Policy

Privacy, AI & Cookies Policy

Privacy

Last updated: 22 July 2026

Business Name: Nicola Turner t/a Turneround Virtual Services

Email: hello@turneroundvs.com

Website: www.turneroundvs.com

Data Regulator: Information Commissioner’s Office – https://ico.org.uk/

1. Introduction

I am committed to treating your personal information with respect and keeping it secure. This Privacy Policy explains what information I collect, how I use it, when I may share it, and how long I keep it.

I do not sell, rent, or trade your personal data.

This policy applies to prospects, clients, suppliers, associates, affiliates/referrers, and anyone interacting with Turneround Virtual Services.

2. Whose Information Do We Collect?

We process information about:

"PROSPECTS" Contacts working at or connected with potential CLIENTS; potential CLIENTS.

"CLIENTS" Individuals or businesses who have bought goods or services from us, and "CLIENT Contacts" who are individuals employed by or contracted to CLIENTS; children for whom services have been purchased.

"SUPPLIERS", "ASSOCIATES" SUPPLIERS or potential SUPPLIERS of goods or services to us.

"AFFILIATES/REFERRERS" Individuals who have signed up to an AFFILIATE scheme or who have referred PROSPECTS to us.

"EMPLOYEES" Our EMPLOYEES if we have any. EMPLOYEES should refer to their contract of employment for data privacy information relating to their own data.

3. Our Policy

We promise respectful treatment of the personal information of everyone we have contact with. We want it to be simple and clear.

This Policy explains how we do that – when and why we collect information, how we use it, the situations when other people can see or use it, and how we keep it secure.

We don’t sell, rent or trade email lists with anyone else.

We’ve split this Policy into sections depending on who you are. Section A is for everyone and includes information about cookies on our websites. Section B is for business prospects. Section C is for CLIENTS or CLIENT Contacts. Section D is for people whose data we process purely because we are providing services to a CLIENT. Section E is for SUPPLIERS, ASSOCIATES or AFFILIATES/REFERRERS.

4. Data Retention

I only keep personal data for as long as it is needed for the purpose it was collected.

  • Client records: kept for 7 years to meet HMRC accounting and tax requirements.

  • Project files, working documents and communications: kept for up to 2 years after the end of the contract unless you request deletion and no legal reason requires retention.

  • Email enquiries and contact form submissions: kept for 12 months unless they become a client relationship.

  • Financial records: kept for 7 years as required by UK law.

  • Website analytics and cookies: retained according to your browser or cookie banner settings.

When data is no longer required, it is securely deleted or anonymised.

SECTION A: FOR EVERYONE

A.1. Our General Approach to Personal Data

We’re committed to protecting your privacy and honouring your legal rights to control how we use your personal data.

We only collect and use personal data when we need to:

  • respond to enquiries

  • send requested newsletters or downloads

  • develop and manage business relationships

  • provide services to CLIENTS

  • calculate payments to ASSOCIATES or AFFILIATES/REFERRERS

  • meet legal obligations

We aim to keep information accurate, relevant, and no more than we need.

A.2. Categories of Data

The types of information we process depend on our relationship with you. We may process information you provide directly or information published online (e.g., social media).

This may include:

  • name, email address, business name, job title

  • contact address and social media handles

  • relevant publicly available information

  • records of interactions, work undertaken, and financial information

If we process information about you purely because we are providing services to others, see Section D.

A.3. Downloads, Newsletters and Services

If you sign up for downloads, newsletters or onboarding emails:

  • We monitor which emails are opened and which links are clicked

  • You can unsubscribe at any time

  • Existing CLIENTS may receive relevant service updates

  • Automations may send helpful onboarding or support information

You can disable cookies in your browser to prevent tracking.

A.4. Social Media

If you interact with us on social media:

  • Your interactions may be visible to us and our associates

  • Your data is processed according to the social media platform’s privacy policy

A.5. No Sale or Exchange of Your Data

We do not sell or exchange your personal data.

A.6. Data Location and Platforms

We use mainstream software tools. This means some data may be stored in the UK, EEA, USA or other locations with appropriate security standards.

A.7. Sharing Your Data

We may share limited data with trusted outsourced support such as:

  • Virtual assistants

  • Web designers

  • IT support

  • Accountants

  • Sales or marketing support

These individuals only access data when necessary and are bound by strict confidentiality agreements.

A.8. How Long We Keep Your Data

Your information is kept according to the retention periods listed in Section 4.

Newsletter subscribers remain on the list until they unsubscribe.

A.9. Accessing Your Data

You can request details of the personal data we hold about you by emailing hello@turneroundvs.com. We may need to verify your identity before providing information.

A.10. Your Rights

You have the right to:

  • know what information we hold

  • request corrections

  • request deletion (subject to legal obligations)

  • withdraw consent for newsletters or marketing

If you have concerns, please contact us. If unresolved, you may contact the ICO.

A.11. Legal Basis for Processing

We process data based on:

  • your consent (e.g., newsletters)

  • performance of a contract

  • legitimate business interests

  • legal obligations (e.g., accounting and tax)

SECTION B: PROSPECTS

We process information so we can reply to you, understand your enquiry, and build a business relationship.

This may include:

  • name, contact details

  • background information relevant to your enquiry

  • publicly available information

  • records of enquiries and responses

You can unsubscribe from newsletters at any time.

SECTION C: CLIENTS

When you buy something from us, we collect:

  • email address, phone number, postal address

  • information needed to deliver services

  • records of work undertaken

  • financial and accounting information

C.1. Third‑Party Data

You may provide us with personal data relating to your employees, clients or suppliers. We treat this information confidentially and process it according to your instructions.

C.2. Financial and Payment Details

Card payments are handled by secure third‑party processors. If you pay by bank transfer, we receive only the information provided by your bank.

SECTION D: THIRD‑PARTY INFORMATION

If we process your data on behalf of a CLIENT, we act under their privacy policy and will refer any enquiries to them.

If we process your data directly, we act as the data controller under this policy.

SECTION E: SUPPLIERS, ASSOCIATES & AFFILIATES

We keep:

  • contracts

  • bank details for payments

  • records of work undertaken

  • invoices and payment records

  • comments, reviews or complaints relating to work

Affiliate/referrer data is held in accordance with this policy.

Complaints

If you have concerns about how your data is handled:

AI

1. TRANSPARENCY

Almost every software platform and application is including some form of Artificial Intelligence (AI) in its system.

2. IN RUNNING OUR OWN BUSINESS

We use mainstream software platforms to run our own business and keep an eye on what is going on. AI implemented within existing major software platforms runs within their data privacy and security policies and does not usually create a security problem or share data outside of our subscription.

If we discover there is a security breach on that software that may potentially affect your data we will notify you as soon as we find out.

3. SUPPORTING YOUR BUSINESS

Where we use AI we use it to complement our work and experience not to replace it. We use our knowledge, skills and experience to ensure that we add real value to the service we offer.

We will use our best endeavours to discover whether the platform uses that learning data for anything other than improving material created for you (machine learning) and will not adopt them if they share your processes or material with a wider learning community.

If you have concerns about particular platforms and want to know if we use them for other clients, or ourselves please don’t hesitate to ask. AI is evolving rapidly and new benefits and concerns and risks are evolving all the time.

4. HUMAN OVERSIGHT

We use AI to complement our work and experience, not to replace it. We use our knowledge, skills and experience to ensure that we add real value to the service we offer. Anything created is checked by a real human being before being offered to you for you to check and approve.

5. YOUR PLATFORMS AND APPLICATIONS

Where you give us access to your platforms and applications we rely on you to check what any AI that runs inside it or is connected with it is doing. We are not responsible for checking its security or the reliability of its output.

a. Data Privacy

We do not put your personal data into AI applications that use it to train or generate data sets for our use or for anyone else to use.

Personal data you share with us from your data subjects will only be handled in the platforms you authorise in the DATA PROCESSING AGREEMENT between us or as otherwise authorised in writing by you.

b. Confidentiality

We will not add your confidential information to any AI app or system unless this is expressly discussed and agreed beforehand.

c. Copyright

We understand that AI generated content does not automatically come with copyright and that any copyright material entered into an AI generation system may form part of that system’s learning and generation of material for other users.

Many AI systems do assign copyright in the work (they call it outputs) to us and where this is the case we will assign appropriate copyright to you in line with our arrangements with you.

d. Overall

We will not knowingly use AI in our business in a way that breaches our contractual obligations, data privacy policy or any data processing agreement issued to us.

Cookies

1. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help the site function properly, improve performance, and provide information to the website owner.

Cookies cannot identify you personally unless you choose to provide information through a form or login.

2. How We Use Cookies

We use cookies to:

  • ensure the website works correctly

  • remember your cookie preferences

  • understand how visitors use the site (analytics)

  • improve website performance and user experience

We do not use cookies for advertising or profiling.

3. Types of Cookies We Use

Essential Cookies

These are required for the website to function and cannot be switched off.

They may include:

  • remembering your cookie preferences

  • enabling secure contact forms

  • maintaining basic site functionality

Analytics Cookies

These help us understand how visitors use the website so we can improve content and layout.

Analytics data is anonymised and may include:

  • pages visited

  • time spent on the site

  • browser/device type

Third‑Party Cookies

Some cookies may be set by third‑party services such as:

  • Hostinger website tools

  • Google Analytics (if enabled)

  • Embedded content (e.g., videos or social media posts)

These providers have their own privacy and cookie policies.

4. Managing Cookies

You can control cookies through:

  • your browser settings

  • clearing cookies from your device at any time

Most browsers allow you to block cookies entirely or delete existing ones.

5. Changes to This Policy

We may update this Cookie Policy from time to time. The latest version will always be available on this page.

6. Contact

If you have questions about this Cookie Policy, please contact:

Nicola Turner hello@turneroundvs.com

Terms of Use

Privacy, AI & Cookies Policy