Legal

Privacy Policy

Last updated: 29 July 2026 | Effective: 29 July 2026

This Privacy Policy explains how Thornton Review Ltd ("we", "us", "our") collects, uses, stores, and protects your personal data when you visit wristanklerestor.world (the "Site") or place an order for Wellaray Coffee. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are (Data Controller)

The data controller for personal data collected through this Site is:

Thornton Review Ltd
27 Clerkenwell Road, London, EC1M 5RN, United Kingdom
Company No. / VAT: 14872306 · GB 412 8843 01
Telephone: +44 20 3948 7620
Email: info@wristanklerestor.world

2. What Personal Data We Collect

We collect the following categories of personal data:

Identity data: full name.
Contact data: telephone number, email address (when provided via the contact form).
Order data: product selected, UTM/campaign parameters, and GCLID where present.
Technical data: IP address, browser type and version, time zone, browser plug-in types, operating system, and platform - collected automatically via server logs.
Usage data: pages visited, time on page, referring URLs, and similar analytics data (only if analytics cookies are consented to).
Cookie data: as described in our Cookie Policy.

We do not collect special category data (health, biometric, genetic data) through this Site.

3. How We Collect Your Data

Directly from you - when you complete the order form, contact form, or any other web form on the Site.
Automatically - through cookies and similar tracking technologies (subject to your consent choices) and through server access logs.
From third parties - analytics providers (e.g. Google Analytics, subject to consent) and advertising platforms where applicable.

4. Lawful Basis for Processing

We rely on the following lawful bases under UK GDPR Article 6:

Purpose	Lawful Basis
Processing your order enquiry and contacting you to confirm and fulfil your order	Contract (Art. 6(1)(b))
Responding to contact form enquiries	Legitimate interests (Art. 6(1)(f))
Analytics and advertising cookies	Consent (Art. 6(1)(a))
Security, fraud prevention, and server logs	Legitimate interests (Art. 6(1)(f))
Compliance with legal obligations	Legal obligation (Art. 6(1)(c))

5. How We Use Your Data

To process and fulfil your order for Wellaray Coffee, including contacting you to confirm your order.
To respond to enquiries submitted via the contact form.
To maintain and improve the security and performance of the Site.
To conduct web analytics to understand how visitors use the Site (only with consent).
To comply with our legal and regulatory obligations.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

6. Sharing Your Data

We do not sell your personal data. We may share it with:

Order fulfilment partners - third-party logistics and payment processors used to dispatch your order.
Analytics providers - Google LLC (Google Analytics 4), where you have consented to analytics cookies. Google LLC is certified under the UK-US Data Bridge.
Advertising platforms - only where you have consented to advertising cookies (e.g. Google Ads via Consent Mode v2).
Professional advisers - lawyers, accountants, and auditors on a need-to-know basis.
Regulatory or law enforcement authorities - where required by applicable law.

All third-party processors are subject to data processing agreements that require them to process your data only on our instructions and in accordance with applicable data protection law.

7. International Transfers

Where we transfer personal data outside the UK, we do so only to countries or organisations that provide an adequate level of data protection as recognised by the UK Secretary of State (adequacy regulations), or we implement appropriate safeguards such as UK International Data Transfer Agreements (IDTAs) or addendums to EU Standard Contractual Clauses. Google Analytics data is transferred to the United States under the UK-US Data Bridge.

8. Data Retention

Order data: retained for 7 years to comply with HMRC record-keeping requirements.
Contact form data: retained for 2 years from the date of the enquiry, or until the matter is resolved.
Analytics data: as set by the relevant third-party platform (Google Analytics default retention: 14 months).
Server logs: retained for up to 90 days for security purposes.

9. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

Right of access - to request a copy of the personal data we hold about you.
Right to rectification - to request correction of inaccurate or incomplete data.
Right to erasure - to request deletion of your personal data in certain circumstances.
Right to restriction - to request that we restrict processing of your data in certain circumstances.
Right to data portability - to receive your data in a structured, machine-readable format where processing is based on consent or contract and carried out by automated means.
Right to object - to object to processing based on legitimate interests or for direct marketing purposes.
Rights related to automated decision-making - we do not carry out solely automated decision-making that produces legal or similarly significant effects.
Right to withdraw consent - where processing is based on consent, you may withdraw it at any time (withdrawal does not affect the lawfulness of processing before withdrawal).

To exercise any of these rights, please contact us at info@wristanklerestor.world or in writing to our address above. We will respond within one calendar month. We may need to verify your identity before processing your request.

10. Right to Lodge a Complaint

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection:

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: ico.org.uk

We ask that you contact us first so we have the opportunity to address your concern.

11. Cookies

We use cookies and similar tracking technologies on the Site. For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.

12. Security

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. However, no internet transmission is completely secure. If you have concerns about data security, please contact us.

13. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to read their privacy notices.

14. Children

The Site is not directed at children under 18. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided personal data through our Site, please contact us and we will delete it.

15. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Where changes are material, we will notify you by prominently posting a notice on the Site.

16. Contact

For any privacy-related queries, please contact: info@wristanklerestor.world or write to us at 27 Clerkenwell Road, London, EC1M 5RN.