Privacy Policy

Last updated: 17 July 2026

1. Who We Are

Clearwater Review Ltd ("we", "us", "our") is the data controller for personal data collected through this website. Registered address: 27 Aldgate High Street, London, EC3N 1AL, United Kingdom. Company No. 14823761. You can contact us at info@strainingoaearth.world or by post at the address above.

2. What Personal Data We Collect

We may collect the following categories of personal data:

Identity data: your name, as provided when placing an order or submitting a contact form.
Contact data: phone number, email address.
Transaction data: details about orders you place, including product, price, and delivery information.
Technical data: IP address, browser type and version, time zone, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage data: information about how you use our website, products, and services.
Marketing and communications data: your preferences in receiving marketing from us and your communication preferences.

3. How We Collect Your Data

We collect data through:

Direct interactions - when you place an order, complete a contact form, or correspond with us by email or telephone.
Automated technologies - as you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns via cookies and similar technologies. See our Cookie Policy for details.
Third parties - analytics providers (Google Analytics) and advertising services (Google Ads).

4. Legal Basis for Processing (UK GDPR Article 6)

Article 6(1)(b) - Contract: processing necessary to fulfil your order or take steps prior to entering into a contract.
Article 6(1)(a) - Consent: where you have given clear consent for us to process your data for a specific purpose (e.g. marketing communications, analytics cookies).
Article 6(1)(c) - Legal obligation: where processing is necessary to comply with a legal obligation (e.g. VAT records, consumer law).
Article 6(1)(f) - Legitimate interests: where necessary for our legitimate interests (e.g. website security, fraud prevention, direct marketing to existing customers), provided these are not overridden by your rights and interests.

5. How We Use Your Data

To process and fulfil your order for Orivelle-pen, including delivery and payment.
To respond to enquiries and provide customer support.
To send you order confirmations and service-related communications.
To improve our website and services through analytics.
To serve relevant advertising through Google Ads and Google Remarketing (subject to your consent preferences).
To comply with our legal and regulatory obligations.

6. Google Services

We use the following Google services on this website:

Google Analytics: collects anonymised usage data (pages visited, session duration, device type) to help us understand how visitors interact with our site. We use Google Consent Mode v2; analytics cookies are only activated with your consent.
Google Ads & Remarketing: we may use Google Ads to serve advertisements and use remarketing lists to show relevant ads to previous website visitors. Ad cookies (_gcl_au) are only activated with your consent. You can opt out via Google Ad Settings.
Google Maps: an embedded map on our contact page loads content from Google's servers. Google may process technical data such as your IP address when you interact with the map. This is governed by Google's Privacy Policy.

7. Cookies

We use cookies and similar tracking technologies. Please see our Cookie Policy for full details, including how to manage your preferences. We implement Google Consent Mode v2, defaulting all non-essential cookies to denied until you provide consent.

8. International Transfers

Some of our third-party service providers (including Google) are based outside the UK. Where we transfer your personal data outside the UK, we ensure a similar degree of protection is afforded by using contracts approved by the ICO (UK International Data Transfer Agreements or equivalent UK adequacy mechanisms).

9. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy, including for legal, accounting, or reporting requirements. Order data is retained for 7 years to comply with financial record-keeping obligations. Contact form data is retained for up to 2 years.

10. Your Rights Under UK GDPR

You have the following rights regarding 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 restrict processing: to request that we limit how we use your data.
Right to data portability: to receive your data in a structured, commonly used, machine-readable format.
Right to object: to object to processing based on legitimate interests or for direct marketing.
Rights in relation to automated decision-making: we do not carry out solely automated decision-making that produces legal or similarly significant effects.

To exercise any of these rights, contact us at info@strainingoaearth.world. We will respond within one calendar month.

11. Right to Lodge a Complaint

You have the right to lodge a complaint with the UK supervisory authority for data protection:

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

12. Third-Party Links

Our website may include links to third-party websites. Clicking those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised "last updated" date. We encourage you to review this page periodically.

14. Contact

Clearwater Review Ltd · 27 Aldgate High Street, London, EC3N 1AL, UK · info@strainingoaearth.world · +44 20 7946 0821