Privacy and Data Protection Policy

Version dated 11/12/2025

This Privacy Policy applies to users of the Close Only website, accessible at: https://closeonly.fr (hereinafter the “Site”). Its purpose is to inform Users about how their personal information may be collected and processed.

Respect for privacy and the protection of personal data are priorities for DIGITAL AIR MEDIA LTD. As such, we undertake to process your data in strict compliance with the UK GDPR (United Kingdom General Data Protection Regulation), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).

 

01. Who are we?

The data controller of your personal data is DIGITAL AIR MEDIA LTD, a Private Limited Company registered in England and Wales under, with its registered office at 128 City Road, London, United Kingdom, EC1V 2NX (hereinafter “Close Only Ltd”, “we”).

We are registered with the Information Commissioner’s Office (ICO) as a data controller.

 

02. Key Definitions

• “Data”: personal data subject to processing.

• “Personal Data”: any information allowing the direct or indirect identification of a natural person (e.g. name, first name, email address, IP address).

• “UK GDPR”: the UK General Data Protection Regulation, as amended after Brexit.

• “Data Protection Act 2018”: the national law governing the application of the UK GDPR.

• “Processor”: any person or entity processing data on our behalf and under our instructions.

• “Data Controller”: the person or entity determining the purposes and means of data processing.

• “User”: any person visiting the Site.

• “Processing”: any operation performed on data (collection, storage, communication, erasure).

 

03. Why do we use your data?

We only collect the data necessary for the following purposes:

• Managing data protection rights requests

  • Legal basis: legal obligation (UK GDPR & Data Protection Act 2018).

• Responding to contact and press requests

  • Legal basis: legitimate interest in managing external communications.

• Ensuring the proper functioning and continuous improvement of the Site

  • Legal basis: legitimate interest (quality of service); consent where necessary (cookies/trackers).

 

04. What data do we collect and how long is it retained?

• Requests relating to UK GDPR rights: email, first name, surname, content → retention 6 years.

• Contact/press form requests: email, first name, surname, content → processing plus 3 years after the last contact.

• Technical operation of the Site: logs, connection data, cookies → retention in line with ICO recommendations (logs max. 12–13 months; analytical cookies 13 months; associated data 25 months).

 

05. What data do we collect automatically?

During your browsing, we automatically collect certain information (IP address, operating system, browser type, pages viewed, cookies and trackers).

 

06. Who has access to your data?

• Our authorised staff,

• Our technical service providers (hosting, maintenance, emailing),

• Third parties depositing cookies (with your consent),

• Judicial, police or administrative authorities where required by law.

⚠️ Your data is never sold.

 

07. What are your rights?

Under the UK GDPR and the Data Protection Act 2018, you have the following rights:

• Right of access, rectification, and erasure,

• Right to restriction and to object to processing,

• Right to withdraw consent,

• Right to data portability,

• Right to lodge a complaint with the ICO (Information Commissioner’s Office, www.ico.org.uk).

? To exercise your rights:

• Email: support@closeonly.fr

• Mail: DIGITAL AIR MEDIA LTD – 128 City Road, London, United Kingdom, EC1V 2NX

 

08. How do we protect your data?

We implement appropriate technical and organisational measures, including:

• Secure system access controls,

• Encryption of passwords and sensitive data,

• Logging of connections,

• Regular tests and audits,

• Physical security of servers.

 

09. Transfers outside the United Kingdom

Your data is primarily processed in the United Kingdom and the EEA.
If data is transferred to a third country, such transfer will be governed by ICO-approved standard contractual clauses or equivalent safeguards.

 

10. Changes to this Privacy Policy

This Policy may be amended to reflect legal, technical, or organisational developments.
The version in force is the one published on the Site.