Fortico Media Ltd respects your privacy and is committed to protecting your personal data. This policy explains what we collect when you use https://www.creativecomment.com/ (“the site”) or otherwise deal with us, why we collect it, how long we keep it, who we share it with and what your rights are.
Version 1, last updated 17 October 2026.
1. Who we are
The data controller is Fortico Media Ltd, a company registered in England and Wales under company number 08929887, whose registered office is at 12A Belle Vue Lane, Bude, Cornwall, EX23 8BR. We are registered with the Information Commissioner’s Office (ICO) under registration number ZA526813.
Questions about this policy or about your personal data should be sent to studio@fortico.media, or by post to 12A Belle Vue Lane, Bude, Cornwall, EX23 8BR.
2. What this policy covers
This policy applies to your use of the site and to personal data you give us by email, telephone, in person or through forms on the site. It does not cover other websites we link to; please read their own privacy policies.
“Personal data” means any information that identifies you or could identify you, directly or indirectly. It does not include data that has been anonymised.
3. Your rights
Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 you have the right to:
- be informed about how we use your personal data, which is the purpose of this policy;
- access the personal data we hold about you (a “subject access request”);
- have it corrected if it is inaccurate or incomplete;
- have it erased in certain circumstances;
- restrict how we process it in certain circumstances;
- object to processing based on our legitimate interests, and to direct marketing at any time;
- withdraw consent at any time where consent is our legal basis;
- data portability: to receive data you gave us in a structured, machine-readable format where we process it by automated means on the basis of consent or a contract;
- not be subject to decisions based solely on automated processing that have legal or similarly significant effects on you (we do not make decisions of this kind).
To exercise any of these rights, contact us using the details above. We will respond within one month, and there is normally no charge. We may need to confirm your identity first.
If you are unhappy with how we handle your personal data, please tell us first so we can try to put it right. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.
4. What we collect, how, and why
We must have a lawful basis for every use of personal data. The table below sets out what we collect, where it comes from, what we use it for and the legal basis we rely on. Where we rely on legitimate interests, our interest is running and improving our business and the site, responding to enquiries and keeping our systems secure, and we have balanced this against your rights.
| What we collect | How we collect it | Why we use it | Lawful basis |
|---|---|---|---|
| Contact details name, email address and anything you include in your message | Given to us when you email us | To reply to you | Our legitimate interests |
| Technical data IP address, browser type, device, pages requested | Collected automatically by our web server | To deliver the site and keep it secure | Our legitimate interests |
| Usage analytics a random visitor ID, pages viewed, referring site | Our own analytics, which runs only if you allow analytics cookies | To understand which articles people read so we can improve the site | Consent (you can withdraw it at any time) |
We only use your personal data for the purposes it was collected for, unless we reasonably consider another purpose compatible with the original one. If we need to use it for an unrelated purpose we will tell you and explain the legal basis.
5. How long we keep it
We keep personal data no longer than we need it for the purpose it was collected, unless the law requires us to keep it longer (for example, accounting records must be kept for six years). Our normal retention periods are:
| Type of data | How long we keep it |
|---|---|
| Contact details | Up to 2 years after our last contact |
| Technical data | Server logs up to 90 days |
| Usage analytics | Up to 26 months |
Where no fixed period is listed: As long as necessary for the purpose it was collected, then securely deleted.
6. Who we share it with
We do not sell your personal data. We share it only with service providers who process it on our behalf under contracts that require them to protect it and use it only on our instructions, with professional advisers, and where the law requires or permits (for example with regulators, or to protect our legal rights). Our current providers are:
- WP Engine: website hosting and backups (UK and USA)
If our business is sold or merged, personal data may be transferred to the new owner, who must use it in accordance with this policy.
7. Where your data is stored
Some of our service providers store or process data outside the United Kingdom and the EEA, including in the United States. Where this happens we make sure your data is protected by one of the safeguards recognised under UK law: UK adequacy regulations, the UK International Data Transfer Agreement, or the UK-US Data Bridge, as applicable. You can ask us for details of the safeguard that applies to a particular transfer.
We protect your personal data with appropriate technical and organisational measures, including encrypted connections (HTTPS), access limited to people who need it and who are bound by confidentiality, secure and regularly updated systems, and procedures for handling any data breach, including notifying you and the ICO where we are required to.
9. Changes to this policy
We may update this policy from time to time. The version and date at the top show when it last changed. Significant changes will be highlighted on the site.