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Privacy Policy

The SWhittlesey ( website is provided for informational, consultation and solicitation purposes by SWhittlesey.  The Data Controller for SWhittlesey is the CSO (Chief Security Officer).  A Data Controller determines how and why personal data is processed. All Personal Identifiable Information (PII) is treated with upmost scrutiny and security per the core values of SWhittlesey.


What data we need

The personal data we collect from you may include:

  • Information you agree to freely provide through contacting
  • This may include your name, email address, phone number, street address and any other information you choose to provide.
  • Your Internet Protocol (IP) address and technical details including date and time of users visiting our site are collected through automatic processes for monitoring and securing our systems and data.
  • Information on how you use the site using analytic techniques

 The legal basis for processing this data is to provide you as our customer, or visitor, relevant and requested informational queries that you request.


Why we need it

We may use Google Analytics software to collect information about how you use

We do this to help make sure the site is meeting the needs of our users and to help us make improvements.

 Google Analytics stores information about:

  • The pages you visit on
  • How long you spend on each page.
  • How you got to our site.
  • What you click on while you’re visiting the site.

 We do not collect or store your personal information (for example your name or address) so this information cannot be used to identify who you are.

 We also collect data in order to:

  • Improve our site by monitoring how you use it.
  • Gather feedback to improve our service.
  • Respond to any feedback you send us, if you requested us to.
  • Send email alerts and notifications to users who request them.
  • Allow you to access our services and make transactions.
  • Provide you with information about local services, if you requested us to.
  • Protect our systems and data against malicious actors.


What we do with your data

The data we collect may be shared with payment providers, supplier organizations and other third party service providers to provide the services you requested.

 We will not:

  • Sell or rent your data to third parties.
  • Share your data with third parties for marketing purposes.

We may share your data if we are required to do so by legal authorities when properly served (ex: warrant) or to prevent fraud or other crime against SWhittlesey or others.


How long we keep your data

We will only retain your personal data for as long as:

  • It is needed for the purposes set out in this document.
  • Regulatory and legal requirements require us to.


Children’s privacy protection

Our services are not designed for, or intentionally targeted at, persons under 18 years of age. We do not intentionally collect or maintain data about anyone under the age of 18.


Where your data is processed and stored

We design, build and run our systems to make sure that your data is as safe as possible at any stage, both while it’s processed and when it’s stored (data is encrypted in transit and at rest).

Your personal data may, throughout the course of its processing at, be transferred outside of the United States.   Where this is the case, all appropriate technical and legal safeguards may be put in place to ensure that you are afforded the same level of protection as within the United States if not higher.


How we protect your data and keep it secure

We are committed to doing all that we can to keep your data secure. We have set up systems and processes to prevent unauthorized access or disclosure of your data.

 We also make sure that any third parties that we deal with keep all personal data they process on our behalf secure.


Your rights

You have the right to request:

  • Information about how your personal data is processed.
  • A copy of that personal data.
  • That anything inaccurate in your personal data is corrected immediately.

You can also:

  • Raise an objection about how your personal data is processed.
  • Request that your personal data is erased if there is no longer a justification for it.
  • Ask that the processing of your personal data is restricted in certain circumstances.

If you have any of these requests, get in contact with our Data Protection Officer.


Links to other websites may contain links to other websites.

This privacy policy only applies to, and does not cover nor pertain to other services and transactions that we link to.  You are fully responsible to review these services and their terms and conditions and privacy policies.


Following a link to another website

If you go to another website from this one, you are fully responsible to review their services, terms and conditions and privacy policies.


Following a link to from another website

If you come to from another website, we may receive information from the other website. We don’t use this data. You are fully responsible to review these services and their terms and conditions and privacy policies.


Changes to this policy

We may change this privacy policy at any time. In that case, the ‘last updated’ date at the bottom of this page will also change. Any changes to this privacy policy will apply to you and your data immediately.

If these changes affect how your personal data is processed, SWhittlesey may take reasonable steps to let you know.  You are fully responsible to review and be attentive to our privacy policy updates.


Contact us or make a complaint

Contact our Data Protection Officer if you:

  • Have any questions about anything in this document.
  • Think that your personal data has been misused or mishandled.


Data Protection Officer

Steve Whittlesey
Last updated January 5, 2024