Privacy notice
How we use business contact information, why we are allowed to, how long we keep it, and how to tell us to stop.
Who we are
Offpause is the trading name of Justyna Lopez Sanchez, a UK sole trader.
General contact: hello@offpause.co.uk
Privacy questions and rights requests: privacy@offpause.co.uk
Data protection complaints: complaints@offpause.co.uk
What information we use
Depending on how you interact with us, we may use business contact information such as your name, role, organisation, work telephone number, work email, public-source details, communication history, marketing preference or objection, client contact and billing information, and information needed to handle a privacy request, complaint or security incident.
We do not ordinarily receive or store full payment-card details: where a client pays by card, Stripe processes the payment details through its payment service. We do not intentionally collect special-category data, identity documents or unrelated private information for our ordinary dormant-quote reactivation service.
Why we use information, and our role
Offpause business development
- Purpose
- Identifying and contacting relevant UK commercial cleaning firms about Offpause.
- Our role
- Offpause is the controller.
- Lawful basis
- Legitimate interests — targeted business development using minimal relevant business contact information — subject to our signed assessment, the telephone marketing rules under PECR including TPS and CTPS screening, and your right to object to direct marketing.
Enquiries and client relationships
- Purpose
- Answering enquiries, taking requested pre-contract steps, administering contracts and campaigns, and keeping necessary business correspondence.
- Our role
- Offpause is the controller.
- Lawful basis
- Contract, or steps taken at your request, where you are the contracting individual; legitimate interests in communicating with corporate client contacts and administering the relationship; legal obligation where particular records must be kept by law.
Client dormant-prospect campaigns
- Purpose
- Carrying out a cleaning company’s campaign to revisit its own selected older enquiries and quotations.
- Our role
- The cleaning company is normally the controller and Offpause is normally the processor, acting on its documented instructions under Article 28 terms.
- Lawful basis
- The client determines the lawful basis for that underlying processing. Offpause does not invent a separate basis for information it processes only as a processor.
Screening and suppression
- Purpose
- Screening proposed telephone numbers, respecting TPS and CTPS results, and honouring objections so that people are not contacted again by mistake.
- Our role
- Processor for client-specific screening and suppression under client instructions; controller for our own minimum suppression record.
- Lawful basis
- Client instructions where we act as processor; legitimate interests in preventing inappropriate re-contact, alongside the applicable direct marketing and data protection duties, for our own record.
Billing and accounting
- Purpose
- Issuing invoices, processing payments and refunds, and keeping necessary accounting and business evidence.
- Our role
- Offpause is the controller.
- Lawful basis
- Contract where you are the contracting individual; legitimate interests in corporate billing administration; legal obligation for tax and accounting records where applicable.
Rights requests, complaints and security
- Purpose
- Recognising, investigating, responding to and evidencing privacy requests, complaints and security incidents.
- Our role
- Controller for our own activities; processor where we are assisting a client with information they control.
- Lawful basis
- Legal obligation where applicable, and legitimate interests in security, complaint handling and keeping accountability or legal-claim evidence.
Where we obtain information
For our own business development, we may obtain business contact information from an organisation’s own website, Companies House or other appropriate current public business sources. Where we do, we tell you the source when we first contact you and point you to this notice.
For client campaigns, the relevant cleaning company supplies or instructs us to process its own selected prior enquiry and quotation information. We may also receive information directly from you during calls, emails, contracts, payments or privacy correspondence.
When providing information is necessary
If you are a sole trader or individual client and we need particular contact, contract or billing information to take requested pre-contract steps or to perform an agreement, not providing it may mean we cannot enter into or administer the service. Some business and accounting information may also need to be retained to meet legal obligations.
If you receive marketing from Offpause, you are not required to give us any additional personal information merely because we have contacted you.
Direct marketing and your right to object
We use targeted rather than indiscriminate outreach. Before live marketing calls we apply the relevant telephone preference and suppression checks under our screening procedure. We identify Offpause, display a callback number, and stop the affected marketing when you object.
You can tell us at any time that you do not want direct marketing from Offpause, and we will stop. We may keep the minimum information necessary — usually the telephone number, the date and the scope of your objection — so that we do not contact you again by mistake. That information is never used to target you.
Who receives information
We use service providers for business email and storage, telephone calling, number screening, electronic signature, our own sales pipeline, and invoicing. These currently include Microsoft 365, VoIPstudio, Selectabase, PandaDoc, HubSpot and Stripe, each for the limited function described in our internal data map.
We do not place client dormant-prospect lists into PandaDoc, HubSpot or Stripe.
International processing
Access to identifiable information by a person stays with Justyna in the UK. No overseas human access is authorised.
Some technology providers may process or support information internationally as part of running their services. Before we use a provider for personal information, we review the relevant contractual and location safeguards, and we update this notice where a material change requires it.
How long we keep information
We keep personal information only for as long as reasonably needed for its purpose and for our legal and accountability needs.
- Raw client candidate files are intended to be short-lived.
- Selected campaign working information is normally removed no later than 30 days after a campaign closes, unless the client asks for sooner or a documented hold applies.
- Screening evidence has a 12-month default.
- Objections may be kept minimally for as long as needed to honour them.
- Core contracts and invoices may be kept for about six years.
- Complaint, rights-request and incident logs have a three-year default unless an active matter requires longer.
We review and minimise supporting detail rather than keeping whole campaign files indefinitely.
Your rights
Depending on the processing and the lawful basis, you may have rights of access, rectification, erasure, restriction, objection and, where applicable, data portability. You also have rights concerning certain solely automated decisions; Offpause does not use solely automated decision-making with legal or similarly significant effects in this service. Where we rely on consent for an activity, you may withdraw it.
You always have the right to object to direct marketing, and we will stop the affected marketing when you do.
To exercise any right, contact privacy@offpause.co.uk. If your request relates to information we process only on behalf of a cleaning company, we may need to pass it to that company or assist them as the controller — but we will not use that distinction as a reason to ignore your request.
Data protection complaints
You can complain to complaints@offpause.co.uk. We acknowledge a data protection complaint within the applicable 30-day maximum — sooner wherever we can — investigate it appropriately without undue delay, and tell you the outcome.
You also have the right to complain to the UK Information Commissioner’s Office. Their current guidance on how to do that is at ico.org.uk/make-a-complaint.
Security and automated decisions
We use access controls, business accounts, restricted Microsoft storage, number screening, and deletion and suppression procedures appropriate to this service. Call recording is off. We do not use automated decision-making that produces legal or similarly significant effects.
Changes to this notice
We update this notice when our services, providers, purposes or material data flows change.