Privacy Policy
Underwaterpistol Ltd Privacy Policy
1. Who we are
This Privacy Policy explains how Underwaterpistol Ltd ("Underwaterpistol", "we", "us", "our") collects, uses and shares personal data when you use our website, download our content, interact with our marketing, or work with us as a client, partner or supplier.
Underwaterpistol Ltd is the data controller for this website and our own marketing and client relationship activities. Our details are:
• Company: Underwaterpistol Ltd
• Registered office: 44 Church Street, Warrenpoint, Newry, Northern Ireland, BT34 3HN, United Kingdom
• Office: 151 Wardour Street, London, W1F 8WE, United Kingdom
• Email: info@underwaterpistol.com
• Phone: +44 203 467 7614
• Website: https://www.underwaterpistol.com
If you have questions about this policy, contact us using the details above.
2. What data we collect
2.1 Information you provide to us
We collect personal data that you voluntarily provide, for example when you:
• Fill in forms on our website (e.g. contact forms, resource downloads, event registrations).
• Subscribe to our newsletters or marketing emails.
• Request or receive proposals, statements of work or contracts from us.
• Communicate with us by email, phone, video call or in person.
This may include:
• Identification and contact details: name, job title, company, email address, phone number.
• Professional information: role, team, areas of responsibility, preferences and interests related to ecommerce and Shopify.
• Business relationship information: details about your project, budget, objectives, and correspondence with us.
• Event and content information: registrations, attendance and interactions with our events, webinars and downloads.
2.2 Information we collect automatically
When you visit our website, we automatically collect certain information about your device and how you interact with our site.
This includes:
• Device and technical data: IP address, browser type, operating system, device identifiers.
• Usage data: pages visited, links clicked, time spent, referring/exit pages, and similar analytics data.
Cookie and tracking data: identifiers associated with cookies or similar technologies used for analytics and advertising (see "Cookies and similar technologies" below).
2.3 Information from third parties
We may receive personal data about you from:
• Our partners (e.g. Shopify and key app partners) where you have interacted with joint campaigns or content.
• Professional networking platforms (e.g. LinkedIn) when you interact with our content or contact us.
• Publicly available sources (e.g. your company website) and reputable B2B data providers, for prospecting and account-based marketing in line with data protection law and ICO guidance on B2B marketing.
3. How we use your data and legal bases
We only process personal data where we have a valid legal basis under UK GDPR/EU GDPR.
3.1 To operate our website and provide information you request
• Purposes: responding to enquiries, arranging calls, providing proposals, sending resources you request.
• Legal basis: performance of a contract or steps taken at your request before entering into a contract; or our legitimate interests in running our business and responding to enquiries.
3.2 To manage client and partner relationships
• Purposes: onboarding and servicing clients, managing projects and retainers, communicating with client teams, managing partner relationships.
• Legal basis: performance of a contract and our legitimate interests in delivering and improving our services.
3.3 To send marketing communications
• Purposes: sending insights, resources, event invitations and other marketing about our services that may be relevant to you in your professional role.
• Legal basis:
- Consent, where required (e.g. some email subscription forms).
- Legitimate interests in B2B marketing to relevant contacts, where permitted and where you would reasonably expect it, subject to your right to opt-out at any time.
You can unsubscribe from marketing emails at any time using the link in the email or by contacting us.
3.4 To run analytics, improve our site and measure campaigns
• Purposes: understanding how visitors use our website, improving content and UX, evaluating the effectiveness of campaigns and channels.
• Legal basis:
- For strictly necessary cookies: our legitimate interests in operating a secure, functional website.
- For analytics and advertising cookies in the UK/EEA: your consent, collected through our cookie banner or preference centre.
3.5 To run advertising and retargeting
• Purposes: serving and measuring digital advertising (e.g. via Meta, Google, LinkedIn or similar platforms) and building audiences based on website visits or interactions with our content.
• Legal basis: your consent to the use of advertising cookies/tracking where required, and our legitimate interests in promoting our services to relevant audiences in a proportionate way.
You can change your cookie preferences at any time via our cookie banner or browser settings and use the platform-specific opt-out tools provided by the major ad platforms.
3.6 To maintain security, prevent fraud and comply with law
• Purposes: protecting our website and systems, detecting and preventing misuse or fraud, complying with legal obligations (e.g. tax, accounting, regulatory).
• Legal basis: our legitimate interests in keeping our services secure and complying with our legal obligations.
4. Cookies and similar technologies
We use cookies and similar technologies (such as pixels and tags) on our website to improve your experience, understand how you use our site, and deliver relevant marketing.
4.1 What are cookies?
Cookies are small text files that are placed on your device when you visit a website. They help the website remember information about your visit, such as your preferences and actions. Similar technologies like pixels and tags work in comparable ways to track interactions with our website and emails.
4.2 Types of cookies we use
Strictly necessary cookies
These cookies are essential for our website to function properly. They enable core functionality such as security, network management, and basic site operations. Without these cookies, certain parts of our website may not work. These cookies do not require your consent as they are necessary for the site to operate.
Examples include:
• Security and authentication cookies
• Load balancing cookies
• Cookie consent preference cookies
Analytics and performance cookies
These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. We use this data to improve our website's performance and user experience.
Examples include:
• Google Analytics cookies that track page views, session duration, and user journeys
• Performance monitoring tools that help identify technical issues
• Heatmap and scroll-tracking tools that show how users navigate our content
Marketing and advertising cookies
These cookies are used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. We use these cookies to build a profile of your interests and show you relevant content on our site and on third-party websites.
Examples include:
• Meta (Facebook) Pixel for retargeting and measuring ad performance
• Google Ads cookies for conversion tracking and remarketing
• LinkedIn Insight Tag for professional audience targeting
• Third-party advertising platform cookies
4.3 Cookie consent and your choices
For visitors in the UK and European Economic Area (EEA), we only set analytics and advertising cookies with your consent. When you first visit our website, you will see a cookie banner that allows you to:
• Accept all cookies
• Reject non-essential cookies
• Customise your cookie preferences
You can change your cookie preferences at any time by accessing the cookie preference centre available in the footer of our website or through the cookie banner that may appear on subsequent visits.
4.4 Managing cookies through your browser
Most web browsers allow you to control cookies through their settings. You can set your browser to:
• Block all cookies
• Block third-party cookies only
• Delete cookies when you close your browser
• Alert you when a cookie is being set
Please note that blocking or deleting cookies may affect your ability to use certain features of our website. For more information about managing cookies in your browser, visit www.allaboutcookies.org.
4.5 Opting out of advertising cookies
You can opt out of targeted advertising through the following platform-specific tools:
• Google Ads: https://adssettings.google.com
• Meta (Facebook): https://www.facebook.com/settings/?tab=ads
• LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
• Digital Advertising Alliance opt-out portal: http://optout.aboutads.info
Please note that opting out of advertising cookies does not mean you will stop seeing advertisements; it means the advertisements you see will be less relevant to your interests.
4.6 How long do cookies last?
Cookies may be either 'session' cookies or 'persistent' cookies:
• Session cookies: These are temporary cookies that expire when you close your browser.
• Persistent cookies: These remain on your device for a set period or until you delete them. The duration varies depending on the cookie, ranging from a few days to several years. Analytics cookies typically last for 1-2 years, while advertising cookies may last for up to 13 months.
5. How we share personal data
We do not sell your personal data. We may share it with:
• Service providers and processors who help us operate our business, such as:
- Website hosting, analytics and performance tools.
- CRM and marketing platforms, email delivery and event tools.
- Project management, collaboration and productivity tools.
• Partners we collaborate with on campaigns, events or content (for example Shopify or app partners), where you have registered for a joint activity or have been informed at the point of registration that your data may be shared.
• Professional advisers (lawyers, auditors, accountants) where necessary for our legitimate interests and compliance.
• Authorities, regulators or law enforcement where we are required to do so by law or reasonably need to protect our rights or those of others.
Where we use processors, we ensure they only process personal data under our instructions and subject to appropriate contractual safeguards.
6. International transfers
Some of our service providers and partners are located outside the UK and European Economic Area (EEA), or process data in those locations (for example, cloud hosting, analytics and marketing platforms).
When we transfer personal data internationally, we do so in accordance with data protection law, using safeguards such as:
• Adequacy regulations or decisions (where the destination country is recognised as providing an adequate level of protection).
• Standard Contractual Clauses (SCCs) or equivalent approved contractual terms.
• Other appropriate safeguards permitted by UK GDPR/EU GDPR.
You can contact us for more information about the specific safeguards applied to your data.
7. How long we keep personal data
We keep personal data only for as long as needed for the purposes described in this policy, and to meet any legal, accounting or reporting obligations.
In general:
• Website enquiry and prospect data: kept for as long as we actively engage with you and for a reasonable period afterwards (typically up to 3 years) for business records and to understand our sales pipeline, unless you ask us to delete it earlier where we have no overriding need to keep it.
• Client and contract data: kept for the duration of the client relationship and for a period afterwards (typically up to 6 years) to comply with legal obligations and to exercise or defend legal claims.
• Marketing data: kept until you unsubscribe or object, or until we determine it is no longer accurate or relevant, at which point we will delete it or anonymise it.
• Technical and analytics data: kept for periods consistent with our analytics and security tools' default retention, after which it is deleted or anonymised.
8. Your rights
If you are in the UK or the EEA, you have certain rights in relation to your personal data, subject to conditions and exemptions in law.
These include the right to:
• Access: request a copy of the personal data we hold about you.
• Rectification: ask us to correct inaccurate or incomplete data.
Erasure: ask us to delete your data in certain circumstances ("right to be forgotten").
• Restriction: ask us to limit how we use your data in certain circumstances.
• Portability: receive your data in a structured, commonly used, machine-readable format and/or ask us to transfer it to another controller where technically feasible.
• Objection: object to our processing where we rely on legitimate interests, including profiling, or to direct marketing at any time.
• Withdraw consent: where we rely on your consent, withdraw it at any time (this will not affect the lawfulness of processing before withdrawal).
To exercise any of these rights, contact us using the details above. We may need to verify your identity before responding.
You also have the right to lodge a complaint with your local supervisory authority. In the UK, this is the Information Commissioner's Office (ICO): www.ico.org.uk.
9. Our role as processor for clients
For most of our client services we act as a data processor when handling end-customer or user data on behalf of clients using Shopify and related tools. In those cases, our clients are the data controllers and their privacy policies and instructions govern how that personal data is used.
Our responsibilities and obligations towards client data are set out in our contracts and Data Processing Agreements with those clients and are not fully described in this website Privacy Policy.
10. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or destruction, taking into account the nature of the data and the risks involved.
However, no internet-based service can be completely secure, so we cannot guarantee absolute security.
11. Changes to this policy
We may update this Privacy Policy from time to time, for example to reflect changes in our services, technologies, or applicable law.
When we make material changes, we will update the "last updated" date and may take additional steps to inform you where appropriate (for example, by email or a notice on our website).
Last updated: January 2026