Privacy notice

Last updated: 18 October 2026 (draft, not yet in force). This covers (1) businesses we contact about our services (by email, or for sole traders by phone or in person), (2) our clients and (3) visitors to reefstudios.ie.

Who we are

Darragh Condell, Web Designer and sole trader, Enterprise Centre, Unit 9, Kilmallock Road, Flankerhouse, Limerick V94 TY82, Ireland (website: reefstudios.ie). Darragh Condell is the controller of the data below. Contact for anything privacy-related: privacy@reefstudios.ie. For anything else: hello@reefstudios.ie. (We're a one-person business and aren't required to appoint a Data Protection Officer.)

1. If we contacted you about a website (outreach)

Who we contact, and how: we only send outreach emails to limited companies, at the business email address the company publishes. We don't cold-email sole traders. If you're a sole trader, Darragh may instead phone you on your published business number or call in to your business in person. Calls and visits are always from Darragh himself, and he'll tell you who he is and where he found your details.

What we hold: your business name, the published business email address we wrote to (companies) or the published business phone number we called (sole traders), the name of the contact person if it was published with it, your business's public details (type of business, town, opening hours, public phone number, address, whether you have a website and how it performs), where we found your details, our emails to and from you, and a short note of any call or visit (for example "not interested" or "send a preview").

Where we got it (GDPR Article 14): only from public business sources: your own website, your business's public social media page, public business directories whose terms allow this, or OpenStreetMap (© OpenStreetMap contributors, ODbL). Each email tells you the exact source we used for you. If we call or visit, just ask and Darragh will tell you. We don't buy lists and we don't scrape Google Maps.

Why and on what basis: to offer your business a website, under our legitimate interests (GDPR Art. 6(1)(f)) in promoting our services to businesses. Emails to limited companies' published business addresses are permitted by Regulation 13 of the ePrivacy Regulations (S.I. 336/2011). We only phone published business numbers, never personal mobiles, and we don't call any number listed on the National Directory Database as opted out of marketing calls, or any number whose owner has asked us not to call. We've assessed that a small amount of relevant, clearly identified contact, with an easy way to say no, doesn't override your interests. You can ask for a copy of that assessment.

Your preview site: if we made a sample website for your business, it's built only from public facts and stock photos, published at an unlisted address hidden from search engines, and deleted within 30 days if you're not interested (sooner if you ask).

How much we contact you: limited companies get at most one first email and one follow-up. Sole traders get at most one call or one visit, and we only follow up if you ask us to. If you don't reply or aren't interested, we stop.

Saying no: reply "no thanks" or "stop", tell Darragh on the call or visit, or email privacy@reefstudios.ie. We'll stop immediately and never contact you again. To make sure of that, we keep only your email address or phone number (and business name/domain) on a do-not-contact list, permanently. That's the only data we keep after you object.

How long we keep it: if you don't go ahead, we delete your data 6 months after our last contact (apart from the do-not-contact list if you objected). If you become a client, see section 2.

2. Clients

What we hold: contact names, email, business details, the content you send us for your site, invoices and payment records, our emails, and short notes of any calls or meetings we have with you. Why: to deliver our contract with you (Art. 6(1)(b)) and to meet legal and tax obligations (Art. 6(1)(c)). How long: for the length of our agreement, then accounting records for 6 years as Irish tax law requires. Other data is deleted within 90 days of the end of the agreement. For your website visitors' data (e.g. enquiry-form messages), you're the controller and we're your processor. See clause 8 of our Terms of Service.

3. Visitors to reefstudios.ie

We don't use analytics cookies, advertising trackers or embedded social media. Our host (Cloudflare) processes technical data such as IP addresses for security and to deliver the site. If you email us, we use your email to reply (legitimate interests). If you ask for a call or a visit, we use the phone number or address you give us only to arrange it.

Who we share data with

Only service providers who process it for us: Cloudflare (Cloudflare, Inc.: website hosting, security and email forwarding) and Google (Google Ireland Ltd: our Gmail inbox). Emails sent to our @reefstudios.ie addresses are passed on by Cloudflare (Cloudflare, Inc.) to a Gmail inbox run by Google (Google Ireland Ltd), where they're stored and answered. Both may process data outside the EEA under standard contractual clauses. We never sell or rent personal data.

Your rights

You can ask to access, correct or delete your data, to restrict or object to our use of it (including an absolute right to object to direct marketing), and, where it applies, to data portability. Email privacy@reefstudios.ie and we'll respond within one month. We don't make automated decisions about you with legal or similar effects. We use software (including AI tools) to help find businesses and draft emails, but a person reviews every email before it's sent, and every call or visit is made by Darragh himself.

You can complain to the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28 (www.dataprotection.ie). We'd appreciate the chance to sort it out first.

Changes

We'll update this notice if our practices change and change the date at the top.