Last updated: 20 June 2026
Privacy Policy
Plain-English draft — have a solicitor review before relying on this for paid subscriptions.Kino is a monthly performance-creative service operated by Joe Bromley as a sole trader, based in England. We take your privacy seriously. This policy explains what personal data we collect, why we collect it, how we use it, and your rights under UK data-protection law. If anything is unclear, email us at joebromley08@gmail.com.
1. Who we are
Controller: Joe Bromley trading as Kino, England & Wales.
Contact: joebromley08@gmail.com
2. What data we collect
We collect personal data in two ways — things you actively give us, and basic analytics we observe automatically.
Data you provide:
- Contact and enquiry data — when you fill in the contact form or email us directly, we receive your name, email address, your product URL, and the message you write. We use this to respond to your enquiry and, if you subscribe, to set up and manage your account.
- Brief and project data — once you become a client, you share product details, briefs, brand assets, landing pages, existing ads, and related creative inputs so we can produce and revise your creative deliverables. This is used solely to deliver your service.
- Billing data — when subscriptions go live, payment is processed by Stripe (our payment processor). We do not see or store your full card number — Stripe handles card data under their own PCI-DSS compliance and privacy policy.
Data we collect automatically:
- Site analytics — we use Vercel Web Analytics, a privacy-friendly, cookieless analytics tool provided by Vercel Inc. It records aggregate page-view counts, approximate country, and referrer. It does not set cookies, does not track you across sites, and does not fingerprint your device. No personally identifiable data is collected by analytics. You can learn more at vercel.com/docs/analytics/privacy-policy.
- Server logs — our hosting provider (Vercel) may retain standard web server logs (IP address, timestamp, browser type) for a short period for security and operational purposes. We do not use these for profiling.
3. Lawful basis for processing (UK GDPR)
| Processing activity | Lawful basis |
|---|---|
| Responding to your enquiry or contact form submission | Legitimate interests (responding to a request you initiated) |
| Delivering and managing your subscription service | Performance of a contract |
| Processing payment via Stripe | Performance of a contract |
| Aggregate, cookieless site analytics | Legitimate interests (understanding how the site is used, with no privacy impact on individuals) |
| Retaining project files after subscription ends | Legitimate interests (audit trail, ability to resolve disputes) |
4. How we use your data
- To respond to your enquiry and communicate about your project.
- To deliver, revise, and hand over your creative work.
- To bill your subscription and manage your account.
- To improve the quality of the service using aggregate, anonymised analytics.
We do not use your data for advertising, profiling, or any purpose unrelated to delivering the service.
5. Sharing and third parties
We do not sell, rent, or trade your personal data. We share it only with the following processors, each bound by their own data-protection obligations:
- Vercel Inc. — hosting and (cookieless) analytics. Vercel Privacy Policy.
- Stripe Inc. — payment processing when subscriptions are live. Stripe Privacy Policy.
- Email provider — our email service handles messages sent to joebromley08@gmail.com.
We may disclose data if required to do so by law or a regulatory authority.
6. International transfers
Vercel and Stripe are US-based companies. Where data is transferred outside the UK, it is protected by appropriate safeguards (such as the UK International Data Transfer Agreement or adequacy decisions). You can ask us for details at joebromley08@gmail.com.
7. Retention
- Enquiry data (no subscription): retained for up to 12 months in case you return to us, then deleted.
- Client project data: retained for the duration of your subscription and for 12 months after it ends (to handle disputes or re-engagement), then deleted or anonymised on request.
- Billing records: retained for 7 years as required by UK tax law.
- Analytics data: aggregate and anonymised; no personal-level retention.
8. Your rights under UK GDPR
You have 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 — request deletion of your data (subject to legal retention obligations).
- Restriction — ask us to restrict processing while a complaint is resolved.
- Objection — object to processing based on legitimate interests.
- Portability — receive your data in a structured, commonly used format.
To exercise any of these rights, email joebromley08@gmail.com. We will respond within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) — the UK's data-protection regulator.
9. No selling of data
We do not sell your personal data to any third party, and we never will.
10. Cookies
This site does not set any tracking cookies. The only storage used is that which your browser requires to serve the page (e.g. cached assets). Our analytics are cookieless by design.
11. Children
Our service is intended for businesses and is not directed at anyone under 18. We do not knowingly collect data from children.
12. Changes to this policy
If we materially change how we handle your data, we will update this page and revise the date at the top. Continued use of the service after a change constitutes acceptance.
13. Contact
Questions or requests: joebromley08@gmail.com.