Privacy Policy (GDPR Compliant Template)
1. Introduction
This Privacy Policy explains how Small Change LTD. (“we”, “us”, “our”) collects, uses, and protects your personal data when you use our website, services, or interact with us.
We are committed to protecting your privacy and handling your data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Irish data protection laws.
Data Controller:
Small Change Ltd
North Tipperary Green Enterprise Park
Cloughjordan
Co. Tipperary
E53 VP86
heywhatsup@smallchange.ie
085 110 6518
What Data We Collect:
We may collect the following types of personal data:
Information You Provide
Name
Email address
Phone number
Billing and payment details
Messages or enquiries you send us
Course registration or booking details (if applicable)
Automatically Collected Data
IP address
Browser/device information
Website usage data (cookies, analytics)
Marketing Data
Preferences for receiving marketing communications
Interaction with emails or ads
3. How We Use Your Data
We process your personal data for the following purposes:
Providing products or services
Processing bookings, orders, or payments
Responding to enquiries or customer support
Improving our website/services
Marketing communications (where consent exists)
Legal compliance and fraud prevention
4. Legal Basis for Processing (GDPR Article 6)
We rely on:
Contractual necessity — to provide purchased services
Legal obligation — accounting, tax, compliance
Legitimate interests — business improvement, customer service
Consent — marketing emails, cookies where required
You can withdraw consent at any time.
5. Data Sharing
We may share data with:
Payment processors
Email marketing providers
Website analytics services
Professional advisors (legal/accounting)
Authorities where legally required
We never sell your personal data.
6. International Transfers
If data is transferred outside the EEA, we ensure appropriate safeguards such as:
EU Standard Contractual Clauses
Adequacy decisions
Secure processing agreements
7. Data Retention
We retain personal data only as long as necessary:
Customer records: typically up to 6 years (tax/legal)
Marketing data: until consent withdrawn
Enquiries: typically 12–24 months
8. Your GDPR Rights
You have the right to:
Access your personal data
Rectify inaccurate data
Erase data (“right to be forgotten”)
Restrict processing
Data portability
Object to processing
Withdraw consent at any time
Lodge a complaint with the Irish Data Protection Commission
Contact: heywhatsup@smallchange.ie
9. Cookies
Our website may use cookies for:
Website functionality
Analytics
Marketing optimisation
You can manage cookie preferences through your browser or our cookie banner.
10. Data Security
We implement appropriate technical and organisational measures to protect personal data, including:
Secure hosting and encryption
Access controls
Staff confidentiality obligations
Regular security reviews
11. Third-Party Links
Our website may link to external websites. We are not responsible for their privacy practices.
12. Changes to This Policy
We may update this Privacy Policy periodically. The latest version will always appear on our website with an updated effective date.
13. Contact Us
For privacy enquiries:
Small Change Ltd
North Tipperary Green Enterprise Park
Cloughjordan
Co. Tipperary
E53 VP86
heywhatsup@smallchange.ie
085 110 6518

