Privacy Policy
Hunter Admin
Effective date: 11th August 2026 Version: 2.0 Supersedes: the Hunter & Co. Administrative Support privacy policy
1. Who we are
Hunter Admin is the trading name of Gemma Hunter, a sole trader based in West Sussex, providing business operations support to UK SME founders.
We are the data controller for the personal data described in this policy.
Contact for anything in this policy: Email: info@hunteradmin.org Post: 134 Timberleys, Littlehampton, West Sussex, BN17 6QE Phone: 07522 261212
We are registered with the Information Commissioner's Office under registration number [ICO NUMBER TO BE INSERTED].
We have not appointed a Data Protection Officer, as we are not required to. Any question about data protection comes directly to Gemma.
2. Two different situations, and why the difference matters
There are two distinct ways we handle personal data, and different rules apply to each.
When we decide how data is used, we are the controller. This covers your own details as an enquirer, client, subscriber or website visitor. This policy explains what we do with that data.
When we handle data on a client's behalf, we are the processor. When we run a client's inbox, CRM or calendar, we are handling personal data belonging to their business, on their instructions. We do not decide what happens to it and we do not use it for our own purposes. That relationship is governed by the data processing terms in Schedule 2 of our Terms and Conditions.
If your data reached us because you are a customer, supplier or contact of one of our clients, that client's privacy policy applies to you, not this one. We are happy to tell you who they are if you contact us.
3. What we collect and why
If you enquire about working with us
What: name, business name, email address, phone number, and whatever you tell us about your business in the enquiry or on a call.
Why: to respond to you, understand whether we can help, and prepare a proposal.
Lawful basis: legitimate interests. We have an interest in responding to people who approach us, and you would expect us to.
If you become a client
What: contact and business details, billing information, correspondence, records of the work, notes from sessions, and any information about your business you share with us.
Why: to deliver the Services, communicate with you, invoice you, and keep proper business records.
Lawful basis: performance of our contract with you. Some of it, particularly financial records, is also a legal obligation.
If you take the Founder Dependency Score
What: your answers, and your email address only if you choose to give it.
Why: to generate your result and, if you have asked us to, to send it to you.
Lawful basis: consent where you give us your email address. You can see your result without providing one.
If you subscribe to Behind the Business
What: name and email address.
Why: to send you the newsletter.
Lawful basis: consent. Every issue includes an unsubscribe link and you can withdraw at any time.
Our newsletter is hosted on Substack. When you subscribe, your details are held by Substack under their own privacy policy as well as ours.
If you buy a digital product, a place at an event, or a service
What: name, email address, billing address, order details and payment confirmation.
Why: to fulfil the order, provide access, and meet our tax and accounting obligations.
Lawful basis: performance of contract, and legal obligation for financial record-keeping.
We do not see or store your full card details. Payments are handled by our payment providers.
If you attend a live session or event
What: your name, the fact of your attendance, anything you contribute, and a recording where one is made.
Why: to deliver the session and to provide replays where these form part of what you bought.
Lawful basis: performance of contract. We will always tell you before recording begins.
If you visit our website
What: IP address, browser and device information, pages viewed, and how you arrived.
Why: to keep the site working and understand how it is used.
Lawful basis: legitimate interests for essential functioning, and consent for analytics and tracking cookies.
4. Marketing
We may send business-related information to existing clients about services similar to those they have already bought. You can opt out at any time.
For everyone else, we only send marketing where you have asked for it.
We treat sole traders and partnerships the same as individuals for marketing purposes. This is deliberate. Much of our audience runs unincorporated businesses, and we would rather ask for consent than rely on a technicality.
Every marketing email carries an unsubscribe link. Opting out of marketing does not stop service messages about work in progress or an order you have placed.
5. Who we share data with
We do not sell personal data, and we do not share it for anyone else's marketing.
We share it with the suppliers who help us run the business:
- Website and hosting: Webador
- Payments: Stripe, PayPal
- Client management and proposals: HoneyBook
- Newsletter: Substack
- Video sessions: Zoom
- Email and file storage: Google Workspace & Outlook
- Accounting: FreeAgent
- Website analytics: Google Analytics
Each of these acts on our instructions under a written agreement.
We also use associates from time to time to help deliver client work. Associates are bound by written confidentiality obligations and handle data only as needed for the work.
We will disclose personal data where the law requires it, or to our professional advisers where necessary.
6. Sending data outside the UK
Some of our suppliers are based outside the UK, mainly in the United States.
Where data is transferred outside the UK, we rely on the safeguards required by law, which are usually UK International Data Transfer Agreements or Addenda, or a finding by the UK government that the destination country provides adequate protection.
You can ask us for details of the safeguards that apply to a particular supplier.
7. How long we keep it
- Enquiries that do not become work - 12 months from last contact
- Client records, contracts and correspondence - 6 years after the engagement ends
- Invoices and financial records - 6 years after the end of the tax year they relate to
- Session recordings - 12 months, unless replay access has been sold for longer
- Newsletter subscriptions - Until you unsubscribe
- Website analytics - As set by the analytics provider
- Client data we hold as processor - Deleted or returned when the engagement ends, in line with Schedule 2 of our Terms
We keep client records for six years because that is the period during which a contractual claim can be brought, and financial records for six years because HMRC requires it.
When a retention period ends, we delete the data or anonymise it so it can no longer identify anyone.
8. Your rights
Under UK data protection law you have the right to:
- Be informed about how we use your data, which is what this policy is for
- Access a copy of the personal data we hold about you
- Have inaccurate data corrected
- Have data erased, where we no longer have a reason to hold it
- Restrict processing, in certain circumstances
- Object to processing based on legitimate interests, and to direct marketing at any time
- Data portability, where processing is based on consent or contract and is automated
- Withdraw consent at any time, where consent is what we rely on
To exercise any of these, email info@hunteradmin.org. We will respond within one month. If a request is complex we may extend that by up to two months, and we will tell you if so.
There is no charge. We may ask you to confirm your identity before we release information.
If your data is held by us as a processor on a client's behalf, we will pass your request to that client, as they are the one who must respond.
9. Cookies and tracking
Our website uses cookies. Some are essential for the site and shop to work. Others help us understand how the site is used, or come from third-party tools embedded in our pages.
Non-essential cookies are only set with your consent, and you can change your choice at any time through the cookie settings on our site.
10. How we keep data secure
We use appropriate technical and organisational measures, including access controls, strong and unique passwords, multi-factor authentication where available, encrypted storage and reputable suppliers.
Where we are given access to a client's systems, we use the minimum permissions needed, and we ask clients to revoke access when an engagement ends.
No system is completely secure. If a breach occurs that is likely to result in a risk to people's rights, we will report it to the ICO within 72 hours and tell the people affected where required.
11. Children
Our services are for businesses and are not directed at children. We do not knowingly collect data about anyone under 18. If you believe we have, contact us and we will delete it.
12. Automated decision-making
We do not make decisions about you by automated means alone, and we do not use profiling that produces legal or similarly significant effects.
The Founder Dependency Score generates a result from the answers you give. It is a guidance tool, not a decision about you, and no consequence follows from it other than the result you see.
13. Changes to this policy
We update this policy when our practices change. The version in force is always the one published here, with the effective date at the top.
Where a change materially affects how we use data we already hold, we will tell people directly.
14. Complaints
If you are unhappy with how we have handled your data, tell us first at info@hunteradmin.org. We would rather put it right ourselves.
You also have the right to complain to the Information Commissioner's Office at any time.
Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Helpline: 0303 123 1113 ico.org.uk
Gemma Hunter trading as Hunter Admin info@hunteradmin.org
Last updated: 11th August 2026