Privacy Policy.

APP/ART is a two person brand and digital studio in Gibraltar. We build positioning, identity and websites for deep tech companies.

APP/ART is registered in Gibraltar under company number BL268182. Registered office: 29 Miami Court, Harbour Views, GX11 1AA, Gibraltar.

For the purposes of data protection law, APP/ART is the data controller for the information described in this policy.

Questions, or a request about your data: hello@appart.gi

This policy covers data about you: what we hold when you visit this site, enquire about work, or engage us. We decide what happens to it, so we are the controller.

It is not about data your customers give to systems we build for you. There you are the controller and we act on your instructions. That is covered under "Data we handle for clients" below.

We keep this short on purpose. If anything is unclear, email and we will explain it properly.

When you contact us or engage us:

• Name and contact details, including email and phone number.
• What you tell us about your company and your project, including material you send us to read.
• Billing details and payment records.
• Our correspondence with you.

When you visit this site:

• Standard technical data your browser sends, including IP address, device and browser type, the pages you viewed and the site you arrived from.
• Page analytics, described under "Analytics" below.

We do not ask for special category data, and we would rather you did not send it.

Why we use it, and on what basis

• To quote for, deliver and invoice the work you engage us for. Basis: performance of a contract.
• To answer an enquiry. Basis: our legitimate interest in replying to people who contact us.
• To keep a record of work we have done, including in our portfolio. Basis: legitimate interest.
• To meet Gibraltar accounting and tax requirements. Basis: legal obligation.
• To send you an email you asked to receive. Basis: your consent, withdrawable at any time.

We do not sell or rent personal data. We do not use it to train machine learning models, and we do not allow our suppliers to.

Clients send us things before any contract exists: decks, spec sheets, drafts, internal documents. We treat all of it as confidential, it stays with the two of us, and we do not publish anything from it without your written agreement. If you would rather have an NDA in place first, send it to hello@appart.gi and it comes back signed before you tell us anything.

We use Framer's built in page analytics to count visits and see which pages people read. It does not use cookies and does not create a persistent identifier for you. We do not run advertising, retargeting or profiling tags on this site.

This site uses the cookies it needs to work and to remember your choices. It does not use advertising cookies. If that ever changes we will ask for your consent before setting them, and we will update the date at the top of this page.

We keep the list short and we name them:

• Framer, which hosts this website and provides its page analytics.
• Google, whose Workspace we use for email and documents. If you write to us, that correspondence is stored there.

That is the whole list. Each acts under its own terms and its own privacy policy, and we do not add to it without updating this page.

Some of our work involves building things that collect data from other people: contact forms, demo requests, newsletter sign ups, and occasionally a connection into a system you already run.

Where that happens you remain the controller of that data and APP/ART acts as your processor. We process it only on your written instructions, only for as long as the engagement requires, and we agree the specifics in writing before the work begins.

Some of the tools above are based outside Gibraltar. Where personal data is transferred internationally we rely on the safeguards those providers have in place, such as standard contractual clauses or an adequacy decision.

Project and communication records: for the engagement and a reasonable period after it, in case you come back or a question arises about past work.

Financial records: as long as Gibraltar tax and accounting rules require.

Enquiries that do not become projects: two years, then deleted.

Anything we no longer need is deleted.

We take reasonable technical and organisational steps to protect your information from unauthorised access, disclosure or misuse. No transmission over the internet is completely secure, and we will not pretend otherwise. If a breach affects your data and is likely to present a risk to you, we will tell you and the Gibraltar Regulatory Authority.

You can ask us to:

• Give you a copy of the data we hold about you.
• Correct or update it.
• Delete it.
• Restrict or object to how we use it.
• Send it to you, or to someone else, in a portable format.
• Stop using it where we relied on your consent.

Email hello@appart.gi. We respond within one month, and there is no charge.

If you are unhappy with how we have handled your data, tell us first and we will try to put it right.

You also have the right to complain to the Gibraltar Regulatory Authority, which acts as Information Commissioner and is the supervisory authority for data protection in Gibraltar. Their site is gra.gi

We update this policy when what we do changes. The date at the top is the date of the current version.

Contact

hello@appart.gi