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Privacy Policy

Carvello Woodscutt Limited

(trading as GradFinale Yearbooks)

Last updated: January 2026

We are committed to protecting your personal information and being transparent about how we use it. This Privacy Policy explains what personal data we collect, how we use it, the legal bases we rely on, and your rights under UK data protection law.

By using our website or submitting information to create a Yearbook profile, you agree to the practices described in this Privacy Policy.

1. Who we are

Carvello Woodscutt Limited (trading as GradFinale Yearbooks)
Registered in England & Wales (No. 4266938)
ICO Registration: Z6282497
Email: admin@gradfinale.co.uk
Address: Unit 3 Brook Court, Blakeney Road, Beckenham, Kent, BR3 1HG

We act as the Data Controller for the personal data collected via our website and Yearbook platform.

2. The personal data we collect

We collect and process the following categories of personal data:

2.1 Information you provide

  • Name
  • Email address
  • Institution, department and course
  • Profile photo(s) and additional photos
  • Text responses to Yearbook questions
  • Social media links (optional)
  • Contact details such as address or phone number (optional)
  • Other content you choose to include in your Yearbook profile

2.2 Information collected automatically

  • IP address
  • Browser type and version
  • Device information
  • Pages visited and actions taken on our website
  • Log data and activity timestamps collected via Google Analytics 4 and essential cookies

2.3 Payment information

Payments are processed securely by Pay360 (PayPoint). We do not receive or store your full card details.

2.4 Additional sources

  • Email communications sent to and from us
  • Address lookup data (via Google) if used during ordering
  • Emails delivered through SendGrid

3. How we use your personal data

We process your personal data for the following purposes:

  • Administering and operating our website and Yearbook creation platform
  • Creating your Yearbook profile and producing printed and digital Yearbooks
  • Taking payment for orders and issuing receipts
  • Contacting you about your Yearbook order or account
  • Providing digital Yearbook access
  • Fraud prevention and maintaining website security
  • Responding to enquiries and user support
  • Generating anonymised statistical reports about website usage
  • Meeting legal and accounting obligations
  • Where you submit content for publication in a Yearbook, we will publish this information in accordance with your selections

We do not use your data for direct marketing unless you have given explicit consent.

4. Legal bases for processing

Under the UK GDPR, we rely on the following lawful bases:

  • Contract – to create your Yearbook profile, process your order, and provide access to printed and digital Yearbooks
  • Consent – for publication of content you submit (text, images, social links)
  • Legitimate Interests – website security, analytics, fraud prevention, service improvement
  • Legal Obligation – tax, accounting and regulatory requirements

5. How long we keep your data (Retention periods)

Data Type

Retention Period

User accounts

12 months after the Yearbook is published

Yearbook content (submitted text & images)

12 months after the Yearbook is published (except where required for ongoing digital access)

Digital Yearbook access

We retain personal data for University services for the duration of the service and then delete/return it as instructed by the University, unless UK law requires retention

Backup copies

24 months after publication

Payment records

6 years (legal requirement)

Email correspondence

Up to 3 years, unless needed longer for legal reasons

After these periods, data is securely deleted unless required for legitimate legal purposes.

6. Sharing your personal data

We only share personal data when necessary for the operation of our service or where you have given permission.

6.1 With service providers

We may share data with trusted third-party providers who help us deliver our services, including:

  • Hosting.uk – website hosting (UK-based servers)
  • I-finity.co.uk – UK web development services
  • Microsoft Azure (UK regions) – Yearbook database infrastructure
  • Pay360 / PayPoint – payment processing
  • SendGrid – transactional email delivery
  • Google – address lookup tool
  • ISO 27001 accredited and UK-based production of physical books
  • Google Analytics 4 – site usage data (anonymised)

These providers act as data processors and may only use your data in accordance with our instructions.

6.2 Sharing with your institution (university / college / school)

We only share your content with your institution if you have opted in during signup. Sharing may be used for alumni engagement, marketing, or institutional archives.

6.3 Legal and compliance requirements

We may share information when required to comply with the law or to defend legal claims. We never sell your personal data.

7. International transfers of your personal data

Most of the personal data we process is stored and handled within the United Kingdom, and we take steps to ensure that your information remains protected at all times.

7.1 Microsoft Azure (UK regions only)

Our Yearbook database and platform infrastructure are hosted on Microsoft Azure, using UK-based data centres only (Azure regions UK-West and UK-South). This means that the core personal data we collect (including Yearbook content, profiles, and account details) is stored and processed exclusively within the UK.

Azure may provide remote technical support from outside the UK; where this occurs, access is strictly controlled and protected by Standard Contractual Clauses and equivalent safeguards.

7.2 When international transfers may occur

Some of our service providers operate globally or use systems located outside the UK/EEA. As a result, limited personal data may be transferred internationally — for example:

  • SendGrid (Twilio) (transactional emails; USA-based infrastructure): name, email address, communication metadata
  • Google Analytics 4 (pseudonymised analytics data processed globally): IP addresses, browser and device information, geolocation data, and user interactions with the website (page views, clicks, conversions)

These services do not host your Yearbook content. We only use providers that implement robust compliance frameworks. Relevant Data Protection Agreements can be found here:

7.3 Safeguards we apply to transfers

Whenever your data is transferred outside the UK, we ensure that one or more of the following legally recognised safeguards are in place:

    1. UK Adequacy Regulations – transfer to countries the UK Government recognises as providing an adequate level of protection

    2. Standard Contractual Clauses (SCCs) with the UK Addendum – contractual terms approved by the UK ICO ensuring equivalent data protection standards

    3. Binding Corporate Rules – for providers operating a global internal data protection framework

    4. Technical safeguards, such as:

    • encryption in transit and at rest
    • pseudonymisation
    • strict access controls
    • audit logging and monitoring

These measures help ensure that any international transfer affords protection essentially equivalent to UK data protection law.

7.4 Transfer Risk Assessments (TRAs)

Where required, we conduct Transfer Risk Assessments in accordance with UK GDPR and ICO guidelines. This includes evaluating:

  • the laws of the destination country
  • the provider's security standards
  • the likelihood of unauthorised access
  • the nature of the personal data transferred
  • whether the transfer is necessary for the service we provide

We only proceed where we determine that your data can be protected to an appropriate standard.

7.5 Publication of Digital Yearbooks (global accessibility)

Yearbook content you submit for publication — such as your name, photo, and written profile — may be included in printed and/or digital Yearbooks.

Digital Yearbooks are accessible online to individuals with valid authentication. However, because they are published on the internet, they may be accessed from anywhere in the world.

Once published, we cannot fully control:

  • how other authorised users view or use your content
  • downloads, screenshots, or onward sharing by others

By submitting content for publication, you acknowledge that your information will be accessible internationally.

7.6 Summary

Although some personal data may be transferred outside the UK, we ensure that:

  • transfers are limited
  • data is minimised
  • strong technical and contractual protections are in place
  • processing always complies with the UK GDPR

8. Cookies and analytics

We use:

  • Essential cookies – required for website functionality
  • Google Analytics 4 cookies – to collect anonymised usage data

You can control cookies through your browser settings. Blocking essential cookies may affect functionality.

9. Security of your personal data

We use technical and organisational measures to protect your data, including:

  • Encrypted data transmission including a secure (SSL) connection between the user's browser and our website servers (https)
  • Password and firewall protection for administrative access
  • Secure servers to store your data on
  • Access controls that ensure access to personal data is limited to authorised personnel only
  • Patch and vulnerability management to ensure the most up to date patches are applied and security updates are deployed

It is important to state however that no transmission over the internet is completely secure, and we cannot guarantee absolute protection.

You are responsible for keeping your login details confidential.

10. Your rights

Under UK data protection law, you have the right to:

  • Access your personal data
  • Request correction of inaccurate information
  • Request deletion of your data
  • Restrict or object to processing
  • Withdraw consent for content publication
  • Request transfer of your data
  • Lodge a complaint with the ICO (www.ico.org.uk)

To exercise these rights, email admin@gradfinale.co.uk. We may need to verify your identity (e.g., Yearbook registration details).

11. University / Institution Projects

For personal data which is not collected directly on our website — i.e. where we provide university yearbook services to a University / institution — the University / institution is the Data Controller and Carvello Woodscutt act as Processor.

In these circumstances:

  • we process that data only on the University's documented instructions and under an Article 28 data processing agreement
  • rights requests (access/erasure/etc.) should be made to the University (as Controller); if requests are received by us, we will forward them promptly and assist the University as required under the Article 28 contract
  • please refer to the University's privacy policy and information available on the University's website for controller-level details (such as purposes/lawful basis/rights). Please contact us at admin@gradfinale.co.uk if you need any help finding this information
  • no sub-processors are engaged without the University's prior written authorisation, and equivalent obligations are flowed down to sub-processors

12. Third-party websites

Our website may contain links to other sites. We are not responsible for their privacy practices.

13. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be published on our website. Significant changes may be notified by email.

14. Contact us

For questions about this policy or how we use your data:

Email: admin@gradfinale.co.uk
Address: Unit 3 Brook Court, Blakeney Road, Beckenham, Kent, BR3 1HG

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