Last reviewed: 2026-08-06
Who is responsible for your information
Andrew Smith is the controller of personal information processed through Tough Smudge. Privacy enquiries and complaints can be sent to go@tough-smudge.uk.
What this notice covers
This notice covers tough-smudge.uk, enquiries, sponsorship and partnership discussions, supporter communications, event activity and any account, membership or shop features that are switched on below.
Information collected
- Website and security information: IP address, browser/device information, request time, requested address and security logs generated by hosting and WordPress.
- Enquiries and partnerships: your name, contact details, organisation, message and correspondence.
- Privacy requests and complaints: information needed to identify, investigate and answer the request.
Why information is used
| Purpose | Likely lawful basis |
|---|---|
| Operating, securing and diagnosing the website | Legitimate interests and legal obligations |
| Answering enquiries and discussing sponsorship or partnerships | Steps at your request before a contract, contract, or legitimate interests |
| Providing an account, membership, order or requested service | Contract and legal obligations |
| Sending optional marketing or supporter updates | Consent, or the limited business/customer rules where legally available |
| Handling privacy requests and complaints | Legal obligations and legitimate interests |
| Optional cookies, analytics, embeds and marketing technologies | Consent, unless a narrow statutory exception is specifically and correctly used |
Who information may be shared with
Information may be shared only where necessary with hosting, WordPress and security providers; email and communications providers; professional advisers; event, fulfilment or delivery providers; payment providers; and public authorities where legally required.
Direct charity donations are made through GiveStar or another identified fundraising provider. Tough Smudge does not receive your full payment-card details. Patreon, YouTube and social platforms process information under their own terms when you visit them or allow an embedded feature.
International transfers
Some technology providers may process information outside the UK. Where Tough Smudge selects a provider, appropriate UK transfer safeguards should be used where required. A third-party service you visit directly is responsible for explaining its own transfers.
How long information is kept
- Routine enquiries: normally up to 24 months after the matter ends.
- Contracts, sponsorship, orders and accounting records: normally six years after the relevant financial period or contract ends.
- Account records: while the account is active and for a proportionate period afterwards for security, disputes and legal duties.
- Privacy requests and complaints: normally 24 months after closure, unless longer retention is necessary.
- Security logs: for the period set by the hosting or security provider and no longer than necessary.
- Consent choices: 180 days unless the policy changes sooner.
Cookies and embedded services
Optional technologies are blocked until you choose them. Read the Cookie Policy and technology inventory.
Your rights
Depending on the circumstances, you may ask for access, correction, deletion, restriction, portability, objection or withdrawal of consent. You also have the right to object to direct marketing at any time.
Use the privacy request form or email ajs61778@gmail.com. Tough Smudge will acknowledge a data-protection complaint within 30 days, investigate without undue delay, keep you informed where appropriate and explain the outcome.
Complaints to the regulator
You may complain to the UK Information Commissioner’s Office. Tough Smudge would appreciate the opportunity to address the issue first, but this does not affect your right to contact the regulator.
Children
Tough Smudge is not intended to collect children’s personal information through accounts, marketing or commercial services without appropriate safeguards and, where required, parental responsibility arrangements.
Changes to this notice
This notice is reviewed when the site introduces new accounts, memberships, Patreon features, YouTube integrations, analytics, sponsorship systems, shop functions or providers. Material changes may also trigger a fresh cookie choice.
Privacy request form: