Privacy Policy (January 2021)

This document outlines our data processing practices and policies, specifically the ways in which your personal data is used and how we keep it secure.

Your personal information is integral to our working relationship, and we are absolutely committed to safeguarding and protecting your personal data and privacy.

The personal information that you have shared with us may occasionally be used to keep you updated with information on products and services that may be of interest to you. It will also be used in connection with undertaking operations which are specifically relevant to the continuance of your trade account. We will only use your personal data for these specific purposes.

We do not sell, rent or share your personal information with any third-parties for commercial or any other reasons.

If you have any requests concerning your personal information or any queries with regard to our procedures, please contact us via

What personal data do we hold?

We hold details provided by you on opening an account. The data will typically include your name, job title, business address, email address and contact telephone numbers, and bank details where you have requested credit facilities or the facility to manage payments via BACS or other electronic payment methods.

We also collect information and keep records about the transactions you undertake with us. These transactions will typically be, order placing, request for quotations, requests for information and payment records, and are an integral part of our order processing procedures.

In the case of sole traders and partnerships, we will also hold home addresses where applicable. We may also keep information that is provided by you, obtained from your bank, credit reference agencies or from your referees that allow us to extend credit facilities to your business.

We may collect additional information in connection with your participation in any promotions or competitions offered by us.

We will never collect sensitive personal data about you without your explicit permission and clear explanation as to why it is required.

What do we use your personal data for?

We may use your information to provide and personalise our service to you. We will also use your contact details to communicate with you and send you information that is required to operate your account.

From time to time we will send you details of circumstances which may impact upon any operational procedures directly relevant to our transactional relationship.

We may use your information to send offers and news on products and services, which we think may be of interest or be of benefit to you. In this case you will always be given the choice to opt out of receiving such emails. You can withdraw your consent by contacting at any time.

Please note that there may be instances where it may be necessary for us to communicate with you for administrative or operational reasons relating to your account or our service.

Gumption design does not use any automated decision making systems or carry out profiling of personal data records.

Does Gumption design share customers’ personal data with third parties?

We may only share your information with our bankers, solicitors, credit insurers and credit reference agencies for invoicing purposes. We will also share information with organisations to comply with legal and regulatory requirements.

It is our strict policy not to pass on any customer specific information to third parties for sales or marketing purposes.

What are the legal grounds for processing your personal information?

Gumption design is the Data Controller as defined by the EU’s General Data Protection Regulation (GDPR).

We use your personal information to provide you with our products and services, including:

Offering of credit account facilities

Delivering goods

Providing information

We also use your information where it is in our legitimate interest to do so, such as:

Updating our records to contact you about your account

Recovering debt

To follow guidance and best practice of regulatory bodies

For management and audit of our business operations and accounting

To carry out searches at credit reference agencies both at the application stage and periodically thereafter.

To maintain and preserve records of our communications with you

To maintain our good governance requirements and to comply with our legal and regulatory requirements.

How do we protect the data that we hold?

All data is held on a private network server that is single point of entry firewall protected.

All data processing is carried out on secure, password protected terminals with operating proprietary security software, and which are physically linked to the private network server.

All emails are security scanned.

Personal data access rights

You have a right to access the personal data that is held about you. To obtain a copy of the personal information that Gumption design holds about you, please contact us at

You also have the right to request removal, transfer or copy (to a location of your choice) of your personal information.

You have the right to ask us to delete all personal data that is used for certain purposes, such as direct marketing and where there is no compelling, legal or regulatory reason for the data to be processed.

You have the right to ask us to amend or delete any inaccurate or incomplete personal data.

Updates and Changes

This document may be updated from time to time in order to reflect changes to legislation or our procedures. Details of any changes will be published on our website.

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