This is the website privacy notice of Libertas VA Services (the “Business”).
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how data protection law protects you.
1. Who we are and important information
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, download a resource and book a consultation, submit an enquiry through our website, contact us by email or telephone or engage us to provide services.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data controller
Courteney Dudley trading as Libertas VA Services is the controller and responsible for your personal data (collectively referred to as “Business” , “we”, “us” or “our” in this privacy notice).
The primary place of business is Flat 10 Alliance Court, Whitehall Lane, Erith, Kent, DA8 2DN.
Email: info@libertasva.co.uk
ICO registration reference: ZB682313
If you have any questions about this privacy notice or how we process your personal data, please contact us using the details above.
As part of providing our services, we may process personal data on behalf of our clients. In these circumstances, Libertas VA Services acts as a data processor and processes personal data only in accordance with our clients’ instructions and any applicable Data Processing Agreement. This Privacy Notice relates to the personal data we collect and process as a data controller.
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The personal data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioner’s Office (ICO) website.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data: includes first name / last name / title / business name.
- Contact Data: includes email address / telephone numbers / billing or correspondence address (where applicable).
- Enquiry Data: includes information you choose to provide when you contact us, complete a website enquiry form, book a consultation or communicate with us about our services.
- Marketing Data: includes your preferences for receiving marketing communications from us and your communication preferences.
- Technical and Usage Data: includes information about how you use our website, including IP address, browser type, device information, pages visited and other analytical data collected through cookies and similar technologies.
- Client Data: where you engage us to provide services, we may collect additional information necessary to provide those services, including billing information and information relevant to your project. Where we process personal data on behalf of our clients, this is governed by a separate Data Processing Agreement where applicable.
- We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not intentionally collect Special Category Personal Data through our website. However, if you choose to provide this information to us, or where it is necessary for the provision of our services, we will process it in accordance with applicable data protection law and any contractual arrangements in place.
We do not intentionally collect information relating to criminal convictions or offences through our website. Where such information is provided as part of our services, it will be processed only where necessary and in accordance with applicable law and any relevant contractual agreements.
If you fail to provide personal data
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How we collect your personal data
We collect personal data in a number of ways, including when you:
- complete an enquiry form on our website using WPForms;
- contact us by email, telephone or social media;
- book a consultation through Calendly;
- download one of our free resources;
- subscribe to our newsletter or marketing communications;
- engage us to provide our services; or
- otherwise communicate with us directly.
We also collect certain technical information automatically when you use our website through cookies and similar technologies. For more information, please see our Cookie Policy.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest: this means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us via the contact details at the end of this privacy notice.
- Comply with a legal or regulatory obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We rely on your consent where required by law, including where you choose to receive marketing communications from us or subscribe to our newsletter. You may withdraw your consent at any time by clicking the unsubscribe link in our emails or by contacting us at info@libertasva.co.uk.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us info@libertasva.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| Responding to enquiries | Identity, Contact, Enquiry | Legitimate Interests |
| Booking consultations | Identity, Contact, Enquiry | Performance of Contract / Legitimate Interests |
| Providing services | Identity, Contact, Client Data | Contract |
| Sending requested free resources | Identity, Contact | Contract (providing the requested resource) |
| Sending newsletters and marketing | Identity, Contact, Marketing Preferences | Consent |
| Managing payments and accounts | Identity, Contact, Billing Information | Contract / Legal Obligation |
| Improving our website | Technical & Usage Data | Legitimate Interests |
| Complying with legal obligations | Relevant Data | Legal Obligation |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will only send marketing communications where you have asked to receive them or where we are otherwise permitted to do so by law.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you by info@libertasva.co.uk.
Opting out of marketing communications will not affect service-related communications, such as information relating to an enquiry you have made, a consultation you have booked or services we are providing to you.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.libertasva.co.uk/cookies-policy/.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact info@libertasva.co.uk.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Who we share your personal data with
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External third parties
We may share your personal data with carefully selected third-party service providers where necessary to operate our business and provide our services. These may include:
- Microsoft 365: for email communications and business productivity.
- Microsoft SharePoint and OneDrive: for secure document storage and file management.
- WPForms: to receive enquiries submitted through our website.
- Calendly: to allow clients and prospective clients to book consultations.
- MailerLite (where applicable): to deliver requested downloadable resources and, where you have provided your consent, marketing communications.
- Google Analytics and Google Search Console: to help us understand how our website is used and improve its performance.
- GoCardless: for processing payments.
- Xero: for accounting, invoicing and financial record keeping.
- Professional advisers, insurers, regulators or legal authorities where required by law.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Some of the third-party service providers we use may transfer, store or process personal data outside the United Kingdom.
Where this happens, we ensure appropriate safeguards are in place to protect your personal data, including relying on UK adequacy regulations or the International Data Transfer Agreement (IDTA) or other approved transfer mechanisms where required.
We only work with service providers that demonstrate appropriate standards of security and data protection.
7. Data security
We have implemented appropriate technical and organisational security measures to protect your personal data against accidental loss, unauthorised access, misuse, alteration or disclosure.
These measures include, where appropriate:
- secure Microsoft 365 email services;
- secure cloud storage using Microsoft SharePoint and OneDrive;
- strong password practices and multi-factor authentication;
- restricted access to personal data on a need-to-know basis;
- secure backup and storage practices;
- regular software updates; and
- confidentiality obligations for anyone authorised to process personal data on our behalf.
We have procedures in place to deal with any suspected personal data breach and will notify affected individuals and the Information Commissioner’s Office where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting and reporting requirements.
When determining how long to keep personal data, we consider:
- the amount, nature and sensitivity of the personal data;
- the potential risk of harm from unauthorised use or disclosure;
- the purposes for which we process the data;
- whether those purposes can be achieved by other means; and
- our legal and regulatory obligations.
As a general guide:
- Enquiry information is retained only for as long as necessary to respond to your enquiry and any reasonable follow-up.
- Client information is retained for as long as required to provide our services and to meet our legal, accounting and tax obligations.
- Marketing information is retained until you unsubscribe or ask us to remove you from our mailing list.
- Financial records are retained for the period required by applicable law.
When personal data is no longer required, it will be securely deleted or anonymised where appropriate.
In some circumstances you can ask us to delete your data. Please see “Your legal rights” below for further information.
9. Your legal rights
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact info@libertasva.co.uk.
No fee required, with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Changes to this notice and your duty to inform us of changes
This notice was last updated on: 5 July 2026 and previous versions can be obtained by contacting us.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. Queries, requests or concerns
If you have any questions about this Privacy Notice or how we handle your personal data, please contact us:
Libertas VA Services
Flat 10 Alliance Court, Whitehall Lane, Erith, Kent, DA8 2DN
Email: info@libertasva.co.uk
12. Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (ico.org.uk), the UK supervisory authority for data protection matters.
We would, however, appreciate the opportunity to address your concerns before you contact the ICO, so please contact us first wherever possible.
If your query relates to personal data processed by us on behalf of one of our clients, we may need to refer your request to that client, as they are the data controller responsible for that information.
