Privacy Policy

1. Who we are

This policy is issued by Made in Earnest Ltd ("Earnest", "we", "us", "our"), a company registered in England and Wales.

• Company number: 17328636
• Registered office: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ
• ICO registration reference: ZC195289
• Contact: privacy@madeinearnest.co.uk

We are the data controller for the personal information described in this policy. We have not appointed a Data Protection Officer — none of the legal triggers for requiring one apply to us.

2. What information we collect

From you, if you're placing an order

About the person you're sending a card to

Because a card is about someone else, you'll tell us things about them during your consultation — their name, your relationship to them, their personality, hobbies, and the occasion. We also ask for their delivery address if you'd like the card sent directly to them.

We deliberately never collect the recipient's email address or phone number, under any circumstances. Where our print partner needs a contact point for delivery purposes, we provide yours instead.

Sensitive information

Because our consultation is a free-flowing conversation, customers occasionally share sensitive details about the person they're sending a card to — for example, health information — even though we don't ask for this and don't need it to make your card. We are finalising the specific legal basis for this occasional, incidental processing with our legal advisors, and will update this section once that's confirmed. In the meantime, this information receives the same security protections as everything else we hold, and is never used for any purpose beyond creating your card.

3. How we use your information, and our legal basis for doing so

Why legitimate interests for the recipient's data: the recipient hasn't interacted with us and can't consent to anything, so we rely on our legitimate interest in providing the personalised product you've asked for. We've tested this formally and concluded the balance favours this processing, given the low sensitivity of the data in the ordinary case, the positive purpose (creating something thoughtful, not building a profile), a limited retention period, no marketing or automated use of the recipient's data, and the recipient's ability to exercise their own rights at any time.

4. Who we share your information with

We use a small number of specialist companies to run Earnest. Each is contractually required to protect your data and use it only as we instruct — none of them can use your information for their own purposes.

We don't sell your information to anyone, and we don't share it for third-party marketing.

5. Sending your information outside the UK

Some of the companies we work with are based in, or process data in, the United States. Where this happens, we rely on legal safeguards recognised under UK law — specifically, the UK's International Data Transfer Addendum attached to the EU's Standard Contractual Clauses, which each of these companies has incorporated into our contract with them. This gives your data the same level of legal protection as if it stayed in the UK, regardless of where it's physically processed.

Neither Anthropic nor OpenAI use the information you share with them to train their AI models, by default — we've confirmed this directly, both from their published policies and from our own account settings with each company.

6. How long we keep your information

• If you start a consultation but don't complete an order: we delete your conversation after 60 days.
• If you complete an order: we delete the full conversation 12 months after your card is delivered. We keep a record of the order itself (order reference, amount, date, delivery address) for 6 years, as UK law requires for accounting purposes.

We don't keep your information for longer than these periods, or use it for any purpose beyond what's described in this policy.

7. Cookies

Our website currently only uses cookies that are strictly necessary for it to work — for example, to process your payment securely. We don't currently use any analytics or marketing cookies. If that changes, we'll ask for your consent first, and you'll be able to withdraw it at any time.

8. Your rights

You have the right to:

• Access the personal information we hold about you
• Correct it, if it's inaccurate or incomplete
• Delete it, in certain circumstances
• Restrict how we use it
• Object to our use of it
• Receive a copy of it in a portable format

This applies whether you're the customer or the recipient of a card — if you've received a card made through Earnest and want to know what information we hold about you, you're entitled to ask, in exactly the same way a customer would.

To exercise any of these rights, email privacy@madeinearnest.co.uk. We'll respond within one calendar month. These rights are free to exercise, unless a request is manifestly unfounded or excessive.

9. How to complain

If you're unhappy with how we've handled your information, please contact us first at privacy@madeinearnest.co.uk — we'll acknowledge your complaint and investigate without undue delay.

You also have the right to complain directly to the UK's data protection regulator:

Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline: 0303 123 1113 · ico.org.uk

10. Automated decision-making

We don't use any automated decision-making or profiling that produces legal or similarly significant effects about you. AI tools help create your card, but no automated system makes decisions about you as an individual.

11. Children

Earnest isn't aimed at, or knowingly used by, children. If you believe a child has provided us with personal information, please contact us and we'll delete it.

12. Keeping this policy up to date

We'll update this policy whenever our processing changes — a new supplier, a new feature that uses personal information, or a change in the law. We'll post the updated version here with a new date.

13. Contact us

Questions about this policy, or about your information generally: privacy@madeinearnest.co.uk