Privacy Policy
Version: 1.0 | Last updated: 2026-04-29 | Status: Live
This Privacy Policy explains how Shooting Systems Ltd ("we", "us", "our") collects, uses, stores, and protects your personal data across all of our services. It applies to:
- the Zero mobile application ("the App"),
- the Zero: Financial Knowledge marketing website at
darrensterling.co.ukand its associated forms, - the Schools sample-pack programme and any follow-up correspondence relating to it,
- email communications you receive from us at
darren@darrensterling.co.ukor any other@darrensterling.co.ukaddress.
We are committed to protecting your privacy and handling your data transparently.
1. Who We Are
Data Controller: Shooting Systems Ltd Company number: 16001177 (England and Wales) Registered office: Riverside House, 4 Melbourne Street, Stalybridge, SK15 2JE, United Kingdom Contact email: privacy@darrensterling.co.uk ICO Registration: ZC135407
2. What Data We Collect
2.1. Account Data (Standard + Vault Tiers, App)
| Data | Purpose | Legal basis |
|---|---|---|
| Full name | Account identification, personalisation | Contract performance |
| Email address | Account authentication, notifications, communications | Contract performance |
| Password (hashed) | Account security | Contract performance |
| Date of birth | Age-based calculator defaults (retirement projections, life stage) | Legitimate interest (personalisation) |
| UK jurisdiction (England/Scotland/Wales/NI) | Correct tax bands, SDLT/LBTT/LTT rates | Legitimate interest (accuracy) |
| Postcode (optional) | Future regional features | Consent |
| Employment status | Calculator relevance (PAYE/self-employed/retired) | Legitimate interest (personalisation) |
| Marital status | Benefit threshold calculators, IHT estimates | Legitimate interest (personalisation) |
| Number/ages of children (optional) | Child benefit, childcare threshold calculators | Consent |
| Homeowner/renter status | Mortgage vs rent calculator relevance | Legitimate interest (personalisation) |
2.2. Progressive Profile Data (App, collected contextually, all optional)
| Data | Purpose | Legal basis |
|---|---|---|
| Tax code | Pre-populate salary calculator | Consent |
| Pension contribution % | Pre-populate pension calculators | Consent |
| Employer pension match % | Pre-populate pension growth calculator | Consent |
| Student loan plan | Salary and threshold calculators | Consent |
| Mortgage details | Property calculators | Consent |
2.3. Financial Data (Pillar 2 — Standard + Vault Tiers, App)
| Data | Purpose | Legal basis |
|---|---|---|
| Account names and balances | Running balance, multi-account dashboard | Contract performance |
| Bill names, amounts, dates | Bill tracking, reminders | Contract performance |
| Income sources and amounts | Budget summary, income calculator | Contract performance |
| Transaction records | Spending tracking | Contract performance |
| Debt details (type, balance, APR) | Debt priority tracker | Contract performance |
This data is stored in our database (Supabase) with Row Level Security — only you can access your own records. Financial data is encrypted at rest using SQLCipher.
2.4. Vault Data (Pillar 3 — Vault Tier Only, App)
| Data | Purpose | Legal basis |
|---|---|---|
| Digital account details | Digital legacy vault | Contract performance + Consent |
| Key contacts | Legacy planning | Contract performance + Consent |
| Document uploads | Secure document storage | Contract performance + Consent |
| Legal obligations | Legacy planning | Contract performance + Consent |
| Next-of-kin configuration | Legacy access management | Contract performance + Consent |
Vault data is end-to-end encrypted. It is encrypted on your device before being transmitted to our servers. We do not hold decryption keys and cannot access, read, or recover your vault data. Our servers store only ciphertext.
2.5. Technical Data (App, all users)
| Data | Purpose | Legal basis |
|---|---|---|
| Device type, OS version | App compatibility, debugging | Legitimate interest |
| App version | Update prompts, debugging | Legitimate interest |
| Crash reports (via Sentry) | App stability, bug fixing. Anonymised — no PII included. | Legitimate interest |
| Usage analytics (via PostHog) | Product improvement. Only collected with your explicit consent. | Consent |
2.6. Marketing-site Lead Capture (darrensterling.co.uk)
When you submit a form on our marketing website (e.g. requesting the schools sample pack at /schools), we collect:
| Data | Purpose | Legal basis |
|---|---|---|
| Name | Personalising the materials we send you | Consent |
| Email address | Sending the requested materials and the related follow-up sequence (see 2.7) | Consent |
| Role (e.g. PSHE Lead) | Tailoring follow-up communications | Consent (optional field) |
| School / organisation name | Tailoring follow-up communications | Consent (optional field) |
| Jurisdiction (England / Scotland / Wales / other) | Sending region-relevant curriculum information | Consent (optional field) |
| IP address & user-agent at the time of submission | GDPR consent audit trail (proof of when and how consent was given) | Legitimate interest |
This data is stored in our Supabase database (EU region) and is accessible only by Darren Sterling. We do not share it with third parties for marketing.
2.7. Schools Sample-pack Follow-up Sequence
After you request the schools sample pack, you will receive a structured 5-email sequence over approximately 60 days:
| Sent | Purpose | |
|---|---|---|
| 1 — Sample pack | Immediately on form submission | Deliver the requested PowerPoint lesson and PDF chapter |
| 2 — Check-in | ~14 days later | Ask whether the materials landed and were useful |
| 3 — Use case | ~28 days later | Share an example of how another school used the materials |
| 4 — Pricing FAQ | ~42 days later | Answer the questions other schools have asked |
| 5 — Final note | ~56 days later | A time-limited offer; final email unless you reply |
Every email in the sequence includes a one-click "Unsubscribe" link in both the email body and the message header (RFC 8058 compliant — your email client will display a native Unsubscribe button). Unsubscribing is processed immediately and is permanent — once you unsubscribe, you will not be re-added even if you re-submit the form, unless you explicitly opt back in.
If you reply to any email in the sequence, the automated cadence is paused for your record so we can have a normal one-to-one conversation.
We retain your contact details for 24 months from your last interaction (open, click, reply or new submission), after which the record is deleted. If you unsubscribe, your record is retained on a suppression list indefinitely for the sole purpose of preventing future emails — this is permitted under UK GDPR and is necessary to honour your unsubscribe.
2.8. Email Replies and One-to-one Correspondence
If you email us at darren@darrensterling.co.uk or any other @darrensterling.co.uk address, we collect and retain:
| Data | Purpose | Legal basis |
|---|---|---|
| Your email address | Replying and continuing the conversation | Legitimate interest |
| The content of your email | Responding appropriately | Legitimate interest |
| Headers and metadata your email client provides | Standard email handling | Legitimate interest |
Email is processed by Microsoft 365 (EU tenant) for inbound and outbound, and by Resend for transactional and cadence emails. Both are documented in Section 5.
3. What We Do NOT Collect
- We do not collect your bank login credentials (the App uses manual entry, not Open Banking)
- We do not use advertising SDKs or share data with advertisers
- We do not sell your data to third parties — ever
- The App does not use cookies (it is a native mobile application). The marketing website uses essential cookies only — see Section 9.
- We do not track your location (postcode is optional and entered manually)
- We cannot read your vault data (it is end-to-end encrypted)
- We do not add anyone to the schools cadence who has not actively requested the sample pack
4. How We Use Your Data
| Purpose | Data used | Legal basis |
|---|---|---|
| Provide the App's features | Account, financial, calculator profile data | Contract performance |
| Personalise calculator defaults | DOB, jurisdiction, employment status, progressive profile | Legitimate interest |
| Send App notifications (bill reminders, vault alerts) | Contact details, bill dates, vault config | Contract performance |
| Process App payments | Handled by Apple/Google — we receive a transaction ID only | Contract performance |
| Improve the App | Anonymised analytics (with consent), crash reports | Consent / Legitimate interest |
| Send the schools sample pack and its 5-email follow-up sequence | Marketing-site lead data (see 2.6, 2.7) | Consent |
| Respond to your enquiries | Email address, message content | Legitimate interest |
| Comply with legal obligations | Account data, audit logs | Legal obligation |
5. Data Sharing
We share your data only in these limited circumstances:
| Recipient | What | Why | Country |
|---|---|---|---|
| Supabase (database, storage, edge functions) | App account & financial data; marketing-site lead data; vault ciphertext only | Infrastructure — Data Processing Agreement in place | EU (Ireland) |
| Resend (transactional email) | Marketing-site lead emails (sample pack + 5-step cadence); App transactional email | Email delivery — Data Processing Agreement in place | EU (Ireland) |
| Microsoft 365 (inbound/outbound mail) | Email replies and one-to-one correspondence | Mailbox provider — Data Processing Agreement in place | EU (Ireland tenant) |
| Cloudflare (DNS, edge protection, CDN) | IP addresses, request metadata | Security — DDoS protection, WAF. No access to App or lead data. | UK + global |
| Vercel (marketing-website hosting) | Request-level metadata (no submitted form data — that goes directly to Supabase) | Hosting darrensterling.co.uk | USA — Standard Contractual Clauses in place |
| Sentry (crash reporting, App) | Anonymised crash data (no PII) | App stability | EU (Frankfurt) |
| PostHog (App analytics, opt-in only) | Anonymised usage events (with your consent only) | Product improvement | EU (Frankfurt) |
| Apple / Google (App payment) | Transaction IDs | Payment processing | USA |
| Amazon Kindle Direct Publishing | Book purchase data (book sales metadata only — no contact between us and individual purchasers via this route) | Book distribution | USA |
| Your Nominated Persons (next-of-kin, App vault) | Vault data subset or full vault — as you have configured | Digital legacy access — only through the mechanism you set up, after countdown timer expiry | n/a — you control |
| Your linked partner (App) | Financial data you have explicitly chosen to share | Partner budgeting | n/a — you control |
| Law enforcement | Account data if required by valid legal order (court order, warrant) | Legal obligation. Note: vault data is E2E encrypted — we cannot provide it even if required. | UK |
We do not share your data with any other third parties.
6. Your Rights (UK GDPR)
Under the UK GDPR, you have the following rights.
For App users, all are accessible from Profile → Privacy & Data in the App:
| Right | How to exercise (App) | How to exercise (everything else) |
|---|---|---|
| Right of access (Subject Access Request) | Profile → Privacy & Data → Download my data. Generates a complete export. | Email privacy@darrensterling.co.uk — response within 30 days |
| Right to rectification | Profile → edit any personal data directly | Email privacy@darrensterling.co.uk |
| Right to erasure (Right to be forgotten) | Profile → Privacy & Data → Delete my account | Email privacy@darrensterling.co.uk; for schools-cadence data, click any unsubscribe link or email us |
| Right to restrict processing | Profile → Privacy & Data → Restrict data processing toggle | Email privacy@darrensterling.co.uk |
| Right to data portability | Profile → Privacy & Data → Download my data (PDF or CSV) | Email privacy@darrensterling.co.uk |
| Right to object | Self-service toggles in Profile → Privacy & Data | Click the unsubscribe link in any cadence email, or email privacy@darrensterling.co.uk |
| Right to withdraw consent | Toggle off any optional data sharing in Profile → Privacy & Data | Click the unsubscribe link in any cadence email |
| Right to complain | You may lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you believe your data rights have been infringed | Same |
We respond to all subject-rights requests within 30 days as required by the UK GDPR. For complex requests, we may extend by an additional 60 days and will notify you within the first 30 days if so.
7. Data Security
| Measure | Detail |
|---|---|
| Encryption in transit | All data transmitted over HTTPS (TLS 1.2 minimum, TLS 1.3 preferred) |
| Encryption at rest (financial data) | SQLCipher encryption, keys in platform keychain |
| Encryption at rest (vault data) | End-to-end AES-256-GCM encryption. Keys derived from your password via Argon2id. We hold only ciphertext. |
| Authentication (App) | Password (12+ characters, breached password check) + TOTP MFA (mandatory for vault) |
| Access control | Supabase Row Level Security on all tables. Users can only access their own data. Service-role access (used by edge functions and Darren Sterling for admin) is logged. |
| Edge protection | Cloudflare WAF, DDoS protection, rate limiting |
| Email authentication | SPF, DKIM, and DMARC (p=quarantine) published for darrensterling.co.uk to prevent spoofing |
| Monitoring | Sentry error monitoring, audit logging for vault access |
| Penetration testing | Independent pen test conducted pre-launch and annually |
| Platform security | iOS Keychain / Android Keystore for credential storage. No sensitive data in logs, backups, clipboard, or screenshots (vault screens). |
8. Data Retention and Deletion
| Data type | Retained while | On deletion request |
|---|---|---|
| App account data | Account is active | Permanently destroyed immediately |
| App calculator history | Account is active | Permanently destroyed immediately |
| App financial data (Pillar 2) | Account is active | Permanently destroyed immediately |
| App vault data (Pillar 3) | Subscription is active + 30-day grace period | Permanently destroyed immediately |
| App audit logs (vault access requests) | 7 years from creation | Anonymised — user ID removed, actions retained for legal compliance |
| Anonymised App analytics | Indefinite | No user link exists — already anonymised |
| App crash reports | 90 days (Sentry default) | No user link exists — already anonymised |
| Schools sample-pack lead data | 24 months from last interaction | Permanently destroyed immediately on request, OR moved to a suppression list (email + hash only) on unsubscribe |
| Schools-cadence audit log (which email was sent when) | 6 years (UK statute of limitations) | Lead identifier removed; aggregate retained |
| Email correspondence | 24 months from last reply | Permanently destroyed immediately on request |
App account deletion:
- Navigate to Profile → Privacy & Data → Delete my account
- You will be shown a clear statement: "Closing your account will immediately and permanently destroy all your data, including your profile, saved calculations, financial records, and vault contents. This action cannot be undone."
- Confirm with your password (+ MFA if vault tier)
- All data is destroyed immediately
- A confirmation email is sent to your registered email address
App vault subscription lapse:
- Payment fails or subscription cancelled → 30-day grace period (read-only access)
- Notifications sent at: day 0, day 7, day 14, day 21, day 28
- After 30 days: vault data permanently destroyed, account downgraded to Standard
Schools-cadence unsubscribe:
- Click any "Unsubscribe" link, or use your email client's "Unsubscribe" button
- Your record is moved to a suppression list immediately — you will receive no further emails
- The suppression list contains only your email address (hashed) and the date you unsubscribed
- You may request full deletion of even the suppression-list record by emailing privacy@darrensterling.co.uk; we will comply, with the consequence that we cannot guarantee not to email you again if you re-submit a form in the future
9. Cookies and Similar Technologies
The App does not use cookies (it is a native mobile application).
The marketing website (darrensterling.co.uk) uses only essential cookies necessary for the site to function:
| Cookie | Set by | Purpose | Duration |
|---|---|---|---|
| Session token | Vercel (hosting) | Page rendering and security | Session |
__cf_bm and similar |
Cloudflare | Bot management, security | 30 minutes |
We do not use analytics cookies, advertising cookies, or any third-party tracking on the marketing website. No consent banner is shown because no consent is required for strictly-essential cookies under PECR.
10. Children's Privacy
The App is not intended for use by anyone under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 18, we will delete it promptly.
The schools sample-pack programme is intended for teachers and education professionals, not students.
11. International Transfers
Most of your data is processed and stored within the European Economic Area (EEA) and the United Kingdom:
- Supabase: EU (Ireland) region
- Resend: EU (Ireland) region
- Microsoft 365: EU (Ireland) tenant
- Sentry / PostHog: EU (Frankfurt)
A small number of processors operate from the United States and process limited data on our behalf:
- Vercel (marketing-website hosting). Standard Contractual Clauses (SCCs) in place. No personal form-submission data flows through Vercel — submissions go directly from the user's browser to Supabase.
- Apple / Google (App payment processing). Limited to transaction identifiers.
- Amazon Kindle Direct Publishing (book distribution). Book sales data only — no contact between us and individual purchasers via this route.
Where data is transferred outside the UK/EEA, we rely on the UK International Data Transfer Addendum to the EU SCCs, or equivalent safeguards.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The current version is always available at https://darrensterling.co.uk/privacy.
For material changes, we will:
- Publish the updated policy at the URL above with a new "Last updated" date
- For App users: notify you via in-app notification and email at least 30 days before the changes take effect
- For schools-cadence subscribers: include a brief notice in the next scheduled email
The "Last updated" date at the top of this policy reflects the most recent revision.
13. Contact Us
If you have questions about this Privacy Policy or wish to exercise your data rights, contact us at:
Email: privacy@darrensterling.co.uk
Postal: Shooting Systems Ltd, Riverside House, 4 Melbourne Street, Stalybridge, SK15 2JE, United Kingdom
ICO: If you are not satisfied with our response, you may contact the Information Commissioner's Office at ico.org.uk or by calling 0303 123 1113.