Privacy Policy

Last updated: 6 October 2026

1. Who we are

Proper Sites Ltd ("ProperSites", "we", "us") is responsible for the personal data described in this notice. In data protection law that makes us the controller. We are a company registered in England and Wales, company number 17081787, and our registered office is 71-75 Shelton Street, Covent Garden, London WC2H 9JQ.

This notice covers:

• people who visit our website or contact us;
• our clients;
• the businesses we contact about their websites;
• people who apply to work with us as sales contractors, and our contractors; and
• anyone we speak to on the phone.

For anything to do with your personal data, email privacy@propersites.com or write to us at our registered office. We are registered with the Information Commissioner's Office (ICO) under registration reference ZC192664.

2. The short version

• We use your details to reply to you, to work for our clients, to contact businesses about their websites and to recruit sales contractors.
• We record our business phone calls, and our phone system makes a written transcript of each recorded call.
• We use some AI tools to help our team. They do not make decisions about you.
• We do not sell personal data, and we do not use it for advertising.
• You can object, ask for a copy of your data or ask us to delete it at any time by emailing privacy@propersites.com.

The rest of this notice gives the detail.

3. What we collect

What you give us. When you fill in a form on this website, email us, message us or call us, we collect what you tell us. That is usually your name, email address, phone number, details about your business such as its name and website, and the content of your message. If you become a client, we also hold your billing details and a record of the work we do for you. We need your contact and billing details to do the work and invoice you.

What we collect when you visit. Our hosting provider records basic technical information in server logs, such as your IP address, browser type and the pages you view. We use these logs for security and to keep the site running. Section 11 covers analytics.

What we get from elsewhere. We hold some business contact details that we found in public sources (section 4), and we receive some job applications through job boards (section 6).

Our website and services are for businesses. They are not aimed at children.

4. Businesses we contact

If you work for a UK business, we may hold your business contact details even though you have never been in touch with us, because we contact businesses about their websites. This section explains what we hold and how to make us stop.

What we hold. Business contact details only: your name, your job title or role, your business email address, your business phone number and the business you work for. We also look at public information about the business itself, such as its reviews, its domain registration record and archived copies of its website. We do not collect anything about your private life, and we hold no special category data.

Where we got it. From public sources:

• Google Maps and Google business listings, which is usually where a business name, phone number, address and website come from;
• the business's own website, including contact details and names published on it; and
• the Companies House register, which is usually where a director's name comes from.

Where a business publishes no email address, we sometimes try a standard one at its own domain, such as info@ or hello@. We do not buy marketing lists or use data brokers to find people. We use Hunter.io only to check that an email address we already hold still works.

What we use it for. We use it to contact the business by email or phone, and sometimes through LinkedIn, about problems we have found on its website. We offer a free assessment and a conversation with no obligation. We keep these records in our CRM systems (section 8) to organise our calls and emails. Our lawful basis is legitimate interests, UK GDPR Article 6(1)(f): our interest in offering our services to businesses that are likely to need them. We have written down the assessment behind that decision and will send you a copy if you ask.

We only contact businesses this way if they are limited companies, including PLCs, or limited liability partnerships. Our systems keep sole traders and ordinary partnerships off our calling and email lists, and we do not contact private individuals this way. Before we call a business, we check its number against the Telephone Preference Service (TPS) and Corporate TPS registers.

How to make us stop. You can object at any time and you do not have to give a reason. For direct marketing that right is absolute: if you object, we stop. Use the unsubscribe link in any email we send, reply and say stop, tell the person who calls you, or email privacy@propersites.com. We add you to a suppression list that our systems check before anyone is contacted, so we do not contact you again by mistake.

How long we keep it. We keep business contact details while the business is an active prospect. We delete a record within a month of it reaching 24 months without contact with the business, or sooner if you ask. If you object or unsubscribe, we keep only your email address or phone number on our suppression list, so that we can keep honouring your request.

5. Phone calls, recordings and transcripts

We record calls to and from our business phone numbers. That includes calls with the businesses we contact, our clients, people applying to work with us and our contractors.

How you are told. We tell you at the start of each call that it is being recorded.

Transcripts. Each recorded call is also turned into a written transcript using speech recognition software, so we can read what was said without replaying the whole call. The transcript is made on our own servers, hosted by Hetzner in Germany. A computer makes the transcript. A person checks it only when we need to look at a particular call.

Why we make transcripts. We use them to improve what we say on calls: to see which explanations work, to write better scripts and training material, and to help our team when they ask for it. We also use them to keep an accurate record of what was said and agreed, to check the quality and compliance of our calls, and to deal with complaints and disputes. Our lawful basis is legitimate interests, UK GDPR Article 6(1)(f): our interest in running an honest, well-run sales operation. We do not use recordings or transcripts to make automated decisions about you.

How long we keep a transcript. A transcript that identifies you is kept for the same period as the call recording: up to 12 months if you applied to work with us and we did not take you on, up to 24 months for calls with the businesses we contact and any other call, and up to 6 years if the call is connected with a signed contractor or client agreement, a complaint or a dispute. At the end of that period we delete the transcript that identifies you and keep a copy with the identifying details removed, which we use only to improve our scripts and training material. We also keep simple statistics drawn from calls, such as how many calls led to a meeting.

Why we record. We record calls to keep an accurate record of what was said and agreed, to train and support our team, to check the quality of our calls, and to deal with complaints and disputes. We do not use recordings or transcripts to make automated decisions about you. Our lawful basis is legitimate interests, UK GDPR Article 6(1)(f).

Who listens to recordings. The people who run our sales and hiring can listen to recordings and read transcripts. To train our sales team, we may also play a recording, or show part of a transcript, to our sales contractors. They are bound by written confidentiality terms and may not share a recording or transcript with anyone else. We choose a call for what it can teach, and we never play our contractors a call with someone who applied to work with us, or show them its transcript. If you would rather your call was not played or shown to our contractors, tell us and we will exclude it.

If you would rather not be recorded. Tell us at the start of the call and we will carry on by email instead. You can also object later, or ask for a copy of a recording or transcript, by emailing privacy@propersites.com.

How long we keep a recording. It depends on why we might need the call:

• calls with applicants we do not take on: up to 12 months;
• calls with the businesses we contact, and any other call: up to 24 months; and
• calls connected with a signed contractor or client agreement, a complaint or a dispute: up to 6 years, which is the time limit for most contract claims.

The transcript that identifies you is kept for the same period, and after that only in the removed-details form described above. We may keep anonymous statistics drawn from calls for longer. They do not identify anyone.

6. If you apply to work with us

How your application reaches us. Through the application form on our careers pages, or through a job board such as Indeed. If you apply through a job board, we receive the details you gave it, such as your name, contact details, CV and answers to its questions. The job board's own privacy notice explains what it does with your data.

What we collect. Our application form asks for your name, email address, phone number if you give one, LinkedIn profile and the country you would work from. It also asks our screening questions:

• whether you can work UK business hours;
• whether you have a quiet place to call from and a headset;
• how reliable your internet and power are;
• whether you have done phone sales before, and for how long;
• when you could start; and
• your confirmation that you understand the role is self-employed and that you must pass our compliance test.

Anything you write in the motivation or referral boxes is kept with your application.

If you meet the initial requirements, we may invite you to record a short answer. We then collect either a link to your audio or video, or a request for a reasonable adjustment, and any optional note you add. Please do not include medical or other special category details in an adjustment note. We store the link. We do not download, transcribe or analyse the recording automatically.

If we invite you to a screening call, the call is recorded and transcribed (section 5). The person running the call keeps notes and a scorecard, including which role we are considering you for: sales development representative (SDR) or business development manager (BDM).

How we decide. Your first answers are checked automatically against the fixed requirements published for the role. If an answer does not meet a requirement, that check can turn the application down. It follows fixed rules and does not use AI. You can ask for a person to look at it again, tell us anything you think was missed and challenge the result by emailing careers@propersites.com. That person can change the outcome. After the first check, a person makes every decision about whether you move forward, and call transcripts are never used to score you automatically.

If we offer you a role. We send you a non-disclosure agreement and a contractor agreement to sign online through HighLevel's document signing service, which keeps a record of when you signed.

Once you work with us. We give you a user account in our CRM and a business phone number. We keep records of your calls, bookings, deals and commission so that we can run our contract with you and pay you. We need your contact, address and payment details to do that. Your calls are recorded like all our business calls (section 5).

Our lawful bases. Before you are engaged: taking steps at your request before entering into a contract, and our legitimate interests in recruiting, UK GDPR Article 6(1)(b) and (f). Once you are engaged: performing our contract with you, Article 6(1)(b), and meeting our legal obligations, such as keeping tax records, Article 6(1)(c). We do not ask for special category data, and you should not send us any.

What you need to give us. We need your name, contact details and answers to the screening questions to consider your application. Without them we cannot consider you. If we invite you to record a short answer, you can send a recording or ask for a reasonable adjustment instead. Everything else is optional.

Who sees it. The people who run our hiring, and the service providers listed in section 8.

7. Why we use it and our lawful bases

• Replying to enquiries. When you ask about our services, request a free website review or book a call, we use your details to reply and follow up. We record the enquiry in our CRM systems so we can manage the conversation and avoid contacting you twice about the same thing. Lawful basis: our legitimate interests in replying to people who contact us, and taking steps at your request before entering into a contract.
• Preparing for calls. When a new enquiry or business record reaches our CRM, an AI tool writes a short briefing for our team from the business's details and any message you sent. A person reads it and decides what to do. Lawful basis: our legitimate interests in preparing properly for conversations with prospective clients.
• Answering messages. When you send us a text or social media message, or reply to an email we sent from HighLevel, an AI assistant built into HighLevel may suggest a reply. A member of our team reads the suggestion and decides what to send. Lawful basis: our legitimate interests in answering messages promptly.
• Contacting businesses about their website. Section 4 explains this. Lawful basis: legitimate interests.
• Recording calls. Section 5 explains this. Lawful basis: legitimate interests.
• Recruiting and working with contractors. Section 6 explains this and the lawful bases.
• Doing the work. If you become a client, we use your details to deliver what we agreed and to invoice you. Lawful basis: performance of a contract.
• Occasional updates. If you sign up to hear from us, we will email you the occasional tip or update. Lawful basis: consent, which you can withdraw at any time using the unsubscribe link or by emailing us.
• Understanding how our website is used. We use analytics that do not identify you to see which pages are visited and where our forms could be easier to use (section 11). Lawful basis: our legitimate interests in improving our website.
• Keeping records and staying secure. We keep accounting and legal records, protect our forms from spam and monitor for misuse of the site. Lawful bases: legal obligation and legitimate interests.

8. Who we share it with

We do not sell your personal data. We share it with the service providers below, who help us run the business and act on our instructions:

• HighLevel (HighLevel LLC, a subsidiary of GoHighLevel Inc., and its affiliate LeadConnector LLC, United States), which provides our main CRM system and our phone system. We use it to manage candidates, contractors and business contacts. It also handles our calls, call recordings and transcripts, calendars and bookings, document signing, and the emails and texts we send from it, which may show the LeadConnector name. HighLevel uses its own sub-processors, including Twilio to carry calls, Amazon Web Services and Google Cloud to store data, and AI providers, including OpenAI, for features such as transcription and suggested replies. Its support team in India may access data to help us. It also receives and manages the enquiries you send through this website, including your name, email address, phone number, business website, message, the service you asked about, your mailing list choice and how you found us.
• Microsoft, which provides our email and calendars.
• Vercel, which hosts this website.
• Upstash, EU region, which stores a reference number for each website enquiry so the same enquiry is never recorded twice. It holds no names, email addresses or messages.
• Cloudflare, which provides our domain name service, the spam check on our forms and our web analytics.
• PostHog, EU region, which provides website analytics (section 11).
• Resend, EU region, which delivers messages from our website forms to our inbox and sends our website emails, our mailing list and some of our emails to businesses.
• OpenRouter (United States), which passes the requests from our CRM to the AI models that write our call briefings.
• Hetzner (Germany), which hosts the servers that run our call transcription and booking pages.
• a telephone preference screening service, which checks business phone numbers against the TPS and Corporate TPS registers before we call.
• Hunter.io (Hunter Web Services, Inc., United States, with servers in Belgium), which checks that business email addresses we hold still work.
• Google, which provides the separate mailboxes we use to email businesses.
• Stripe, which processes card payments if you pay us online.

We also share personal data with our professional advisers, such as accountants and lawyers, when they need it to advise us. We disclose it where the law requires us to, and to a buyer if we sell or reorganise our business.

Transfers outside the UK. Some of these providers are based in, or process data in, other countries. HighLevel and its sub-processors, Vercel, Cloudflare, Google, Microsoft, OpenRouter, Stripe and Hunter.io may process data in the United States, and HighLevel's support team is in India. For these providers we rely on a safeguard recognised by UK law. That is the UK International Data Transfer Addendum to the EU standard contractual clauses, or the UK Extension to the EU-US Data Privacy Framework where the provider is certified under it. Data held in the EU, such as Hunter.io's servers in Belgium and our servers in Germany, is covered by the UK's adequacy regulations for the EU. Email privacy@propersites.com if you would like details or a copy.

9. How long we keep it

• Enquiries that do not lead to work: up to 24 months, then deleted, including from our CRM systems.
• Business contact details from public sources: deleted within a month of reaching 24 months without contact (section 4). Suppression entries are kept for as long as we contact businesses, so that we can keep honouring them.
• Call recordings: up to 12 months, 24 months or 6 years, depending on the call. Transcripts that identify you: the same period as the recording, then a copy with identifying details removed, which we keep to improve our scripts and training material (section 5).
• Applications that do not lead to a role: up to 12 months after our decision, then deleted.
• Contractor records: for the length of the engagement, then 6 years.
• Client records: for the length of our work together, then as long as tax and company law require, normally 6 years.
• Mailing list details: until you unsubscribe.
• Server logs and website analytics: kept by our providers for no longer than 12 months, and never linked to your name or contact details.

10. Your rights

Your right to object. Where we rely on legitimate interests, you can object at any time. That includes contacting businesses, recording calls and using AI tools. We will stop unless we have compelling grounds that override your interests, or we need the data for a legal claim. If you object to direct marketing, we always stop. Email privacy@propersites.com or tell the person you are speaking to.

You also have the right to:

• ask for a copy of the personal data we hold about you;
• ask us to correct data that is wrong or incomplete;
• ask us to delete your data;
• ask us to restrict how we use it;
• receive the data you gave us in a portable format;
• ask for a person to review a decision made about you automatically (section 6); and
• withdraw your consent at any time, where consent is the basis we rely on.

To use any of these rights, email privacy@propersites.com. It is free. We may ask you to confirm who you are. We will reply within one month. If your request is complex we may need up to two more months, and we will tell you if so.

11. Cookies, analytics and local storage

We do not use advertising cookies, and we do not sell or share your data for advertising.

Analytics. We use Cloudflare Web Analytics and PostHog, EU region, to see which pages are visited and where people get stuck on our forms. Both run without cookies. PostHog runs in memory-only mode, so it stores nothing on your device and cannot recognise you on a later visit. We do not record your screen. If a page error happens, your browser type, the page address without any personal tokens and the error text are sent to PostHog (EU) so we can fix it, still without cookies or storage on your device.

Spam protection. Our forms use Cloudflare Turnstile to check that a person, not a bot, is sending them. It checks technical information from your browser and device to do that.

What we store on your device. A small "theme" cookie remembers whether you chose light or dark mode. If you arrive from a marketing link and send an enquiry or application from that page, we note the campaign details from the page address with your enquiry, so we know how you found us. We do not store them on your device. If you close our "book a consultation" prompt, it stays hidden for 14 days, and if you shrink it, it stays small for the rest of your visit. If you book, your browser remembers that until you clear it, so the prompt stops appearing. While you fill in a job application, your browser keeps a random reference number for it in session storage, which is cleared when you close the tab. You can clear all of these at any time in your browser settings.

If we ever add advertising or other non-essential cookies, we will update this notice and ask for your consent first where the law requires it.

12. Complaints

If you are unhappy with how we have handled your personal data, you can complain to us by email at privacy@propersites.com or by post to our registered office. We will acknowledge your complaint within 30 days, look into it without undue delay and tell you the outcome.

You can also complain to the Information Commissioner's Office (ICO) at any time, at ico.org.uk/make-a-complaint or by calling 0303 123 1113.

13. Changes to this notice

We update this notice when the way we use personal data changes, and publish the new version on this page with a new "last updated" date.