This policy covers the semitro.com website. Browsing it collects nothing about you. The only time we handle your personal data is when you choose to book a call, and even then the booking itself is handled by Calendly, not stored by us. The Semitro software product (app.semitro.com) has its own data processing terms provided to customers at sign-up.
Miller Capital Ltd (trading as Semitro) is the data controller for personal data handled through semitro.com. We are registered in England and Wales. Our registered address is available on request.
You can reach our data protection point of contact at: luke@semitro.com.
Browsing semitro.com: nothing. We do not set cookies, run analytics, record sessions, or build any profile of your visit. There is no tracking on this site.
Booking a call. If you start the short qualifier you answer four questions (business type, monthly revenue, team size, and your business), then pick a time. The scheduling, and your name and email, are handled by Calendly, which is the controller for that booking under its own privacy policy. Your answers travel with the booking as metadata. We do not store any of it. When a booking is made we receive a notification email so we can prepare for the call, delivered to our inbox by Resend and not kept in any database.
| Data | Purpose | Legal basis | Where it lives |
|---|---|---|---|
| Your name and email (entered into Calendly when you book) | Schedule, confirm, and hold the call with you | Steps taken at your request before entering a contract | Held by Calendly; emailed to us for the call, not stored in our systems |
| Your answers to the four qualifying questions | Understand your business before we speak | Steps taken at your request before entering a contract | Attached to the Calendly booking; emailed to us, not stored |
We keep no marketing database, so there is very little to handle. The companies below are the only third parties involved when you book a call, and only then.
| Company | Role | Location | Transfer mechanism |
|---|---|---|---|
| Calendly LLC | Scheduling. Holds your name, email, and answers for the booked call, as controller under its own policy | United States | UK-US Data Bridge and/or IDTA-amended Standard Contractual Clauses |
| Resend Inc. | Delivers the booking notification email to us. Processes your name and email in transit only | United States | UK-US Data Bridge and/or IDTA-amended Standard Contractual Clauses |
| Vercel Inc. | Hosts the website and runs the webhook that triggers the notification email | United States | UK-US Data Bridge and/or IDTA-amended Standard Contractual Clauses |
We will update this table if the companies involved change. We will not introduce a new one that materially changes how your data is handled without updating this policy first.
The companies listed above are based in the United States. Transfers of your personal data to the US are protected by the UK-US Data Bridge, an adequacy framework recognised by the UK government in October 2023. Where a specific company is not certified under the Data Bridge, we rely on UK International Data Transfer Agreements (IDTAs) incorporating the UK Addendum to the EU Standard Contractual Clauses.
If you would like a copy of the transfer mechanisms relied on for any specific company, contact us at luke@semitro.com.
We do not keep a database of your personal data, so for us there is nothing to retain. Your data lives in only two places:
Calendly holds your booking (name, email, answers, and meeting time) under its own retention policy. You can ask Calendly, or ask us, to delete it.
Our inbox holds the booking notification email as ordinary business correspondence. We delete it on request, and routinely once the call has passed and it is no longer needed.
You can request deletion at any time, see Section 07 below.
Under UK GDPR, you have the following rights in relation to your personal data. You can exercise any of these by emailing luke@semitro.com. We will respond within one calendar month (we may extend this by two further months for complex requests, and will notify you if so).
You have the right to obtain confirmation of whether we process personal data about you, and if so, a copy of that data along with information about how it is processed, where it is stored, and with whom it is shared.
If any personal data we hold about you is inaccurate or incomplete, you have the right to have it corrected.
You have the right to request deletion of your personal data. We hold no marketing database, so for most visitors there is nothing for us to delete. Where your booking sits with Calendly, we will help you have it erased and you can also contact Calendly directly.
In certain circumstances, you can request that we pause processing of your data, for example while a query about its accuracy is resolved.
For data you provided directly and that we process by automated means on the basis of consent or contract, you have the right to receive it in a structured, commonly used, machine-readable format.
You have the right to object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms. You have an unconditional right to object to direct marketing.
We do not set cookies or otherwise rely on your consent to process data on this site, so there is nothing to withdraw. If that ever changes, you will be able to withdraw consent at any time, and doing so would not affect processing that happened beforehand.
If you are not satisfied with how we have handled your data, you can lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or by calling 0303 123 1113.
We take reasonable and appropriate measures to protect personal data against loss, unauthorised access, disclosure, alteration, or destruction. Specifically:
No system is perfectly secure. If you believe your data has been subject to a breach, please contact us immediately at luke@semitro.com.
This website is not directed at children under the age of 13. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.
We may update this policy from time to time, for example when the companies involved change, we introduce new data collection, or in response to changes in law. The “Last updated” date at the top of this page will always reflect the most recent version. For material changes, we will make a reasonable effort to notify affected users (for example, via a notice on the website or by email if we hold your address). Continued use of the website after a material change constitutes acceptance of the updated policy.
For any questions about this policy, to exercise your rights, or to request a copy of the transfer safeguards we rely on:
We aim to respond to all enquiries within 5 business days.