1. Purpose

Computerko Limited is committed to protecting personal data and processing it lawfully, fairly, securely, and transparently.
This GDPR / Data Protection Policy explains how Computerko Limited governs personal data across its business operations as a managed IT provider, cloud and hosting provider, and business technology supplier. It sets out our approach to compliance, accountability, security, data sharing, and the use of third-party providers.

This policy applies alongside our Privacy Policy, Cookie Policy, Terms of Sale, and any customer-specific agreements, including any data processing terms where we act on behalf of customers.

2. Company Details

Company name: Computerko LimitedRegistered office: 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom
Contact email: support@computerko.co.uk

Computerko Limited is a registered company in England and Wales.
3. Scope
This policy applies to all personal data processed by Computerko Limited in connection with:
website enquiries and customer communications;
quotations, orders, billing, and fulfilment;
managed IT support and service delivery;

• hosting, cloud, domain, email, and infrastructure services;
• backup, security, monitoring, and endpoint services;
• DaaS, TaaS, finance-related processing, and related administration;
• supplier, distributor, and partner interactions; and
• internal business operations.

This policy applies to directors, employees, contractors, consultants, temporary staff, and any third party acting on behalf of Computerko Limited where personal data is processed.
4. Data Protection Principles
Computerko Limited will process personal data in accordance with the following principles:
lawfully, fairly, and transparently;
for specified, explicit, and legitimate purposes;
only to the extent necessary for those purposes;
accurately and, where necessary, kept up to date;
retained only for as long as necessary;

• securely and with appropriate technical and organisational measures; and
• in a way that supports accountability and demonstrable compliance.

5. Roles and Responsibilities

Computerko Limited may act as either:

• a Data Controller, where we determine the purposes and means of processing personal data; or
• a Data Processor, where we process personal data on behalf of a customer and under that customer’s instructions.

5.1 Controller Activities

Computerko Limited will generally act as a Data Controller in relation to:
website operation;
enquiries and lead handling;
quotations and customer account management;

• billing, payment collection, and financial administration;
• supplier and partner management;
• recruitment and administration;
• internal security, fraud prevention, and compliance processes; and
• direct business communications where lawful.

5.2 Processor Activities

Computerko Limited may act as a Data Processor where we provide services on behalf of customers, including:
managed IT support;
hosting and cloud services;
backup and disaster recovery;
endpoint and device management;
monitoring and maintenance;
service desk and support delivery;

• application hosting and managed infrastructure; and
• other managed technical services where the customer remains the Data Controller.

Where we act as a processor, we will process personal data only on documented customer instructions, unless otherwise required by law.

6. Categories of Personal Data

Depending on the context, Computerko Limited may process:
names;
business contact details;
employer or organisation details;
account and login information;
delivery and billing details;
payment-related information;
order and fulfilment data;
support and communication records;
technical and diagnostic information;
IP addresses and device metadata;
audit, access, and security logs;
domain registration information;
service usage data; and

• any other personal data reasonably required to provide services or manage the business relationship.

Computerko Limited does not intentionally process more personal data than is reasonably necessary for the relevant purpose.
7. Lawful Basis
Where Computerko Limited acts as a Data Controller, personal data will be processed on one or more of the following lawful bases:
performance of a contract;
steps prior to entering into a contract;
compliance with legal obligations;
legitimate interests;
consent, where required; and
vital interests, where exceptionally necessary.
Where Computerko Limited acts as a Data Processor, we will process personal data on behalf of the relevant Data Controller in accordance with their instructions and the applicable contractual framework.
8. Use of Personal Data

Personal data may be processed for the following purposes:

• responding to enquiries;
• preparing quotations and proposals;
• fulfilling orders;
• arranging delivery and service implementation;
• providing managed services and support;
• operating hosting, cloud, email, and domain services;
• invoicing, payment collection, and account management;
• administering direct debit or finance-supported arrangements;
• fraud prevention, security monitoring, and compliance;
• warranty, repair, return, and fulfilment coordination;
• maintaining service records and audit trails;
• carrying out regulatory, legal, or contractual obligations; and
• improving service delivery and operational performance.

9. Security and Confidentiality

Computerko Limited will implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, alteration, disclosure, or damage.
These measures may include:
role-based access controls;
account authentication controls;
device and endpoint security;
secure hosting and infrastructure controls;
restricted access to support and admin systems;
audit logging and monitoring;
backup and recovery controls;
secure configuration and maintenance processes;

• staff awareness and confidentiality obligations; and
• controlled engagement of third-party providers.

Access to personal data will be limited to those who require it for legitimate business or service-delivery reasons.

10. International Transfers

Where personal data is processed outside the United Kingdom, or where overseas access may occur through a provider or infrastructure arrangement, Computerko Limited will take reasonable steps to ensure that appropriate safeguards are in place.

Such safeguards may include contractual protections, provider commitments, and risk-based due diligence appropriate to the service and the nature of the data involved.

11. Data Retention

Computerko Limited will retain personal data only for as long as reasonably necessary for:
the purpose for which it was collected;
the performance of contracts;

• regulatory, tax, accounting, and legal obligations;
• support and audit requirements;
• security and incident investigation;
• dispute resolution; and
• the establishment, exercise, or defence of legal claims.

Retention periods may vary depending on the data category, service type, and contractual or regulatory context.

12. Data Subject Rights

Where applicable and where Computerko Limited acts as Data Controller, individuals may have the right to:
access their personal data;
correct inaccurate data;
request erasure;
restrict processing;
object to processing;
request portability; and

• withdraw consent where processing is based on consent.

Where Computerko Limited acts as Data Processor, we will assist the relevant controller as appropriate and in accordance with contractual obligations.
13. Personal Data Breaches
Requests should be sent to: support@computerko.co.uk

Any suspected or actual personal data breach must be reported internally without delay.

Computerko Limited will assess the nature, scope, and impact of the incident and will take appropriate steps to:
contain and investigate the issue;
preserve relevant evidence;
mitigate risk;
notify the relevant controller where required;
notify regulators where required by law; and
maintain records of the incident and response.
14. AI and Automation
Computerko Limited may use AI and automation at a computational, infrastructure, and operational level to support system performance, monitoring, and service efficiency.
Computerko Limited does not train AI models on identifiable personal data as part of its standard operations.

Any AI-assisted output remains subject to human oversight and review.

Computerko Limited will continue to review its use of AI and automation to ensure alignment with data protection, security, and ethical standards.
15. Third-Party Providers and Sub-Processors
Computerko Limited may use third-party providers, partners, and service platforms in order to deliver goods and services, process payments, manage fulfilment, provide cloud or infrastructure services, and support core business operations.

Where personal data is shared with or processed by such providers, this will be done only where necessary and subject to appropriate contractual, operational, or legal controls.

15.1 Sub-Processor / Third-Party Provider Table

15.2 Provider Governance

Computerko Limited will take reasonable steps to ensure that third-party providers handling personal data:
are engaged for legitimate business purposes;

• receive only the data reasonably necessary for the relevant service;
• are subject to contractual, commercial, or operational controls where appropriate;
• are reviewed periodically in line with service and risk requirements; and
• are used in a manner consistent with applicable data protection obligations.

16. Customer Data Processed on Instruction

Where Computerko Limited acts on behalf of a customer as processor, we will:

• process personal data only on documented instructions;
• maintain appropriate confidentiality;
• implement appropriate security measures;
• support customers in meeting relevant data protection obligations where agreed or required;
• notify customers of relevant data incidents without undue delay where applicable; and
• use subprocessors only in line with appropriate governance and contractual arrangements.

17. Accountability and Governance

Computerko Limited will maintain appropriate governance measures to support compliance, which may include:
policy and process reviews;
staff awareness and training;
access control oversight;
provider and service reviews;
incident and risk monitoring;

• records relating to processing and service delivery; and
• periodic review of this policy and related notices.

18. Review and Updates

This policy will be reviewed regularly and may be updated from time to time to reflect changes in:

• legal requirements;
• business operations;
• technology platforms;
• service delivery arrangements; and
• risk profile.

19. Contact

If you have any questions about this policy or Computerko Limited’s approach to data protection, please contact:
Below is a draft Cookie Policy for Computerko Limited.
Computerko Limited27 Old Gloucester StreetLondonWC1N 3AXUnited KingdomEmail: support@computerko.co.uk