1. Introduction
Headline Access ('we', 'us', 'our') is a paid membership community operated by Ian Turner, registered in the United Kingdom. We connect small business owners with journalists, TV producers, and podcast hosts through our platform at headlineaccess.com.
This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
By using our website or services, you confirm that you have read and understood this Privacy Policy. If you do not agree, you should not use our services.
2. Who We Are (Data Controller)
The data controller responsible for your personal data is:
Ian Turner
Headline Access
Address: Unit 13 The Beresford Centre, Wade Road, Basingstoke, RG24 8FA, England
Email: hello@headlineaccess.com
Website: headlineaccess.com
As a UK-based operator with customers predominantly located in the United States, we process personal data in accordance with UK GDPR. We also take reasonable steps to comply with applicable US state privacy laws including the California Consumer Privacy Act (CCPA/CPRA) where relevant.
3. What Data We Collect
3.1 Data You Provide Directly
When you register, subscribe, or contact us, we may collect:
- Full name
- Email address
- Business name and type
- Location (country, state/region)
- Payment information (processed securely by Stripe — we do not store card details)
- Communications you send to us (e.g., support emails)
- Profile information you add to the platform (e.g., bio, expertise areas)
3.2 Data Collected Automatically
When you visit headlineaccess.com, we may automatically collect:
- IP address
- Browser type and version
- Pages visited and time on site
- Referring URLs
- Device and operating system information
This data is collected through standard web server logs and, where applicable, analytics tools.
3.3 Data From Third Parties
We may receive limited personal data from third-party services we use, including:
- Stripe: Payment confirmation and subscription status (not card details)
- Kit (formerly ConvertKit): Email engagement data for subscribers who join our mailing list
- Facebook: Basic profile data if you join via our Facebook Group (governed by Meta's own privacy policy)
4. How We Use Your Data
We use your personal data only for the following purposes and legal bases:
| Purpose | Legal Basis |
|---|---|
| To provide and manage your membership account | Contractual necessity |
| To process payments via Stripe | Contractual necessity |
| To send service-related communications (e.g., receipts, account notices) | Contractual necessity |
| To send marketing emails about Headline Access (where you have opted in) | Legitimate interest / Consent |
| To moderate community activity and enforce our Terms & Conditions | Legitimate interest |
| To improve our website and services | Legitimate interest |
| To comply with legal obligations | Legal obligation |
5. Marketing Communications
We may send you marketing emails about Headline Access, new features, or relevant community news. You can unsubscribe at any time by clicking the unsubscribe link in any email, or by emailing hello@headlineaccess.com.
We use Kit (formerly ConvertKit) to manage email marketing. Your email address and name are stored on Kit's servers, which are based in the United States. Kit is certified under the EU-US Data Privacy Framework and complies with applicable data transfer requirements.
We will never sell, rent, or share your email address with third parties for their marketing purposes.
6. Cookies
Our website may use cookies — small text files stored on your device — to:
- Ensure the website functions correctly (essential cookies)
- Analyse how visitors use the site (analytics cookies)
- Remember your preferences (functional cookies)
You can control cookie settings through your browser. Disabling cookies may affect the functionality of some parts of the site. We will display a cookie consent notice on first visit where required by law.
7. How We Share Your Data
We do not sell your personal data. We share personal data only with the following categories of recipients, where necessary to provide our service:
- Stripe, Inc. — Payment processing. Stripe's privacy policy is available at stripe.com/privacy.
- Kit (ConvertKit, LLC) — Email marketing and list management.
- Hosting and infrastructure providers — Where our website and community platform is hosted.
- Legal or regulatory authorities — Where required by applicable law or in connection with legal proceedings.
All third-party processors are contractually required to handle your data securely and in accordance with applicable data protection law.
8. International Data Transfers
Headline Access is operated from the United Kingdom. Our primary members are based in the United States. Some of our service providers (including Stripe and Kit) are based in the United States.
Where we transfer personal data outside the UK, we rely on:
- Adequacy decisions where applicable
- Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (ICO)
- The UK International Data Transfer Addendum (IDTA) where relevant
By using our services, you acknowledge that your data may be processed in the United States or other countries where data protection laws may differ from those in the UK.
9. Data Retention
We retain your personal data for as long as your account is active, plus a reasonable period thereafter for legal, tax, and legitimate business purposes. Specifically:
- Account and billing data: 7 years from the end of your subscription (HMRC requirements)
- Email marketing data: Until you unsubscribe or request deletion
- Community content and messages: For the duration of your membership; deleted within 30 days of account closure on request
- Website analytics data: Up to 26 months
10. Your Rights (UK GDPR)
Under UK GDPR, you have the following rights:
- Right of access — You may request a copy of the personal data we hold about you.
- Right to rectification — You may ask us to correct inaccurate or incomplete data.
- Right to erasure ('right to be forgotten') — You may request deletion of your personal data, subject to legal obligations.
- Right to restriction — You may ask us to restrict processing of your data in certain circumstances.
- Right to data portability — You may request your data in a structured, machine-readable format.
- Right to object — You may object to processing based on legitimate interests, including direct marketing.
- Rights related to automated decision-making — We do not make solely automated decisions that significantly affect you.
To exercise any of these rights, email us at hello@headlineaccess.com. We will respond within one calendar month. We may ask you to verify your identity before fulfilling a request.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
11. California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
- The right to know what personal information we collect, use, disclose, or sell
- The right to delete personal information we hold about you (subject to certain exceptions)
- The right to correct inaccurate personal information
- The right to opt out of the sale or sharing of personal information — we do not sell personal information
- The right to non-discrimination for exercising your privacy rights
To exercise these rights, email hello@headlineaccess.com. We will not discriminate against you for exercising your CCPA/CPRA rights.
12. Children's Privacy
Headline Access is intended for adults operating businesses. We do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has provided us with personal data, please contact hello@headlineaccess.com and we will delete it promptly.
13. Security
We implement appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, alteration, or disclosure. These include:
- HTTPS encryption for all website traffic
- Secure payment processing via Stripe (PCI DSS compliant)
- Access controls limiting who can access personal data within our systems
No method of transmission or storage is 100% secure. We cannot guarantee absolute security, but we take our obligations seriously.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will update the effective date at the top of this document and, where changes are significant, notify members by email or a notice on the platform. Continued use of our services after the updated policy is posted constitutes acceptance of the revised terms.
15. Contact Us
For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:
Email: hello@headlineaccess.com
Website: headlineaccess.com
Operated by: Ian Turner, Headline Access, United Kingdom
This Privacy Policy was prepared for Headline Access. It should be reviewed by a qualified legal professional before publication. It does not constitute legal advice.