Privacy Policy
Last updated: 13.08.2026
studio/sturnell (“we”, “us”, or “our”) is the data controller for the website at www.sturnell.com (the “Site”).
Registered address: 29, Flat 1, Triq Antonio Schembri, Attard, ATD1420, Malta
Contact email: jeremy@sturnell.com
VAT number: MT18981433
This Privacy Policy explains how we collect, use, and protect your personal data when you visit our Site or contact us.
2. Personal data we collect
At present, we only collect personal data that you voluntarily provide to us, for example when you:
- Contact us via email or a contact form (if/when added), such as your name, email address, and any other information you choose to share.
- Correspond with us about projects, quotes, or collaborations.
We do not currently use analytics, advertising, or tracking technologies that automatically collect personal data about your browsing behaviour. If we introduce such tools in the future, we will update this policy and, where required, obtain your consent.
3. How we use your data
We may use your personal data to:
- Respond to your enquiries and communicate with you about potential or ongoing projects.
- Provide information about our services where you have requested it.
- Comply with legal obligations (e.g. tax, invoicing, record‑keeping).
Our legal bases for processing under the GDPR include:
- Performance of a contract or steps taken at your request before entering a contract (e.g. quotes, project discussions).
- Legitimate interests in operating our business and responding to enquiries, where this does not override your rights.
- Legal obligation where applicable (e.g. invoicing and tax records).
- Consent, if and when we use cookies or tracking that require it.
4. Sharing your data
We do not sell your personal data. We may share your data with:
- Service providers who help us run our business (e.g. email hosting, website hosting, invoicing/accounting tools), under appropriate data processing agreements.
- Professional advisers (e.g. lawyers, accountants) where necessary.
- Authorities where required by law.
All third parties are required to respect the security and confidentiality of your data and to process it only in accordance with our instructions and applicable law.
5. International transfers
If any of our service providers are located outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place (for example, EU Standard Contractual Clauses) to protect your data in line with GDPR requirements.
6. Data retention
We retain your personal data only for as long as necessary to:
- Provide our services and communicate with you;
- Comply with legal, accounting, or reporting obligations;
- Resolve disputes and enforce our agreements.
For example, we may keep contact and project‑related data for the duration of our business relationship and for a period thereafter as required by Maltese law (e.g. tax and invoicing records).
7. Your rights
Under the GDPR, you have the right to:
- Access the personal data we hold about you.
- Request correction of inaccurate or incomplete data.
- Request deletion of your data in certain circumstances.
- Object to or restrict certain processing activities.
- Request data portability where applicable.
- Withdraw consent at any time, where processing is based on consent (this does not affect the lawfulness of processing before withdrawal).
- Lodge a complaint with the Maltese data protection authority (Office of the Information and Data Protection Commissioner).
To exercise these rights, please contact us at jeremy@sturnell.com. We will respond within the timeframes required by law.
8. Security
We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorised access. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.
9. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be posted on this Site with a revised “Last updated” date. We encourage you to review this policy periodically.
10. Contact
If you have any questions about this Privacy Policy or our data practices, please contact us at:
studio/sturnell
Email: jeremy@sturnell.com
Address: 29, Flat 1, Triq Antonio Schembri, Attard, ATD1420, Malta