What personal data this tool processes, why, and what you can do about it. In short: the tool uses cookies and similar technologies (in fact your browser’s storage) only to keep your choices, between visits only if you accept; it has no analytics, advertising or tracking, and asks you for no personal details. The only personal data involved is what any web host receives in serving a page, and your choices in the tool are kept on your own device as you decide.
Last changed 11 October 2026
Who we are
The tool is operated by Enkefalos Holdings Ltd, a company registered in England and Wales under company number 17301883, based in London. In this notice “we” means Enkefalos Holdings Ltd. We are the controller of the personal data described here, which means we decide why and how it is processed.
The tool was made for Gallagher Specialty and is intended to be hosted by Gallagher. Until it is, Enkefalos Holdings Ltd runs it as a preview.
To ask about this notice or about your personal data, write to alexander@enkefalos.co.uk.
What the tool does not do
The tool has no accounts, no sign-in and no forms for you to fill in. It uses cookies and similar technologies only to keep your choices in the tool: for your visit, and between visits only if you accept (see the Cookie policy). It has no analytics, no advertising and no tracking of any kind, and it loads nothing from other websites: its fonts, images and scripts are served with its pages.
What you choose in the tool, and anything you export from it, is worked out in your browser and is never sent to us or to anyone else. We do not profile you, and no decision about you is made by automated means.
The personal data we process
When your browser asks for a page, the web host that serves the tool receives the request, as every web host does. A request carries your device’s IP address, the time, the address of the page asked for, the page that linked to it where your browser sends that, and details your browser gives about itself, such as its name and version and the kind of device it runs on. The host may record these in its logs.
That is the only personal data the tool’s operation involves. We do not use it to identify you, and we do not combine it with anything else.
Why we process it, and on what basis
The host uses these details to send you the pages you ask for, to keep the site secure (for example, by detecting and blocking attacks and abuse) and to find and fix faults.
The lawful basis is our legitimate interests (Article 6(1)(f) of the UK GDPR). Our interests are in serving the tool to the people who use it, keeping it secure and available, and keeping it working. We have weighed them against yours: the details are those any website receives, a page cannot be served without them, they are kept only for a short time, and they are not used to identify or profile anyone. You have the right to object, as set out under “Your rights” below.
Who receives it
The tool is hosted by Vercel Inc., which serves its pages and keeps the logs described above. It acts as our processor: it handles this data on our behalf, under its data processing terms.
We do not sell personal data or share it with anyone else. We would disclose it only where the law requires us to.
Transfers outside the United Kingdom
Vercel Inc. is based in the United States, and the data it processes may be held or accessed there, and in other countries where it runs its service. Where personal data goes to a country that UK law does not recognise as giving it adequate protection, the host’s data processing terms provide the safeguards UK law requires for the transfer. You can ask us for a description of those safeguards at alexander@enkefalos.co.uk.
How long it is kept
The host keeps its request logs only for a limited period under its own retention policies, after which they are deleted. We do not export the logs or keep copies of them.
What is kept on your device
The tool keeps your choices in it (the clubs you have chosen to compare, the club you are reviewing and the view on screen) in your browser’s storage, on your own device: for your visit, and between visits only if you accept. Nothing in this storage is sent to us or to anyone else, and none of it identifies you. The Cookie policy says what is kept, why, for how long, and how to change your answer.
So far as these choices are personal data at all, the basis for keeping them between visits is your consent (Article 6(1)(a) of the UK GDPR), which you can withdraw at any time; for keeping them during your visit, and for the record of your answer, it is our legitimate interest in providing the tool you have asked for.
Links to other websites
The Data page links to the clubs’ own published documents on their websites. Those websites have their own privacy notices, and this notice does not cover them.
If you write to us
If you write to us, we receive your email address, your name if you give it, and what you write. We use them only to answer you, on the basis of our legitimate interest in answering questions about the tool, and keep them for as long as we need to deal with your message.
Your rights
Under the UK GDPR you have the right to:
- be told how your personal data is used, which is what this notice is for;
- have access to the personal data we hold about you;
- have personal data that is wrong corrected (rectification);
- have your personal data erased;
- have its processing restricted;
- object to processing based on our legitimate interests;
- receive personal data you have given us in a form you can take elsewhere (portability), where its processing is based on your consent or a contract and carried out by automated means;
- withdraw your consent at any time, without affecting what was done before; for this tool, that means choosing “Decline all” under “Storage choices”.
Some of these rights apply only in certain circumstances. To use any of them, write to alexander@enkefalos.co.uk. We will answer within one month and will not charge you. We hold nothing that links a log entry to a name, so to find one we would need details such as your IP address and the time of your visit. The choices kept in your browser are on your device, not with us, and you can see or delete them yourself at any time.
Complaints
If you are unhappy with how we have handled your personal data, please tell us first, at alexander@enkefalos.co.uk. You also have the right to complain to the Information Commissioner’s Office, the UK’s regulator for data protection: at ico.org.uk, or by telephone on 0303 123 1113.
Changes to this notice
We will update this notice when what the tool does with personal data changes, for example if it moves to a new host or gains a sign-in. This notice was last changed on 11 October 2026.