OnlySales
ONLYSALES.IE / YOUR PRIVACY
PRIVACY POLICY
Last updated: 16 October 2026
DRAFT FOR REVIEW — NOT YET APPROVED
Draft for final review — controller and business contact details have been supplied by Paddy Morgan. This policy describes voluntary personal enquiries, not a newsletter signup. Any remaining bracketed review notes are unresolved, not verified claims. The enquiry popup remains inactive pending your policy review and final test.
01 / INTRODUCTION
OnlySales respects your privacy. This policy explains how we handle personal information when you visit onlysales.ie or ask us to contact you about our digital marketing services. OnlySales is an Irish digital marketing agency operated by its owner personally as a sole trader, not a limited company. The popup is a voluntary enquiry form, not a newsletter signup.
Data controller: Paddy Morgan, trading as OnlySales, a sole trader. The controller decides why and how personal information is used. Business contact address: 34 Brighton Avenue, Foxrock, Dublin, Ireland. Privacy contact: socials@onlysales.ie.
02 / INFORMATION WE COLLECT
Popup enquiries: your email address, your affirmative permission to be contacted about your enquiry, the exact checkbox wording, the submission time and privacy-policy URL and version. Submissions also include an enquiry-purpose label, source and submission identifier. These fields record an enquiry request, not a newsletter subscription.
Enquiries and consultations: the name, email address, business details, service interests and messages you voluntarily provide. If you choose to include a phone number or other contact details in your message, we receive those too; this does not mean every form asks for a phone number.
Technical and usage information: the published website loads Framer’s built-in analytics. The reviewed scripts send page-visit and performance information, including the visited URL, referrer, timezone, locale and site identifiers, to Framer. Hosting and form services may also process connection/request information to provide their services. [TO VERIFY: account-specific logging, retention and the complete runtime data inventory.]
03 / HOW WE USE INFORMATION
We use your email address to respond personally to your enquiry. Your request is submitted through Formspree, which sends a notification to socials@onlysales.ie. OnlySales then contacts you personally using Microsoft 365 / Outlook to introduce the business, discuss how its digital marketing services may help, and potentially arrange a consultation.
We also use information you voluntarily provide to deliver requested services and manage related client communications. Submitting the popup does not add you to a newsletter or promotional mailing list. We do not use this process to send automated promotional campaigns.
04 / LEGAL BASIS
Voluntary popup follow-up: your specific, affirmative consent to be contacted about your enquiry (GDPR Article 6(1)(a)). The required checkbox records this limited permission. It is not consent to a newsletter, a promotional mailing list or automated marketing campaigns. You may withdraw this contact permission at any time.
Where you ask us to take steps towards a service agreement with you, or we deliver agreed services to you, the legal basis may be steps at your request before entering a contract or performance of that contract (Article 6(1)(b)).
Other business enquiries and routine client administration may rely on legitimate interests in responding to business contacts and managing working relationships (Article 6(1)(f)), subject to your rights and an appropriate balancing assessment. This does not permit unrelated promotional campaigns. [TO CONFIRM: the lawful basis and assessment for the installed Framer usage analytics before approving this policy.]
Records required by law: compliance with a legal obligation (Article 6(1)(c)), only where a specific obligation actually applies. [TO CONFIRM: any such obligations and the records affected.]
05 / ENQUIRIES AND CONTACT PERMISSION
The popup says: “Leave your email and we’ll get in touch to discuss how OnlySales can help grow your business.” Its checkbox says: “I agree to be contacted by OnlySales about my enquiry.” The checkbox is unchecked by default, requires an affirmative action and must be selected to submit this enquiry form. The submission records the choice, exact wording, time and privacy-policy details.
You can ask OnlySales to stop following up or withdraw this permission by contacting socials@onlysales.ie or replying to the personal email you receive. Withdrawal does not affect the lawfulness of processing before withdrawal. Information may still need to be retained for another applicable lawful purpose, as explained below.
This permission is limited to personal contact about your enquiry. There is no automatic newsletter subscription and no automated promotional campaign. The popup sends the enquiry and a notification; OnlySales personally handles the response through Microsoft 365 / Outlook.
06 / THIRD-PARTY SERVICES
Framer is the website platform. The existing consultation/contact form uses Framer’s form functionality to send enquiries to the OnlySales business inbox.
Formspree processes popup enquiry submissions and sends notifications to socials@onlysales.ie. It receives the email address and enquiry-permission record described above.
Microsoft 365 / Outlook is the confirmed business email service used to receive enquiry notifications and personally contact enquirers. Framer, Formspree and Microsoft 365 / Outlook are the services identified for this process; no additional mailing-list or automated campaign service is part of it.
07 / DATA RETENTION
Inactive enquiry records are reviewed after 24 months of inactivity and deleted or anonymised when no longer necessary, unless another lawful retention reason applies. This review applies to the enquiry records held through Formspree, relevant Framer form records and Microsoft 365 / Outlook, including notification copies and correspondence. It is a review criterion, not a promise that every record is automatically deleted on the 24-month date.
[TO CONFIRM BEFORE PUBLICATION: who carries out the review, how deletion or anonymisation is implemented across the relevant services and copies, any applicable backup-deletion arrangements, and the actual retention criteria for client records, evidence of contact permission and records kept for legal obligations.] If another lawful reason requires retention, keep only the information necessary for that reason and review it accordingly.
08 / DATA SHARING AND INTERNATIONAL TRANSFERS
Information is shared with the providers needed to host the website, process the enquiry and deliver and manage personal email correspondence: Framer, Formspree and Microsoft 365 / Outlook. Access within OnlySales should be limited to people who need the information for those purposes. This enquiry process does not automatically transfer addresses to a promotional mailing list.
Framer’s public Data Processing Addendum (version 2.0, effective 16 June 2026) identifies Framer B.V. as a processor and provides for international transfers using applicable adequacy decisions or contractual safeguards, including the EU Standard Contractual Clauses where required. These published terms do not by themselves verify OnlySales’ account agreement, processing locations or particular subprocessor transfers.
Formspree, Inc.’s public privacy policy states that information is processed in the United States and other countries where it operates. [TO VERIFY BEFORE PUBLICATION: Formspree’s applicable Article 28 data-processing agreement and specific Chapter V transfer safeguard; Microsoft 365’s contracting entity, tenant data location and applicable DPA/transfer safeguards; and account-specific Framer subprocessor/transfer details.] We have not verified a particular certification or safeguard for these account-specific transfers. Contact socials@onlysales.ie to request information about applicable safeguards once confirmed. Enquiry-contact permission is not consent to an otherwise unsupported international transfer.
09 / DATA SECURITY
We aim to use reasonable technical and organisational measures appropriate to the personal information we handle. No website or email system can be guaranteed completely secure, so please do not include unnecessary sensitive information in a general enquiry.
[TO CONFIRM: OnlySales’ actual access controls, account protection, handling procedures and provider settings.] We do not claim any unverified security certification.
10 / YOUR GDPR RIGHTS
Depending on the circumstances, you may ask to access your personal information; correct inaccurate or incomplete information; erase information; restrict processing; receive information in a portable format; or object to processing based on legitimate interests. Where processing relies on consent, you may withdraw it at any time. You may also object to direct marketing if it ever occurs; the enquiry process described in this policy is not a newsletter or automated campaign.
Contact socials@onlysales.ie to exercise your rights. We may need proportionate information to verify your identity. Rights are subject to the GDPR’s conditions and exceptions. We will respond without undue delay and normally within one month; if an extension is permitted, we will explain the reason and timing.
11 / COMPLAINTS
You may contact us first at socials@onlysales.ie if you have a concern. You also have the right to complain to Ireland’s Data Protection Commission. Information on making a complaint is available at dataprotection.ie.
12 / COOKIES AND ANALYTICS
The enquiry popup uses sessionStorage with the key “onlysales:enquiry:session:v1” to limit repeat display during the current browser-tab session. After Formspree accepts an enquiry, localStorage with the key “onlysales:enquiry:submitted:v1” remembers that this browser has already submitted an enquiry. These markers contain no email address or contact-permission record and do not subscribe anyone to a list. Storage may be cleared or unavailable, so repeat-display controls are not guaranteed.
The published website loads Framer analytics from events.framer.com. The reviewed analytics script sends page-view/performance events to its /anonymous endpoint and contains no cookie, localStorage or sessionStorage access. No Google Analytics, Meta advertising pixel, Hotjar or Microsoft Clarity installation was identified in the reviewed HTML and analytics/main-loader sources. This limited source review is not proof that no other tracking, cookies or storage can occur.
[REVIEW REQUIRED BEFORE APPROVAL: complete a fresh-browser network and storage audit, verify Framer analytics settings and the applicable GDPR basis, and assess whether any prior Irish ePrivacy consent controls are needed. Also review the persistent enquiry-suppression marker’s necessity and duration; it currently has no programmed expiry.] Do not deploy technologies requiring prior consent without appropriate controls. Permission to be contacted about an enquiry is not consent to cookies or analytics.
13 / CONTACT
For privacy questions, GDPR requests, deletion requests, or to ask us not to contact you again, email socials@onlysales.ie. You can also reply directly to the personal email sent from OnlySales.
Controller: Paddy Morgan, trading as OnlySales (sole trader). Business contact address: 34 Brighton Avenue, Foxrock, Dublin, Ireland. Privacy email: socials@onlysales.ie.
14 / CHANGES TO THIS POLICY
We may update this policy when our services, providers, legal requirements or data practices change. The “Last updated” date will identify the current version. Where required, we will provide additional notice or seek fresh consent before a new use of your information.