Last updated 4 Oct 2026
Who this covers
Cortex PPC ("Cortex") is private software built and operated by Phil Seaton to manage the advertising accounts he runs for his clients.
Phil Seaton is a trading name of LS Trader Limited, which runs this site and is responsible for your data (the “controller”).
LS Trader Limited, registered in England and Wales, company number 06967924
VAT number: GB 387 3497 42
Registered office: 6b Parkway, Porters Wood, St Albans, Hertfordshire, AL3 6PA, United Kingdom
Email: phil@cortexppc.com
This policy has two parts. The first covers the Google user data the Cortex software accesses. The second covers this website, cortexppc.com, and its waiting-list form. To get in touch about anything in it, use the contact form.
Part 1: Google user data and the Cortex software
Who uses Cortex
Cortex is not a public service. The only person who signs in to it is Phil Seaton, with his own Google account. It reaches client accounts only where the client has given Phil access.
Google user data Cortex accesses
- Google Ads: campaign structure, settings and performance data for accounts Phil manages.
- Google Merchant Centre: product feed data and product status for those clients.
- Google Analytics, Google Tag Manager and Google Search Console (read-only): site performance, tracking set-up and search data for those clients' websites and for Phil's own websites.
- Google Sheets and Google BigQuery: spreadsheets and datasets that Cortex creates or that Phil owns.
- Gmail and Google Calendar: Phil's own messages, drafts and calendar.
How the data is used
- To report on and analyse the advertising accounts Phil manages.
- To prepare account changes, which Phil approves before they are applied.
- To check product feeds, conversion tracking and search visibility for clients.
- To organise Phil's own email and calendar. Cortex sends email only to Phil himself, such as scheduled reports. It never emails anyone else.
Google user data is used only to provide these features. It is not used for advertising, not sold, and not used to develop, improve or train general-purpose AI or machine learning models.
Limited Use
Cortex's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
Sharing
- Reports about a client's account are shared only with that client.
- Data is processed by the service providers Cortex runs on: Google Cloud, a private server Phil rents, and AI services Phil uses to analyse data on his own behalf. They process it only to provide those features to Phil.
- Data is never sold or passed to data brokers or advertisers.
- Data may be disclosed where the law requires it.
Storage, security and retention
Data is kept on Phil's own computers, in his Google Cloud project and on a private server he controls, all protected by access controls. Data about a client's accounts is kept while Phil manages those accounts and is deleted on request or when the relationship ends.
Your choices
Clients can remove Phil's access to their accounts at any time from within each Google product. Access granted to Cortex can be revoked at myaccount.google.com/permissions. To ask for data to be deleted, use the contact form.
Part 2: this website and the waiting list
What the website collects
- The waiting-list and contact form: your name, email address, company (optional), what you're interested in, and your message.
- Technical data: when you visit, the hosting provider receives your IP address and browser details, as every website host does, to deliver the page and protect it from abuse.
The website has no analytics, advertising or tracking tools, and the fonts are served from this site rather than a third party.
Why it's used, and the legal basis
- Replying to your enquiry, including about account management: legitimate interests, and taking steps at your request before any contract.
- Telling you when Cortex opens to other advertisers: your consent, given by joining the waiting list. You'll get that news by email and nothing else unless you ask, and you can withdraw consent at any time through the contact form.
- Technical data: legitimate interests in running a secure website.
No decisions about you are made by automated means.
Who processes it
- Vercel hosts this website and handles the technical data.
- Namecheap hosts Phil's email and the handler that receives the form, on a server in the UK. Each submission is emailed to Phil there.
- Cloudflare protects that server, so form submissions pass through it on the way.
If you go on to exchange emails with Phil, he'll also hold that correspondence in his email account.
Form submissions are stored in the UK. Vercel and Cloudflare may process data outside the UK, including in the United States, while delivering the site and passing on the form. If you'd like to know how it is protected, ask Phil and he'll give you the details.
How long it's kept
Waiting-list entries are kept until Cortex opens and you've been told, or for two years, whichever comes first, and then deleted. If an enquiry doesn't lead to work, it's deleted within 12 months of the last contact. If we work together, correspondence and records are kept for six years after the work ends, because tax and legal rules require it, and then deleted. Technical data is kept by the host for a short period under its own retention settings. You can ask for your data to be deleted sooner at any time.
Your rights
You can ask to see the personal data held about you, have it corrected or deleted, restrict or object to how it's used, receive a copy to take elsewhere, or withdraw your consent. Use the contact form and you'll get a reply within one month.
Complaints
If you're unhappy with how your data has been handled, please tell Phil first through the contact form. He'll acknowledge your complaint within 30 days, look into it, and tell you what he found and what he's done about it. You also have the right to complain to the Information Commissioner's Office at ico.org.uk.
Cookies
The public pages of cortexppc.com (this policy and the home page) set no cookies and store nothing in your browser. The private sign-in area at bcc.cortexppc.com, which only Phil uses, sets strictly necessary cookies through its sign-in provider, Clerk, to keep him signed in. Strictly necessary cookies don't need consent under UK law.
Changes
If this policy changes, the updated version will be posted on this page with a new date.