Who is responsible
Kingswell Digital is a trading name of Kingswell Consulting Group Ltd, company number 17024099. Registered office: 5 Oaks Road, Stanwell, Staines-Upon-Thames, England, TW19 7JU. We are responsible for the personal information described here. Contact Usman.Qureshi@kingswell-consulting.com about your information or this notice.
Information we use and its sources
We record business names, websites, published business contact details and relevant observations about a business’s website and services. Some of these details identify an individual business contact. We obtain them from the business’s own public website and official public business records, including Companies House, and public business listings such as OpenStreetMap. We also keep correspondence you send us and your contact preferences. We do not use purchased contact lists for this pilot.
Why we use it
We assess whether our website services may be relevant, prepare a suitable concept or proposal, make a permitted business approach and respond to enquiries. Where this involves personal information, we rely on legitimate interests in offering relevant business services, balanced against people’s rights and reasonable expectations. Where electronic-marketing law requires consent, legitimate interests do not replace it.
AI-assisted tools may help research public business information or draft material. Research and document preparation may be automated; a person reviews the exact proposed message before any permitted approach. We do not make solely automated decisions with legal or similarly significant effects about you. Please do not send financial documents, payment details or sensitive personal information in response to an initial approach.
Access and service providers
Our records are held in a restricted local project system, Microsoft 365 business email and private SharePoint review storage. Private website concepts use protected Cloudflare hosting. Recovery copies are also held separately from active marketing records. A sanitised initial recovery package is prepared locally for private OneDrive for Business storage; it is not an active marketing database and excludes active credentials and unnecessary correspondence. Authorised research and drafting tools may process relevant public business information; we do not upload private customer correspondence or credentials as research material. We do not sell contact information or make our review folders public.
Our service providers may process information outside the UK. Where a restricted transfer is involved, the applicable arrangements must provide UK-recognised protection, such as contractual data-protection clauses with the UK Addendum. Contact us for the safeguards relevant to your information and how to obtain a copy. The applicable provider arrangements are recorded separately from this notice.
Retention
For inactive prospects, our policy is 90 calendar days from first collection for contact records, prospect-specific research and drafts. Internal review or regeneration does not restart that period. At expiry we stop further marketing use and arrange deletion or anonymisation under a tracked process. We do not treat restricting a record as proof that every copy has already been erased.
Active discussions and client records have a separate continuing purpose and are reviewed against the relationship and applicable business/legal requirements. We retain only the minimal information needed to honour an objection or do-not-contact request for as long as necessary to avoid contacting you again.
Deletion is a controlled process and is not an immediate wipe of every copy on day 90. Recoverable copies can remain in provider version history, deleted-item locations and restricted recovery backups. Those copies are kept out of ordinary marketing use. Before restored information can be used, it must be reconciled with current deletions and do-not-contact requests. Applicable legal retention or holds are handled separately. We track outstanding disposal rather than treating removal from the active register as proof that every copy has gone.
Your choice and rights
You can object to direct marketing at any time by replying or emailing Usman.Qureshi@kingswell-consulting.com. We stop marketing and record your preference; you do not have to continue a conversation.
Where applicable, you can ask to access, correct or erase your information, restrict use or object to processing. If we rely on consent, you can withdraw it without affecting earlier lawful use. Contact us at the address above. You can complain to the Information Commissioner’s Office: https://ico.org.uk/make-a-complaint/.