Privacy Policy

1. Who we are

Twisthand Intelligence Ltd is the data controller for the personal data described here. Registered in England and Wales, company number 17077464. Registered office: 16 Commerce Square, Nottingham NG1 1HS. ICO registration: we have paid the ICO data protection fee, and our registration number will be added here as soon as it's issued.

Data protection contact: Javan Green, founder · [email protected] · 0330 043 2489.

2. What we collect

• When you contact us or book a call: your name, email address, phone number, company, job title, and whatever you tell us about your organisation and what you need.
• When we work together: business contact details for the people involved, meeting notes, emails, and the working documents the engagement needs.
• When you visit the site: standard server logs (such as IP address, browser type and pages requested), used to keep the site running and secure. We don't run analytics or advertising trackers. See the Cookie Policy.
• Event invitations: if you ask for an invitation to one of our events, your name, email, company and any dietary or access needs you choose to share.

We don't ask for special category data (such as health information), apart from dietary or access needs you volunteer for an event, which we use only for that event.

3. How we use it, and our lawful basis

We don't sell personal data, and we don't use it for automated decision-making or profiling.

4. Client data on engagements

When we work on your systems or data as part of an engagement, we act on your instructions and within your approved tools and policies, as set out in our Terms of Service and your statement of work. Where we process personal data on your behalf, we agree data processing terms with you before we start. That client data is covered by those terms, not by this policy.

5. Who we share it with

We share personal data only with service providers who help us run the business, and only what they need:

• Email and documents: Google Workspace
• Call booking: Calendly (when you book a call; Calendly's own privacy notice applies to what you enter)
• Website hosting: Cloudflare
• Accounting and invoicing: Zoho Books
• Professional advisers such as our accountant or solicitor, under a duty of confidentiality

We also disclose data where the law requires it.

6. International transfers

Some of these providers may process data outside the UK. Where they do, they rely on safeguards recognised under UK data protection law, such as the UK International Data Transfer Agreement or Addendum, the UK Extension to the EU–US Data Privacy Framework, or an adequacy decision.

7. How long we keep it

• Enquiries that don't lead to work: up to 12 months after our last contact.
• Engagement records: for six years after the engagement ends, in case of questions or claims.
• Financial records: six years from the end of the financial year they relate to, as HMRC requires.
• Event invitations: until the event has finished, then deleted, apart from a simple attendee list kept for up to 12 months.

After that, we delete or anonymise it.

8. How we protect it

Access is limited to Javan Green and anyone working with us under a confidentiality agreement. We use multi-factor authentication and encrypted devices, keep our systems updated, and use reputable providers with strong security. No system is perfectly secure; if a breach affected your data in a way that put you at risk, we would tell you and, where required, the ICO.

9. Your rights

You have the right to access your data, to have it corrected, to have it deleted, to restrict or object to how we use it, to receive it in a portable format, and to withdraw consent where we rely on consent. To use any of these, email [email protected]. We'll respond within one month. There's normally no charge.

If you're unhappy with how we've handled your data, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113.

10. Changes to this policy

We'll update this page when how we handle data changes, and change the date at the top. If a change significantly affects how we use data you've already given us, we'll tell you directly.