Windfall
Privacy notice
Windfall Intelligence Ltd is the data controller for the personal data described here. We are registered in England and Wales, company number 17301158, and registered with the Information Commissioner’s Office under reference ZC198337. If you want anything on this page explained, or you want to exercise any of the rights set out below, write to privacy@joinwindfall.com and a person will answer you.
The short version
Windfall reads UK public registers, principally Companies House, The Gazette, the Financial Conduct Authority registers and the Charity Commission register, and produces a short daily briefing for wealth managers and private bankers about people in their market who have had a documented financial event, and a short weekly review of people whose filed public record shows standing wealth on a subscriber’s patch with no recent event. A subscriber may ask us to watch a named person’s public register entries, in which case their next Companies House event is included in a later briefing. If you appear in one of those registers because you control a company, direct one, or are named in an insolvency notice, you may appear in our records.
We never contact you on a subscriber’s behalf. We never buy or use scraped social media data. We hold no bank’s client information. If you would rather we did not process your data at all, you can object and we will stop, permanently, and that is explained below.
Two groups of people
Subscribers are the wealth managers and bankers who buy the briefing. We hold their work email, firm, job title, location, coverage preferences and billing status.
Prospects are individuals who appear on the public registers we read. Most of this notice concerns them, because they did not choose to deal with us.
What we hold about people on the public registers
Where an individual is reachable from a company event we are tracking, we create a record holding: their name as registered, their month and year of birth as published by Companies House (never the day, which the register itself withholds), their nationality and country of residence where the register states them, the companies they control, and a summary of those companies’ filed accounts.
Where a briefing naming an individual is about to be sent, we also resolve their business contact details: a work email address at their own company’s domain, verified before it is shown, and a link to a public professional profile they have published themselves. This happens for the handful of people in that day’s briefings only, never in bulk, and we do not collect personal email addresses or phone numbers.
We reduce the correspondence address published on the register to a matching key and a postcode at the moment we read it. We do not store the full address text and it is never shown to a subscriber.
We do not hold, infer or state any special category data. That means nothing about health, race, religion, political opinions, trade union membership, sex life or sexual orientation, and nothing about criminal convictions beyond the disqualification register that Companies House publishes for exactly this purpose. We do not estimate your income, your spending or your household.
Where it comes from
Companies House (the company register, the register of people with significant control, officer appointments and filed accounts), The Gazette (statutory insolvency notices), the FCA registers and the Charity Commission register (the register of charities and their trustees, where a charity holds substantial investments). These are public registers maintained so that corporate control, solvency and charity governance can be checked by anyone. We collect from the registers themselves and from their published bulk data, not from you.
Business contact details come from public web pages (including, for the advisers named on a deal, the adviser firm’s own published pages) and from email-finding services, checked against the company’s or firm’s own website or the FCA register before anything is shown. We never buy or use scraped social media data for this or for anything else.
Why we are allowed to do this
Our lawful basis for processing prospect data is legitimate interests under Article 6(1)(f) of the UK GDPR. The interest is operating a professional intelligence service; the assessment weighing that interest against your rights is written down, is reviewed as the product changes, and can be summarised for you on request.
For subscribers, the basis is performance of the contract for the service itself, and legitimate interests for improving how names are selected.
Because we collect from registers rather than from you, Article 14 of the UK GDPR would ordinarily require us to contact each person individually. The registers we read contain millions of people, and contacting each one would be disproportionate and would itself be intrusive. We therefore rely on Article 14(5)(b) and publish this notice instead. That is the purpose this page serves.
Who sees it
A subscriber sees the individuals selected for their own briefing. We do not sell data, we do not run an open database anyone can search, and no subscriber can browse our records. The service is capped at a small number of subscribers and each receives at most a handful of names a day.
If a subscriber decides to approach someone we have named, that approach is theirs. They decide whether to make it and they are responsible for it under their own obligations and their firm’s. We are not party to it and we never make contact ourselves.
The suppliers we use
We use a small number of service providers: Supabase for the database (data held in London), Railway and Vercel for hosting, Resend for email, Stripe for billing, and Anthropic for the language model that drafts the briefing text. When a briefing is about to be sent we also use contact-resolution services: Dropcontact and Hunter to find a business email address, MillionVerifier to verify that it works, and the Brave search API to locate a company website or a public profile. Each receives no more than a name, a firm and the address being checked. We keep a register of these and of what each one receives.
Our data is held in the UK and the European Economic Area. The routine transfers outside it are to the United States: to Anthropic, for drafting the briefing text, and to Hunter and Brave, for resolving business contact details. Each is made under the standard contractual clauses with a transfer risk assessment. Model providers we use do not train their models on our data.
How long we keep it
The principle we work to is that the sensitive part goes first. What a briefing said about a person is the intrusive part, so it has a short life. That a briefing was sent, to whom and on what date is an accounting record, so it has a longer one, and by then it no longer names anybody.
- Your record on our system: deleted within 90 days of the public filings that brought you into scope no longer doing so, unless a briefing has been sent about you, in which case it follows the clock below.
- The text of a briefing that named you, and our stored copy of the email it went in: deleted after 24 months.
- The remaining record of that briefing, which by then holds no name: 6 years, the ordinary period for business records.
- Public filings we have read that never produced a briefing: 24 months.
- Subscriber account and billing records: for the life of the subscription and 6 years afterwards, as tax and company law require.
- Technical logs: 12 months.
The one thing we keep indefinitely is a record that you have objected or asked to be erased, explained under your rights below. These periods are enforced by a scheduled job, not by anyone remembering.
Your rights
You have the right to:
- ask what we hold about you, and get a copy;
- have inaccurate information corrected;
- have your data erased;
- restrict or object to how we use it;
- object to direct marketing, which is an absolute right: if you object, we stop, and we do not weigh it against anything;
- complain to the Information Commissioner’s Office.
How objection and erasure work here, in practice. If you ask us to stop, we record that permanently against your name and date of birth as published, and we delete the profile we built. We keep the record of your objection itself, and only that, because our records are rebuilt from the public registers every night and without it you would simply reappear. Keeping the smallest possible note of “do not process this person” is what makes your request stick. Nothing in that record is used for anything else. An objection also reaches the contact-resolution services above: once you are on the suppression list, your name is never sent to any of them again, and the check happens before any lookup, not after.
Write to privacy@joinwindfall.com. We will confirm within a few days and complete the request within one month.
Complaints
If you are unhappy with how we have handled your data you can complain to the Information Commissioner’s Office at ico.org.uk, or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would rather you told us first so we can put it right.
Contact
Windfall Intelligence Ltd, a company registered in England and Wales, number 17301158.
Registered office: Fifth Floor, 167-169 Great Portland Street, London W1W 5PF.
ICO registration: ZC198337.
privacy@joinwindfall.com