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, from time to time, a short 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, serve as a trustee of a charity with substantial investments, or are named in an insolvency notice, you may appear in our records. So may a professional adviser named on a deal or a filing, and a banker we write to about the service.
We never contact you on a subscriber’s behalf. The briefing never uses social media data, bought or scraped. 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.
Who this notice is about
Subscribers are the wealth managers and bankers who buy or trial the briefing. We hold their work email, firm, job title, location, coverage preferences and billing status, and a record of how they use it, explained below.
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.
Professional advisers are the accountants, lawyers, auditors and corporate finance advisers named on a deal or a filing we report: on the adviser firm’s own announcement, on a regulatory filing, or as the senior statutory auditor on audited accounts. We hold them in their professional capacity only.
Prospective subscribers are the bankers and wealth managers we write to about the service before they have asked for it. Their section is below.
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 or, where the company’s mail server accepts every address and so cannot confirm one mailbox, the single address an email-finding service or the company’s own format gives, labelled as a catch-all address; and a link to a public professional profile they have published themselves. Where no work address is found from the company’s own records, that link may be given to one of our email-finding services to look for one, for that person alone. If we find no route to that person, we may look for one to another individual who controls the same company, and the briefing says whose it is. We also record the company’s own switchboard number as the company publishes it on its website; that is the company’s number, never a person’s, and we never record a mobile number. 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 personal phone numbers.
For a professional adviser named on a deal we report, we hold their name, title, firm, their role on the deal, and the page that names them. We may also hold their business email address and a link to their public professional profile. An address is held only with the evidence behind it: the adviser firm’s own page that publishes it, a check that it is live and in the firm’s own address format, or an address an email-finding service returns, checked as live before it is held. We do not take adviser details from data brokers. We delete an adviser’s contact record twelve months after we last used it.
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. We also read what a company or its advisers have published about a deal or an appointment on their own pages, one candidate at a time, and Wikidata’s public entries, to tell a person widely written about from a private one.
Business contact details come from public web pages (the company’s or adviser firm’s own published pages first) and from email-finding services, checked against the company’s or firm’s own website or the FCA register before anything is shown. Adviser names come from the firms’ own published announcements, regulatory filings and filed accounts. For people in briefings, none of this uses social media data, bought or scraped.
Bankers we write to before they subscribe
If you are a private banker or wealth manager at a firm the service is built for, we may write to you about it. We hold your name, firm, job title, work location, work email address and your firm’s office address, and a note of what we sent and whether you replied. We find these on your firm’s own published pages, the FCA’s public register, published trade press, Companies House, and through Clay, a licensed business-data provider whose data may draw on professional profiles people have published, including LinkedIn; we use it only to find the names, titles and work email addresses of bankers we write to, and none of it is used in the briefings. We write one to one, from a named person at Windfall, by email to your work address or by a card posted to your firm’s office; we do not send bulk marketing. Each message is signed by the person who sent it, and a reply asking us to stop is enough. The page our message links to records whether it was visited and, if you choose to start a trial on it, the address you give.
Our basis is legitimate interests: telling professionals about a service built for their work. If you tell us to stop, by any route, we record that the same day and never write again. Otherwise we delete these details twelve months after our last contact, unless you have become a subscriber.
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 and for understanding whether the briefing is read. For professional advisers and for prospective subscribers, the basis is legitimate interests.
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)(e) and, as Article 14(7) requires, protect your rights and interests by publishing this notice, by giving you an easy way to object that stays in force, by keeping only limited data, and by keeping it only for the periods set out here. That is the purpose this page serves.
How we know the briefing was read
The briefing email contains a small image and tracked links, which tell us when it was opened and which links were followed. The page a subscriber opens from the briefing tells us when it has been read: it reports a view only after it has been on screen for five seconds and the reader has scrolled, touched, pointed or pressed a key, so that an automatic link check by an email security system is not counted. With each of these events we keep the browser’s description of itself and the network address shortened so that it identifies a network rather than a device. We use this only to tell a person reading from an automated scan, and to see whether the service is useful. We erase the browser and network detail after 24 months.
How we count visits to the website
Our public pages use Vercel Web Analytics to count visits: which page was viewed, the page that linked to it, the country, and the kind of device and browser. It sets no cookies and stores nothing on your device, and it does not identify you or follow you to other sites; visits are counted from a short-lived value that cannot be traced back to a person and is discarded within a day. We use the counts only to see which pages are read.
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 for the processing that builds the briefing, Vercel for the website, Resend for sending the briefing and reporting when it is opened and its links followed, Google Workspace for our own mailboxes, Stripe for billing, and Anthropic for the language model that drafts the briefing text. For our dealings with subscribers and prospective subscribers we also use Attio, our customer records system, Clay, a licensed business-data provider used only to find and check the work details of bankers we write to, and Penned, which writes and posts the cards we send them; none is used to build the briefing. When a briefing is about to be sent we also use contact-resolution services: Dropcontact, Hunter and Enrow to find a business email address, MillionVerifier, and Enrow where MillionVerifier cannot settle the answer, 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, and, where no address is found that way, the link to the person’s public professional profile. We keep a register of these and of what each one receives.
Our data is held in the UK and the European Economic Area, and the website’s server functions run in London. 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 or the UK addendum to them. The public Wikidata service, run by the Wikimedia Foundation in the United States, also receives a forename and surname when we check whether a person is widely written about; it needs no account and we send it nothing else. 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. The browser and network detail kept with a record of the briefing being opened or read is erased after 24 months.
- A professional adviser’s contact record:deleted 12 months after we last used it.
- Details of bankers we have written to: 12 months after our last contact, unless they have become a subscriber or asked us to stop.
- A subscriber’s reply to a briefing: filed against that morning so that we can act on it; the words of the reply are deleted after 12 months.
- 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 us;
- 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. The same applies to a professional adviser, whose objection removes them from every future briefing.
Write to privacy@joinwindfall.com. We will confirm within a few days and complete the request within one month.
Complaints
You have the right to complain to us about how we handle your data. Write to privacy@joinwindfall.com. We will acknowledge your complaint within 30 days, take appropriate steps to respond, and tell you the outcome without undue delay. You can also complain to the Information Commissioner’s Office at ico.org.uk, or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
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.
VAT registration: 527 6190 79.
ICO registration: ZC198337.
privacy@joinwindfall.com
