Privacy notice
DRAFT for Daniel's review. Version 0.1, 09/08/2026. This is the privacy notice referred to in clause 14 of the Terms. Not in force. Not to be published until every [NEED FROM ME] marker is resolved, the solicitor review has happened, and Daniel has approved it.
1. Who we are
The portal at tools.danielwalsh.ai (the "Portal") is run by Knowles Farm Ltd, trading as danielwalsh.ai ("we", "us"). We are the data controller for the personal data described in this notice.
- Company number: 15179349 (registered in England and Wales)
- Registered office: 453 Carr Place, Walton Summit Centre, Preston, PR5 8AU
- Privacy contact: hello@danielwalsh.ai
We do not have a data protection officer, because the law does not require one for a business of our size and activities. For anything about your personal data, use the privacy contact above.
2. The short version
- We collect only what we need to run your account and subscription, keep the Portal secure, and meet our legal record-keeping duties.
- We never see or store your bank account number or sort code. You give those directly to GoCardless, our Direct Debit provider.
- There are no analytics or advertising trackers on the Portal, and the only cookies are the ones that make login work.
- We do not sell your data, and we do not share it for marketing.
3. What we collect, why, and the legal basis
UK data protection law requires a lawful basis for each use of your personal data. Here is everything we hold, why we hold it, and the basis we rely on.
Your email address and password. To create and run your account. Your password is stored only as a bcrypt hash, a one-way scrambled form, so we cannot read it. Basis: performing our contract with you.
Email verification and invite tokens. One-time codes that prove you control your email address and, where registration is by invitation, control who can register. Basis: taking steps at your request before entering the contract, and our legitimate interest in keeping registration limited to people we have invited.
Session data and login cookies. To keep you signed in as you move around the Portal. See section 9 for the detail, including the optional 30-day remember-me cookie. Basis: performing our contract with you.
Login rate-limiting records. Short-lived records of login attempts, used to slow down repeated tries and block password-guessing attacks. [NEED FROM ME: confirm from the build exactly what the rate limiter stores, for example IP address, email address or both.] Basis: our legitimate interest in keeping the Portal and your account secure.
Your subscription status and payment references. Whether your subscription is active, plus the customer, mandate and subscription reference IDs that GoCardless assigns. These are references, not bank details. Basis: performing our contract with you.
Payment event logs from GoCardless. Automated messages (webhooks) from GoCardless telling us whether a collection succeeded, failed or was cancelled, so we can manage your access and keep proper accounts. Basis: performing our contract with you, and our legal obligation to keep accounting records.
Emails we send you. Service emails such as email verification, payment and subscription notices, sent from hello@danielwalsh.ai through our email provider Resend, which keeps delivery records for us. Basis: performing our contract with you.
Server logs. Standard technical logs of requests to the Portal, which typically include your IP address, the time, the page requested and your browser type. Used for security and to diagnose faults. Basis: our legitimate interest in running the Portal securely and reliably.
Where we rely on legitimate interests, we have checked that our interest is not outweighed by your rights, and you can object at any time (see section 8).
What we do not collect. No bank account numbers or sort codes (GoCardless holds those). No analytics or advertising trackers. No profiling of your investment activity. The market price data the Portal reports on is not personal data and is not about you. We do not ask for, and do not want, any special category data (such as health or political information).
Automated decisions. We do not make automated decisions about you with legal or similarly significant effects. The rate limiter can temporarily block login attempts, but that is a routine security measure, and you can contact us if it catches you out.
4. Where your data comes from
Almost everything comes from you directly, when you register, log in and manage your subscription. The only other source is GoCardless, which sends us the payment event messages described above.
5. Who we share your data with
GoCardless Ltd (Sutton Yard, 65 Goswell Road, London EC1V 7EN), which collects your Direct Debit payments. You give your bank details to GoCardless directly, and GoCardless is a data controller in its own right for the data it collects from you as a payer. Its privacy notice for payers is at https://gocardless.com/privacy/payers/. We receive back only reference IDs and payment status information.
Resend (a US company), which sends our emails as our data processor and holds delivery records. Its privacy information is at https://resend.com/legal/privacy-policy.
Hetzner, our hosting infrastructure provider, as our data processor. The Portal and its database run on a server we control (managed by us through the Coolify platform) on Hetzner infrastructure in Europe. [NEED FROM ME: the exact Hetzner region/data centre, so the country can be named here.]
We may also share personal data with our professional advisers (such as accountants and solicitors) under confidentiality, with HMRC or other authorities where the law requires it, and with a buyer if the business is ever sold, in which case this notice would continue to protect you.
We do not sell personal data, and we do not share it with anyone for their marketing.
6. International transfers
- GoCardless is a UK company and is responsible, as a controller, for any cross-border handling of the payer data it collects. Its own privacy notice covers that.
- Resend processes data in the United States, so your email address and the content of the emails we send you go to the US. Resend's data processing agreement provides safeguards for UK data through Standard Contractual Clauses with the UK Addendum, and Resend states that it adheres to the EU-US Data Privacy Framework principles. [NEED FROM ME: before launch, confirm Resend's DPA applies to our account and check Resend's certification, including the UK Extension, on the Data Privacy Framework list at https://www.dataprivacyframework.gov/.]
- Hosting: the Portal runs on Hetzner infrastructure in Europe, so your data is stored outside the UK. Hetzner's European regions are in the EEA, and transfers from the UK to the EEA are permitted under the UK's adequacy regulations without further safeguards. [NEED FROM ME: the exact Hetzner region, so this bullet can name the country; if the server turns out to sit outside the EEA, the safeguard here must be re-done before launch.]
We will not move your data outside the UK without a lawful safeguard in place.
7. How long we keep your data
| What | How long |
|---|---|
| Account details (email, hashed password) | While your account is open, then deleted within [NEED FROM ME: decide the window; suggested 90 days] of closure |
| Verification and invite tokens | Until used or expired, then invalid [NEED FROM ME: token lifetime from the build] |
| Login rate-limiting records | Cleared automatically after a short period [NEED FROM ME: exact window from the build] |
| Session cookie | Ends when your session ends; the remember-me cookie lasts up to 30 days (section 9) |
| Subscription and payment records, including payment event logs | 6 years from the end of the financial year they relate to, which is the period companies must keep accounting records for (see https://www.gov.uk/running-a-limited-company/company-and-accounting-records) |
| Server logs | [NEED FROM ME: decide the retention period at launch; suggested 30 days unless there is a reason for longer] |
| Email delivery records held by Resend | [NEED FROM ME: confirm from the Resend account whether sent email content is retained in its dashboard and for how long, and set a purge if configurable] |
When a retention period ends, we delete the data or strip out anything that identifies you.
8. Your rights
Under UK data protection law you have the right to:
- Access a copy of the personal data we hold about you (a subject access request).
- Correct anything that is wrong.
- Erase your data, where there is no good reason for us to keep it. Note that we must keep payment records for the accounting period above even if your account is closed.
- Restrict how we use your data in certain situations.
- Port the data you gave us to another service in a usable format.
- Object to any processing we base on legitimate interests. If you object, we will stop unless we have compelling grounds to continue.
To use any of these rights, email hello@danielwalsh.ai. It is free, we may need to check you are who you say you are, and we will reply within one month.
If you are unhappy with how we handle your data, you can complain to the Information Commissioner's Office: https://ico.org.uk/make-a-complaint/, telephone 0303 123 1113, or Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. We would appreciate the chance to sort it out first, but you do not have to give us one.
9. Cookies
The Portal uses only strictly necessary cookies. There are no analytics, advertising or third-party cookies, which is why you do not see a cookie banner: there is nothing optional to consent to.
| Cookie | What it does | How long it lasts |
|---|---|---|
| Session cookie [NEED FROM ME: cookie name from the build] | Keeps you signed in while you use the Portal. Set as HttpOnly and SameSite, which means scripts on other sites cannot read it | Until your session ends |
| Remember-me cookie [NEED FROM ME: cookie name from the build] | Keeps you signed in between visits. Only set if you tick "remember me" when you log in; if you do not tick it, this cookie is never created | Up to 30 days, or until you log out |
You can remove either cookie at any time by logging out or clearing cookies in your browser. If we ever add a cookie that is not strictly necessary, we will update this notice and ask for your consent first.
10. Children
The Portal is for adults. Our terms require subscribers to be at least 18, and the Portal is not aimed at anyone under 18. We do not knowingly collect data about under-18s; if you believe we have, contact us and we will delete it.
11. How we look after your data
Passwords are stored only as bcrypt hashes, login cookies are HttpOnly and SameSite, repeated login attempts are rate-limited, and access to the systems holding your data is restricted. No system is perfectly secure, but if a breach ever puts you at risk we will tell you and the ICO as the law requires.
12. Changes to this notice
If we change this notice, the new version will appear at this page with a new "last updated" date. If a change is material, for example a new processor or a new use of your data, we will email you before it takes effect.
Last updated: [NEED FROM ME: publication date, DD/MM/YYYY] (version [NEED FROM ME: version number at publication]).