This notice explains how FlowDialect Ltd uses personal data relating to website visitors, people who contact us, professional contacts, research participants, and client representatives. Separate privacy information or contractual terms may apply where we process personal data as part of a client’s engagement.
1. Who we are
FlowDialect Ltd is a private limited company incorporated in England and Wales. Company number: 17320712. Registered or correspondence address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ. ICO registration number: ZC209707. Data protection contact: hello@flowdialect.com. FlowDialect Ltd is the controller of the personal data described in this notice unless an engagement-specific agreement states otherwise.
2. Information we collect and where it comes from
Website visits and enquiries: if you contact us, we may collect your name, contact details, organisation, role, and the content of your message. Our website is hosted by Framer, which may process technical request information needed to deliver and secure the site. We use Framer’s built-in analytics to understand aggregate activity such as page views, referral sources, approximate country, and device type. Framer states that its built-in analytics does not use cookies or persistent identifiers. Professional and commercial contacts: we may collect professional information from public company websites, LinkedIn, referrals, events, previous business interactions and information you provide directly. Research participants: we may collect professional details and structured notes about operational issues discussed; participation is voluntary and a separate participant notice and consent form will explain specific processing. Client contacts and operational data: we process client representatives’ contact and engagement information to scope, deliver and administer work. Client-provided operational data may include personal data and, in some engagements, special-category data; our role is established for each engagement.
3. How and why we use personal data
We use personal data only where we have a lawful basis under UK data protection law. Depending on the context, we use it to respond to enquiries and discuss potential work; manage client relationships and deliver engagements; identify organisations that may reasonably benefit from our services; conduct voluntary research and improve our methodology; operate, secure and understand use of our website; and meet legal, regulatory, accounting and insurance obligations. Our lawful bases are legitimate interests, steps before entering a contract, performance of a contract, and legal obligation, as applicable. Where we rely on consent for a specific activity, you may withdraw it at any time. For business-to-business outreach, we use limited professional information and comply with applicable electronic marketing rules, including PECR. You may object to direct marketing at any time.
4. Who we share personal data with
We do not sell personal data. We may share it only where necessary with Microsoft, which provides our business email, document storage and collaboration services through Microsoft 365; Framer, which hosts our website and provides built-in website analytics; professional advisers, insurers, auditors or contractors subject to appropriate confidentiality and data-protection obligations; and regulators, courts, law enforcement bodies or other parties where disclosure is required by law or necessary to protect legal rights. When a service provider processes personal data on our behalf, we require appropriate contractual protections.
5. International transfers
Some service providers may process or allow access to personal data outside the UK. Where this occurs, we rely on safeguards recognised under UK data protection law, such as UK adequacy regulations or approved contractual protections. Microsoft documents limited circumstances in which data may be transferred or accessed outside its EU Data Boundary. Further information about the safeguards used is available on request.
6. How long we keep personal data
We keep personal data only for as long as reasonably needed for the purpose collected, including legal, accounting and dispute-management requirements. We securely delete or anonymise information when it is no longer required. A different period may apply where an engagement-specific agreement, participant notice or legal hold requires it.
DATA
RETENTION
Enquiries, professional contacts and outreach
Up to two years after the last substantive interaction
Client, contractual and financial records
Normally six years after the relevant engagement or financial year, where required for legal, tax or accounting purposes
Research and project data
As stated in the relevant participant notice or client agreement; otherwise deleted or anonymised when no longer required
We may retain limited information where necessary to establish or defend legal claims, comply with a legal obligation, or record that someone has opted out of future communications.
7. Your data-protection rights
Depending on the circumstances, you may have a right to access, correct or erase your personal data; restrict its use; receive certain data in a portable format; or object to processing based on legitimate interests. You may withdraw consent where it is the lawful basis. An objection to direct marketing is absolute: once received, we will stop using your personal data for that purpose. To exercise a right, email hello@flowdialect.com. We normally respond within one month and may need to verify your identity.
8. Cookies and website tracking
We do not currently use advertising pixels, behavioural tracking, or cookie-based analytics. Framer’s built-in analytics operates without cookies or persistent identifiers. If this changes, we will update this notice and obtain consent where required before activating the relevant tools.
9. Security and changes to this notice
We use proportionate technical and organisational measures to protect personal data against loss, misuse and unauthorised access, and review those controls as our processing develops. We may update this notice when our practices or obligations change. The effective date identifies the current version.
10. Contact and complaints
Questions, requests, or concerns should be sent to hello@flowdialect.com or to the business address stated in section 1. You also have the right to complain to the Information Commissioner’s Office. Information is available at ico.org.uk or by telephone on 0303 123 1113.