Privacy Policy
How we collect, use, and protect your personal data
→ Section 9: AI Tools & Service Delivery — new disclosure of AI use in our services
→ Section 10: Sub-Processor Register — full list of third parties handling your data
→ Section 11: Data Retention Schedule — how long each data category is held
- 1. Who We Are
- 2. The Data We Collect
- 3. How We Collect Your Data
- 4. Why We Use Your Data
- 5. How Long We Keep Your Data
- 6. Who We Share Your Data With
- 7. International Data Transfers
- 8. Your Rights
- 9. AI Tools & Service Delivery NEW
- 10. Sub-Processor Register NEW
- 11. Data Retention Schedule NEW
- 12. Cookies
- 13. Children's Data
- 14. Changes to This Policy
- 15. Contact Us & Complaints
Who We Are
Wishory Ltd ('Wishory', 'we', 'us', 'our') is a specialist AI Governance and Compliance consultancy registered in England and Wales (Company No. 15989978). Our registered office is at 128 City Road, London EC1V 2NX.
We are registered with the Information Commissioner's Office (ICO) as a data controller under registration number ZB922510 (renewed to 24 June 2027).
We provide AI governance advisory services, digital compliance products, and training to businesses across the UK, EU, United Arab Emirates, and Saudi Arabia.
For all data protection enquiries, contact us at: info@wishory.com
The Data We Collect
We collect and process the following categories of personal data:
| Category | Data Types | Why We Collect It |
|---|---|---|
| Identity Data | First name, last name, job title, company name | To identify who we are working with and address communications correctly |
| Contact Data | Email address, telephone number, LinkedIn profile URL | To communicate with you about our services and your enquiries |
| Enquiry Data | Content of messages sent via our contact form, email, or LinkedIn | To respond to your enquiry and assess how we can help |
| Engagement Data | AI system descriptions, regulatory context, business information shared during a consulting engagement | To deliver our advisory services |
| Commercial Data | Payment records, invoice amounts, purchase history | To process payment for services and products and maintain financial records |
| Marketing Data | Email address, name, newsletter subscription preferences | To send our newsletter and regulatory updates, with your consent |
| Usage Data | IP address (anonymised), pages visited, time on site, browser type | To understand how our website is used and improve it |
| Scheduling Data | Name, email address, calendar availability submitted via Calendly | To book discovery calls and manage appointments |
We do not collect any special category data (health, racial or ethnic origin, political opinions, religious beliefs, biometric data, or criminal convictions) in the ordinary course of our business.
How We Collect Your Data
We collect personal data through the following channels:
- Website contact form at wishory.com/contact
- Direct email to info@wishory.com
- LinkedIn messages and connection requests
- Discovery call booking via Calendly
- Purchase of digital products via our WooCommerce shop — payment processed by Stripe
- Newsletter sign-up via Mailchimp subscription form
- During consulting engagements — information provided by the client in intake questionnaires, calls, and documents
- Automatically — via Google Analytics 4 (anonymised) when you visit wishory.com
Why We Use Your Data — Lawful Bases
We only process your personal data where we have a lawful basis to do so under UK GDPR.
| Purpose | Lawful Basis | Detail |
|---|---|---|
| Responding to enquiries | Legitimate interests | We have a legitimate interest in responding to business enquiries |
| Delivering consulting services | Performance of contract | Processing is necessary to perform the engagement you have contracted us for |
| Processing payments | Performance of contract | Processing is necessary to complete your purchase |
| Sending our newsletter | Consent | You have given explicit consent via our sign-up form. You can withdraw consent at any time by clicking unsubscribe. |
| Booking discovery calls | Legitimate interests | We have a legitimate interest in scheduling calls with prospective clients |
| Maintaining financial records | Legal obligation | We are required to retain financial records under UK tax law |
| Website analytics | Legitimate interests | We use anonymised analytics to improve our website. No personally identifiable data is stored. |
| CRM and pipeline management | Legitimate interests | We maintain records of prospect and client interactions to manage our business effectively |
How Long We Keep Your Data
We do not keep your personal data longer than is necessary for the purpose for which it was collected. Our full retention periods are set out in Section 11. A summary:
- Enquiries that did not lead to an engagement: 12 months from last contact
- Client engagement records: 6 years from completion (Limitation Act 1980)
- Financial and invoice records: 6 years from end of tax year (HMRC requirement)
- Newsletter subscribers: until you unsubscribe
- Website analytics data (anonymised): 26 months (Google Analytics default)
- Calendly booking data: 12 months from the date of the appointment
Who We Share Your Data With
We do not sell, rent, or trade your personal data with any third party for marketing purposes.
We share your data only with third-party service providers ('sub-processors') who process it on our behalf and under our instruction, for the purpose of delivering our services. These are listed in full in Section 10.
We may also disclose your data where required to do so by law, court order, or regulatory authority — for example, to the ICO in the event of a data protection complaint.
International Data Transfers
Some of our sub-processors are based outside the UK and EEA, including in the United States. Where we transfer your personal data to a country that does not provide an equivalent level of data protection, we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) approved by the UK ICO or European Commission
- An adequacy decision by the UK Secretary of State or European Commission
- The vendor's own binding corporate rules or equivalent certification
The specific transfer mechanism for each sub-processor is set out in Section 10.
Your Rights
Under UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:
Request a copy of all personal data we hold about you. We will respond within one calendar month.
Ask us to correct any inaccurate or incomplete personal data we hold about you.
Ask us to delete your personal data where there is no compelling reason for us to continue processing it.
Ask us to pause processing your personal data in certain circumstances.
Ask us to provide your personal data in a structured, machine-readable format.
Object to processing where we are relying on legitimate interests as our lawful basis.
Where we rely on your consent (e.g. newsletter), you can withdraw it at any time by clicking unsubscribe or emailing us.
To exercise any of these rights, email info@wishory.com with the subject line 'Data Rights Request'. We will respond within one calendar month at no charge.
AI Tools & Service Delivery NEW
This section discloses Wishory's use of artificial intelligence tools in the delivery of its services, in accordance with our obligations under EU AI Act Article 50(1).
9.1 — Our Use of AI Tools
Wishory uses artificial intelligence tools — including large language models — to assist in the preparation of advisory reports, gap analyses, governance frameworks, digital products, website content, and other materials. The primary AI tool we use is Claude, developed by Anthropic.
We also use AI-powered features within Canva Pro (design) and Perplexity AI Pro (regulatory research). A full list is set out in Section 10.
9.2 — Human Oversight
Every AI-assisted output produced by Wishory — including all client deliverables — is reviewed, verified, and approved by our senior team before delivery. We do not deliver raw AI-generated content to clients without human review. Wishory remains solely responsible for all advisory outputs, regardless of whether AI tools were used in their preparation.
9.3 — Article 50 Disclosure Statement
In accordance with EU AI Act Article 50(1), all Wishory client deliverables produced with AI assistance will carry the following disclosure from 2 August 2026:
9.4 — Your Data in AI Tools
- We do not enter your name, contact details, or other personally identifiable information into AI tools as part of routine service delivery
- Where engagement-specific context is used, we anonymise or generalise the information — using sector descriptors rather than company names where the specific name is not required
- We do not enter commercially sensitive or confidential client information into any AI tool without your prior written consent
- We do not use free-tier AI tools for client work — free tiers typically train on user inputs
- All AI tool vendors used for service delivery operate under appropriate Data Processing Agreements or Standard Contractual Clauses
9.5 — Your Rights in Relation to AI Tools
- You can request that a specific deliverable be produced without the use of AI tools — contact us at info@wishory.com
- You can request a copy of our AI Inventory Register and Internal AI Acceptable Use Policy — available on request
- You can exercise any of the data rights set out in Section 8
Sub-Processor Register NEW
The following third parties process personal data on behalf of Wishory Ltd. Each is engaged under a written Data Processing Agreement or Standard Contractual Clauses.
| Sub-Processor | Country | Purpose | Data Processed | Transfer Mechanism |
|---|---|---|---|---|
| Anthropic (Claude) | United States | AI-assisted content generation | Anonymised service context only — no personal data as standard practice | Anthropic DPA |
| HubSpot | EU (Ireland) | CRM — contact & pipeline management | Name, email, organisation, interaction notes | EU DPA — EU data centre |
| Mailchimp (Intuit) | United States | Newsletter & email marketing | Name, email address, engagement data | Standard Contractual Clauses |
| Stripe | EU (Ireland) | Payment processing | Name, email, payment card data (tokenised) | EU DPA — EU data centre |
| Calendly | United States | Discovery call scheduling | Name, email, calendar availability | Standard Contractual Clauses |
| Zapier | United States | Workflow automation | Contact data in transit between tools | Standard Contractual Clauses |
| Hostinger | EU (Lithuania) | Website hosting | Server logs, anonymised visitor data | GDPR-compliant — EU-based |
| Google (GA4) | US / EU | Website analytics | Anonymised IP addresses, session data | SCCs + IP anonymisation enabled |
| GoDaddy / Microsoft 365 | United States | Domain & email infrastructure | Email metadata only — content not accessed | Standard Contractual Clauses |
We will notify you of any material change to our sub-processors within 30 days. This register was last updated: 27 June 2026.
Data Retention Schedule NEW
| Data Category | Retention Period | Legal Basis | Action at End of Period |
|---|---|---|---|
| Enquiry data (no engagement) | 12 months from last contact | Legitimate interests | Deleted from HubSpot and email |
| Prospect/pipeline data (no conversion) | 24 months from last contact | Legitimate interests | Deleted from HubSpot and email |
| Client engagement records | 6 years from engagement completion | Legal obligation — Limitation Act 1980 | Securely deleted from all systems |
| Financial and invoice records | 6 years from end of tax year | Legal obligation — HMRC requirements | Securely deleted or anonymised |
| Newsletter subscriber data | Until unsubscribe, then 30 days | Consent | Deleted from Mailchimp on unsubscribe |
| Calendly booking data | 12 months from appointment date | Legitimate interests | Deleted from Calendly records |
| Payment and purchase records (Stripe) | 6 years from transaction date | Legal obligation — HMRC & PCI | Retained by Stripe per their policy |
| Website analytics (GA4) | 26 months (anonymised) | Legitimate interests | Automatically deleted by Google Analytics |
| Email correspondence | 3 years from last contact | Legitimate interests | Deleted from Microsoft 365 mailbox |
Where you exercise your Right to Erasure and we have no overriding legal obligation to retain your data, we will delete it within 30 days and confirm deletion in writing.
Cookies
Our website wishory.com uses cookies — small text files placed on your device when you visit.
- Strictly necessary cookies — required for the website to function (e.g. shopping cart, security). These cannot be disabled.
- Analytics cookies — Google Analytics 4, used to understand how visitors use our site. These are anonymised and can be declined via our cookie consent banner.
- Functional cookies — used to remember your preferences (e.g. cookie consent choices). These can be managed via our cookie settings.
When you first visit wishory.com, a cookie consent banner (managed by CookieYes) will ask for your consent to non-essential cookies. You can change your cookie preferences at any time via the cookie settings link in our website footer.
For a full list of specific cookies, see our Cookie Policy.
Children's Data
Our services are directed at business professionals and organisations. We do not knowingly collect personal data from anyone under the age of 18. If you believe we have inadvertently collected data from a child, please contact us immediately at info@wishory.com and we will delete it promptly.
Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the version number and effective date at the top of this policy, publish the updated policy at wishory.com/privacy-policy, and where the change materially affects how we use your data, notify you by email.
How to Contact Us & Complaints
For any data protection enquiry, Subject Access Request, or to exercise your rights:
Email: info@wishory.com
Post: Wishory Ltd, 128 City Road, London EC1V 2NX
Website: wishory.com
If you are not satisfied with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) — the UK supervisory authority for data protection.
- Website: ico.org.uk
- Helpline: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
We would appreciate the opportunity to address any concern before you contact the ICO. Please contact us first at info@wishory.com and we will respond within 5 business days.
Wishory Ltd · AI Governance & Compliance · wishory.com · info@wishory.com
Registered in England & Wales · Co. No. 15989978 · ICO No. ZB922510 · Privacy Policy v2.0 · Effective 27 June 2026
