Privacy Policy — Wishory Ltd
Wishory Ltd · Legal

Privacy Policy

How we collect, use, and protect your personal data

Version: 2.0 Effective: 27 June 2026 ICO No.: ZB922510 Contact: info@wishory.com
Version 2.0 — What's new

→ 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

01

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

02

The Data We Collect


We collect and process the following categories of personal data:

CategoryData TypesWhy We Collect It
Identity DataFirst name, last name, job title, company nameTo identify who we are working with and address communications correctly
Contact DataEmail address, telephone number, LinkedIn profile URLTo communicate with you about our services and your enquiries
Enquiry DataContent of messages sent via our contact form, email, or LinkedInTo respond to your enquiry and assess how we can help
Engagement DataAI system descriptions, regulatory context, business information shared during a consulting engagementTo deliver our advisory services
Commercial DataPayment records, invoice amounts, purchase historyTo process payment for services and products and maintain financial records
Marketing DataEmail address, name, newsletter subscription preferencesTo send our newsletter and regulatory updates, with your consent
Usage DataIP address (anonymised), pages visited, time on site, browser typeTo understand how our website is used and improve it
Scheduling DataName, email address, calendar availability submitted via CalendlyTo 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.

03

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
04

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.

PurposeLawful BasisDetail
Responding to enquiriesLegitimate interestsWe have a legitimate interest in responding to business enquiries
Delivering consulting servicesPerformance of contractProcessing is necessary to perform the engagement you have contracted us for
Processing paymentsPerformance of contractProcessing is necessary to complete your purchase
Sending our newsletterConsentYou have given explicit consent via our sign-up form. You can withdraw consent at any time by clicking unsubscribe.
Booking discovery callsLegitimate interestsWe have a legitimate interest in scheduling calls with prospective clients
Maintaining financial recordsLegal obligationWe are required to retain financial records under UK tax law
Website analyticsLegitimate interestsWe use anonymised analytics to improve our website. No personally identifiable data is stored.
CRM and pipeline managementLegitimate interestsWe maintain records of prospect and client interactions to manage our business effectively
05

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
06

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.

07

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.

08

Your Rights


Under UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:

Right of Access

Request a copy of all personal data we hold about you. We will respond within one calendar month.

Right to Rectification

Ask us to correct any inaccurate or incomplete personal data we hold about you.

Right to Erasure

Ask us to delete your personal data where there is no compelling reason for us to continue processing it.

Right to Restrict Processing

Ask us to pause processing your personal data in certain circumstances.

Right to Data Portability

Ask us to provide your personal data in a structured, machine-readable format.

Right to Object

Object to processing where we are relying on legitimate interests as our lawful basis.

Right to Withdraw Consent

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.

09

AI Tools & Service Delivery NEW


EU AI Act Article 50 Disclosure — effective 2 August 2026

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:

"This document was produced with the assistance of AI tools, including Claude by Anthropic. All content has been reviewed, verified, and approved by Wishory's senior team prior to delivery. Wishory remains solely responsible for all advisory outputs contained herein."

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
10

Sub-Processor Register NEW


UK GDPR Article 30 — Records of Processing Activities

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-ProcessorCountryPurposeData ProcessedTransfer Mechanism
Anthropic (Claude)United StatesAI-assisted content generationAnonymised service context only — no personal data as standard practiceAnthropic DPA
HubSpotEU (Ireland)CRM — contact & pipeline managementName, email, organisation, interaction notesEU DPA — EU data centre
Mailchimp (Intuit)United StatesNewsletter & email marketingName, email address, engagement dataStandard Contractual Clauses
StripeEU (Ireland)Payment processingName, email, payment card data (tokenised)EU DPA — EU data centre
CalendlyUnited StatesDiscovery call schedulingName, email, calendar availabilityStandard Contractual Clauses
ZapierUnited StatesWorkflow automationContact data in transit between toolsStandard Contractual Clauses
HostingerEU (Lithuania)Website hostingServer logs, anonymised visitor dataGDPR-compliant — EU-based
Google (GA4)US / EUWebsite analyticsAnonymised IP addresses, session dataSCCs + IP anonymisation enabled
GoDaddy / Microsoft 365United StatesDomain & email infrastructureEmail metadata only — content not accessedStandard 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.

11

Data Retention Schedule NEW


Data CategoryRetention PeriodLegal BasisAction at End of Period
Enquiry data (no engagement)12 months from last contactLegitimate interestsDeleted from HubSpot and email
Prospect/pipeline data (no conversion)24 months from last contactLegitimate interestsDeleted from HubSpot and email
Client engagement records6 years from engagement completionLegal obligation — Limitation Act 1980Securely deleted from all systems
Financial and invoice records6 years from end of tax yearLegal obligation — HMRC requirementsSecurely deleted or anonymised
Newsletter subscriber dataUntil unsubscribe, then 30 daysConsentDeleted from Mailchimp on unsubscribe
Calendly booking data12 months from appointment dateLegitimate interestsDeleted from Calendly records
Payment and purchase records (Stripe)6 years from transaction dateLegal obligation — HMRC & PCIRetained by Stripe per their policy
Website analytics (GA4)26 months (anonymised)Legitimate interestsAutomatically deleted by Google Analytics
Email correspondence3 years from last contactLegitimate interestsDeleted 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.

12

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.

13

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.

14

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.

v1.0 May 2026 Initial Privacy Policy — operational launch
v2.0 June 2026 Added Section 9 (AI Tools), Section 10 (Sub-Processor Register), Section 11 (Data Retention Schedule). Registered address confirmed. All sub-processor details updated.
15

How to Contact Us & Complaints


Contact Wishory Ltd

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.