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Privacy Policy

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Last updated: 24 September 2026

 

This policy explains how COWXSALES LTD ("cowX", "we", "us") collects and uses personal data, and the rights you have over it. We are committed to handling your data fairly, lawfully and transparently under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).

 

1. Who we are

COWXSALES LTD is a company registered in England and Wales (company number 12686111), with its registered office at 12 Leighton Road, Hove, England, BN3 7AD. We are the data controller for the personal data described in this policy, except where section 6 says otherwise.

ICO data protection fee application number: C2041514

If you have any questions about this policy or your data, contact us at ed@cowxsales.com or write to us at the address above.

 

2. Whose data this policy covers

This policy applies to:

  • Website visitors and enquirers: people who visit our website, fill in our contact form or email us.

  • Customers: people at businesses that use our services, and their colleagues who work with us.

  • Business contacts we research: people in professional roles at organisations we research on behalf of our customers. We do not contact these people ourselves.

 

3. What we collect

Data you give us. When you fill in our contact form, we collect your name, email address and website, and an optional short description of what you need. If you contact us in other ways, such as by email, we collect whatever you choose to send us.

Data about your use of our website. With your consent, we use Google Analytics and Wix's built-in analytics to collect information such as the pages you visit, the site that referred you, your approximate location, and your device and browser type. See section 11.

Business contact data from public sources. To help our customers identify organisations that may be a good fit for their services, and the right person to speak to at each, we collect professional information about people in business roles. This may include name, job title, employer, business email address, professional profile links, and information the person or their organisation has published, such as company announcements, website content, case studies, press coverage and professional social media posts. We do not collect special category data (such as health, religion or political opinions) about business contacts.

 

4. How we use your data, and our lawful basis

The UK GDPR requires us to have a lawful basis for each use of your data. We rely on the following.

What we doLawful basis

Reply to your enquiry and arrange callsLegitimate interests (responding to people who contact us), or steps before entering a contract

Provide our services to customers and manage the accountPerformance of a contract

Research organisations and identify relevant business contacts for our customersLegitimate interests (helping our customers find businesses that may benefit from their services), see section 5

Keep records for accounting, tax and legal purposesLegal obligation

Improve our website and servicesLegitimate interests, or consent where cookies are involved

Protect our business and handle legal claimsLegitimate interests

Where we rely on legitimate interests, we have balanced our interests against your rights and freedoms. You can ask us for details of that assessment and you have the right to object (section 9).

 

5. Research into business contacts

We research organisations and the people who work there so that our customers can decide who may be interested in their services. We do not send marketing or outreach to the people we research. Any contact is made by our customer, who is responsible for doing so lawfully.

When we carry out this research:

  • We only collect professional information that relates to a person's role, and nothing about their private life.

  • We only use information that has been made public, for example by the person or their organisation.

  • We keep what we collect to the minimum needed to judge whether an organisation is a good fit and who the relevant contact is.

  • We record the source and date of what we collect, so it can be checked and kept accurate.

Where we get this information. Typical sources include organisations' websites, Companies House, press releases, published case studies and portfolio pages, event listings and professional networking sites.

Why we do not notify each person directly. Because we do not contact the people we research, telling each of them individually would involve disproportionate effort. We publish this policy instead so the information is available to anyone. If you think we hold data about you, you can ask us at any time (section 9), and you can object to this research. If you object, we will stop processing your data and keep only the minimum needed to make sure we do not include you again.

 

6. When we act for our customers

When we research organisations and contacts as part of a campaign for a customer, we may do so as a data processor acting on our customer's instructions, or as a controller in our own right, depending on the arrangement. Our customers decide whether to contact anyone, and they are responsible for any outreach they send, including telling people where their details came from. If you are contacted by one of our customers and want to know how your details were found, you can ask them or us, and we will help.

 

7. Who we share your data with

We do not sell your personal data. We share it only with:

  • Service providers who help us run our business, under contracts that require them to protect your data and use it only on our instructions. These include:

    • Wix.com, which hosts our website and our contact form

    • Google Workspace, which provides our email and Google Sheets, where we store research results and customer records

    • Google, which provides Google Analytics

    • Anthropic, which provides Claude, the AI tool we use to find and analyse public information

    • Stripe, which processes card payments (we also accept bank transfers through our bank)

    • Our accountant, for bookkeeping and tax

  • Our customers, where we research business contacts on their behalf (section 6).

  • Professional advisers, such as lawyers and accountants, where needed.

  • Authorities, where the law requires it or to protect our legal rights.

  • A buyer or successor, if our business is sold or reorganised, under the same protections.

 

8. International transfers

Some of our service providers are based outside the UK, including in the United States and the European Economic Area. When your data is transferred outside the UK, we make sure it is protected by one of the safeguards the law allows, such as a UK adequacy decision (including the UK-US Data Bridge for certified organisations), or the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses.

 

9. Your rights

You have the right to:

  • Be informed about how we use your data (this policy).

  • Access the personal data we hold about you.

  • Correct data that is inaccurate or incomplete.

  • Erase your data in certain circumstances.

  • Restrict how we use your data in certain circumstances.

  • Object to our use of your data based on legitimate interests. You have an absolute right to object to direct marketing, and we will stop as soon as you ask.

  • Data portability: receive data you gave us in a common format, where we rely on consent or contract.

  • Withdraw consent at any time, where we rely on it. This does not affect anything we did before you withdrew.

To use any of these rights, email ed@cowxsales.com. We will respond within one month. We may ask you to confirm your identity. There is normally no charge.

 

10. How long we keep your data

We keep personal data only as long as we need it:

DataHow long

Enquiries that do not lead to work: 12 months after our last contact

Customer records and contracts: 6 years after the end of the contract, for legal and tax reasons

Business contact research data: 12 months from collection if there is no ongoing contact, then deleted or refreshed

Records of objections: For as long as needed to make sure we respect your request

 

11. Cookies

Cookies are small files placed on your device when you visit a website. Our website is built on Wix, and uses two kinds:

  • Strictly necessary cookies, set by Wix so the website works securely and properly. These do not need your consent.

  • Analytics cookies, set by Google Analytics and Wix, which help us understand how visitors use the site so we can improve it. We only use these if you agree.

You can accept or reject analytics cookies using the banner when you first visit, and change your choice at any time using the cookie settings link at the bottom of every page. You can also block or delete cookies in your browser settings.

 

12. Security

We use appropriate technical and organisational measures to protect your data, including access controls, encrypted connections and reputable service providers. No system is completely secure, but we work to protect your data and will notify you and the regulator of a serious breach where the law requires it.

 

13. Children

Our services are for businesses. We do not knowingly collect data from anyone under 18.

 

14. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated at the top.

 

15. Complaints

If you are unhappy with how we have handled your data, please contact us first at ed@cowxsales.com and we will try to put it right.

You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO):

  • Website: ico.org.uk/make-a-complaint

  • Helpline: 0303 123 1113

  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

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