Privacy Policy

1. Who We Are

Client Funnels Ltd is the organisation responsible for the personal information described in this Privacy Policy where we determine why and how that information is used.

Our details are:

• Client Funnels Ltd
• Company No. 14135257
• Registered in England and Wales
• Registered Office: 7 Beauchamp Avenue, Midsomer Norton, Radstock, England, BA3 4FW

Email: paul@clientfunnels.co.uk

Client Funnels helps businesses generate, nurture and convert leads through conversational sales and marketing systems, consultancy, training, courses, workshops and related services.

2. What This Policy Covers

This Privacy Policy explains how we collect, use, store and share personal information when you:

• visit our website;
• contact us;
• communicate with us on WhatsApp;
• join a mailing list;
• complete a form, quiz or application;
• book a call;
• buy a product or service;
• attend a course, workshop or event;
• participate in training;
• work with us as a client;
• interact with one of our campaigns;
• interact with an AI or automated system operated by us; or
• otherwise deal with Client Funnels.

It also explains your data-protection rights.

3. Our Approach

Our approach to communication is based on permission and relevance.

We don't sell personal information.

We don't believe that having someone's phone number gives us permission to repeatedly market to them.

Where marketing consent is required, we will obtain it.

Where another legal basis or an electronic-marketing exemption applies, we will use it only where the relevant conditions are met.

4. Information We May Collect

Depending on how you interact with us, we may collect:

Contact information

This may include:

• name;
• email address;
• telephone number;
• WhatsApp number;
• company;
• job title; and
• business contact details.

Information you give us

This may include:

• form responses;
• quiz or ScoreApp responses;
• applications, including an incomplete application where you complete the first section and provide your contact details;
• survey responses;
• messages;
• emails;
• WhatsApp conversations;
• voice notes;
• meeting information;
• business information;
• consultancy information;
• feedback; and
• information you provide during courses, workshops or training.

Transaction information

This may include:

• products or services purchased;
• invoice information;
• payment status;
• billing information; and
• transaction records.

We do not normally store full payment-card details ourselves. Payment providers process payment information on our behalf.

Event information

This may include:

• attendance details;
• access requirements; and
• dietary requirements.

Some information about dietary or accessibility requirements may reveal health, religious or other more sensitive information.

Where this is classed as special-category personal data, we will only process it where both an appropriate lawful basis and an additional legal condition apply.

Website information

This may include:

• IP address;
• browser;
• device;
• referring page;
• website activity;
• pages visited;
• campaign information; and
• cookie or similar technology data.

5. Where We Obtain Information

We normally receive personal information directly from you.

For example, when you:

• fill in a form;
• message us;
• give us your business card;
• buy something;
• register for an event;
• book a call;
• respond to a campaign; or
• communicate with us through WhatsApp.

We may also receive information from:

• event organisers;
• referral partners;
• payment providers;
• software platforms we use;
• advertising platforms; or
• a client where we are acting on that client's behalf.

Where data-protection law requires us to tell you about information obtained from another source, we will do so within the required period unless an exemption applies. ICO guidance generally requires this privacy information within a reasonable period and no later than one month where Article 14 applies.

6. Why We Use Personal Information

We may use information to:

• answer enquiries;
• provide requested information;
• manage bookings;
• communicate with clients;
• provide consultancy;
• provide Done For You and Done With You work;
• securely save an application start so we can help you resume it or respond to your application enquiry;
• deliver courses, training and workshops;
• manage accounts;
• take and reconcile payments;
• manage contracts;
• operate WhatsApp campaigns;
• provide customer support;
• personalise communications;
• manage events;
• analyse the use of our website;
• improve our products and services;
• protect our business and systems;
• handle complaints;
• meet legal and regulatory requirements; and
• send lawful marketing.

7. Our Lawful Bases

UK data-protection law requires us to have a lawful reason for processing personal information.

Depending on the activity, we may rely upon:

Contract

We may process information where it is required to enter into or perform a contract with you.

For example:

• delivering purchased services;
• managing client projects;
• processing bookings; or
• administering an account.

Consent

We may rely on consent where you have actively agreed to a specific use.

This can include certain:

• marketing;
• WhatsApp communications;
• cookies;
• recordings; or
• use of sensitive information.

Where we rely on consent, you can withdraw it.

Legitimate Interests

We may process information where there is a legitimate business reason and that reason is not outweighed by your interests, rights or freedoms.

This may include:

• responding to business enquiries;
• maintaining business relationships;
• managing and improving services;
• preventing fraud;
• securing our systems;
• keeping appropriate business records; and
• certain business-to-business marketing.

Where required, we assess the interests involved before relying on this basis.

Legal Obligation

We may process information where the law requires us to do so.

This may include:

• accounting;
• tax records;
• legal claims;
• responding to lawful requests; and
• handling certain data-protection matters.

8. Marketing

We may communicate with you about relevant Client Funnels products, services, events or resources where permitted by law.

The rules vary depending upon the communication method and recipient.

For electronic marketing such as email, WhatsApp or direct messages, we will comply with applicable UK GDPR and PECR requirements.

Where consent is required, we will obtain consent.

Where the law permits another route, such as an applicable soft opt-in or business-to-business communication, we will make sure the relevant conditions are met.

You can tell us to stop direct marketing at any time.

Marketing messages should contain a simple way to opt out where required.

A publicly available email address or telephone number does not by itself mean that someone has consented to electronic marketing.

9. WhatsApp

WhatsApp is an important part of our business.

We may communicate with people through WhatsApp where there is an appropriate legal basis and where the communication complies with applicable electronic-marketing rules.

This may include where:

• you start a conversation with us;
• you ask us to contact you;
• you register for something involving WhatsApp communication;
• you are an existing client and WhatsApp is being used to deliver the service; or
• another lawful basis applies.

WhatsApp conversations may be processed through service providers used to manage WhatsApp communication, such as WhatsApp Business solution providers.

Messages and voice notes may be retained where reasonably required to manage the relationship, provide services, maintain records or deal with disputes.

10. AI

Client Funnels uses AI in parts of its business.

AI may assist with:

• drafting;
• analysis;
• summarisation;
• campaign development;
• administration;
• customer support;
• conversational agents;
• research; and
• automation.

Where personal information is processed through AI, normal data-protection law continues to apply.

We consider:

• the purpose;
• lawful basis;
• amount of information required;
• supplier;
• security;
• retention;
• international transfer position; and
• risk to individuals.

We do not currently use AI to make solely automated decisions about individuals which have legal or similarly significant effects.

More information is available in our AI Governance and Use Policy.

ICO guidance requires organisations to be clear about the use of personal information in AI systems.

11. When We Process Information for Clients

There will be times when Client Funnels handles personal information belonging to a client's leads, customers or prospects while providing consultancy, Done For You or Done With You services.

In those circumstances, the Client will normally decide why the information is being used and Client Funnels will process it on the Client's instructions.

The Client will normally therefore be the controller and Client Funnels the processor for that activity.

Our contractual data-processing terms apply where required.

If you have received a message as part of one of our client's campaigns and want to understand why your information is being used, the relevant client's own privacy notice may also apply.

12. Who We Share Information With

We do not sell personal information.

We may share information with suppliers where this is required to run our business or provide services.

These may include providers of:

• WhatsApp services;
• WATI or similar messaging platforms;
• CRM and email systems;
• ClickFunnels or similar page and campaign systems;
• ActiveCampaign;
• ScoreApp;
• payment services such as PayPal;
• accounting services such as QuickBooks;
• Meta services;
• website analytics;
• hosting;
• file storage;
• meeting and booking software;
• AI services;
• contractors; and
• professional advisers.

We may also share limited information with event venues or organisers where needed to manage an event.

Suppliers receive information only where there is a reason for them to have it.

13. International Transfers

Some suppliers may process personal information outside the UK.

Where UK data-protection rules on international transfers apply, we take steps to ensure that a lawful transfer mechanism is available.

Depending on the destination and supplier, this may include:

• UK adequacy regulations;
• the UK Extension to the EU-US Data Privacy Framework where applicable;
• an International Data Transfer Agreement;
• the UK Addendum to EU Standard Contractual Clauses; or
• another permitted safeguard.

Where required, we also consider whether an appropriate transfer risk assessment or data protection test is needed. Current ICO guidance recognises adequacy arrangements, the UK IDTA and Addendum as transfer mechanisms under the UK regime.

14. How Long We Keep Information

We keep personal information only for as long as there is a reason to keep it.

Typical periods include:

• Leads and enquiries: normally up to 36 months after the last meaningful interaction, unless there is a reason to retain the information for longer.
• Client and contractual records: normally up to 6 years after the relevant relationship or transaction where required for contractual, legal or business-record purposes.
• Financial records: normally 6 years or another period required by tax or accounting law.
• Marketing information: until you opt out, consent is withdrawn where relevant, or we determine that the information should no longer be retained.
• Event dietary or accessibility information: only for as long as needed to organise the event and deal with any related matter.

Website and analytics data: according to the retention settings used for the relevant technology.

Different information may need different retention periods.

15. Cookies and Similar Technologies

Our website may use cookies, pixels and similar storage or access technologies.

They may be used for purposes including:

• making the website function;
• security;
• remembering settings;
• understanding website usage;
• improving the website;
• measuring campaigns; and
• advertising or remarketing.

Some technologies can be used without consent where a legal exception applies.

For example, current PECR rules contain exemptions for certain strictly necessary uses and certain statistical uses that satisfy specific conditions.

Where consent is required, including for relevant advertising or remarketing technology, we will ask for consent before using it.

You can change the choices available through our cookie controls.

Rejecting optional tracking should be as straightforward as accepting it.

16. Google Analytics, Meta and Advertising

Where enabled, we may use services such as Google Analytics and Meta technologies to understand website activity and measure or support advertising.

These services may receive information about:

• your device;
• browser;
• IP address;
• page activity; and
• interactions with advertising or website content.

Advertising tracking is only activated where we have the required permission.

17. Special-Category Information

We do not normally need sensitive personal information.

There may be limited cases where it is provided to us, such as:

• accessibility requirements;
• dietary requirements;
• health information relevant to an event; or
• information voluntarily supplied during a conversation.

Where the information is special-category data, UK GDPR requires both a normal lawful basis and an additional Article 9 condition.

We will limit this processing to what is necessary.

18. Security

We use appropriate organisational and technical measures to protect information.

These may include:

• access controls;
• account security;
• password protection;
• restricted access;
• supplier checks;
• data minimisation; and
• appropriate security settings.

No internet-based service can guarantee zero risk.

If a personal-data incident occurs, we will assess it and take any steps required by law.

19. Your Rights

Depending upon the circumstances, you may have the right to:

• ask whether we hold personal information about you;
• obtain a copy;
• correct inaccurate information;
• ask for information to be deleted;
• restrict certain uses;
• object to certain processing;
• object to direct marketing;
• request data portability where applicable; and
• withdraw consent where processing depends upon consent.

These rights are not all absolute and exceptions may apply.

To exercise a right, contact:

paul@clientfunnels.co.uk

We may need information to confirm your identity before acting on a request.

20. Data-Protection Complaints

If you believe we have handled your personal information incorrectly, please contact us at:

paul@clientfunnels.co.uk

We will provide a reasonable means for you to make a data-protection complaint.

For complaints received under the applicable UK data-protection complaint regime, we will:

• acknowledge the complaint within 30 days;
• take appropriate steps to investigate it without undue delay;
• keep you informed of progress where appropriate; and
• tell you the outcome.

These requirements have applied to UK controllers since 19 June 2026.

You also have the right to raise concerns with the UK data-protection regulator, the Information Commissioner's Office.

21. Children

Our services are aimed at businesses and adults.

We do not intentionally market our services to children or knowingly collect children's personal information for marketing purposes.

If we become aware that we hold children's personal information without an appropriate reason, we will assess what action should be taken.

22. Links and Third-Party Services

Our website and communications may contain links to services operated by other organisations.

Those organisations have their own privacy practices.

Client Funnels is not responsible for how an independent third party processes information once you interact directly with its service.

23. Changes to This Privacy Policy

We review this Privacy Policy regularly.

Where we make a material change to how we use personal information, we will update this policy and take additional steps to tell affected people where required.

The most recent version will be available on our website.

24. Contact Us

For questions about this Privacy Policy, our use of personal information, or a data-protection complaint:

• Client Funnels Ltd
• 7 Beauchamp Avenue
• Midsomer Norton
• Radstock
• England
• BA3 4FW
• Email: paul@clientfunnels.co.uk

Company No: 14135257