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What personal data we hold about you, why, and what you can make us do about it.
Version 2026-10-24.1Updated 24 October 2026
FourWinds Digital is the controller for personal data processed through this portal and through our website at fourwindsdigital.com. Contact us at hello@fourwindsdigital.com about anything in this notice.
This notice covers both, because the website sends you here and you should not have to guess which half you are reading about. The portal is the part you sign in to. The website is the part anybody can read without an account, and what it collects is set out in its own section below.
FourWinds Digital is a trading name of Oscar Cobbe, who is the controller.
To provide the portal and the services you have engaged us for (performance of a contract), to keep the service secure and meet our legal obligations, and, where you have not objected, to tell you about relevant updates (legitimate interests).
You do not need an account to read the website, and most of what follows applies to anybody who visits it, client or not.
We use Google Analytics to see which pages people read. Its cookies need your consent: under regulation 5 of the ePrivacy Regulations (SI 336/2011), storing them on your device requires consent before it happens, not after. So no Analytics cookie is set until you choose Allow on the banner. Decline and none are set, and the site works exactly the same. Your answer is remembered in your browser's local storage under fw_analytics_consent so we do not ask again on every page.
The Google Analytics script itself loads on every visit, in Google's consent mode. Until you answer, and after you decline, it sets no cookie and stores nothing on your device, and it sends Google a record of each page you view: the page address and title, the page you came from, the time, your browser, device, screen size and language, and your IP address. Each record carries a random number held only in the open browser tab and never stored, so the records cannot be linked from one visit to the next. Google may use them to model the visits it cannot count. Our lawful basis is our legitimate interest in knowing which pages are read. You can object by writing to us, and because these records carry nothing we could find yours by, the reliable way to stop them is to block Google Analytics in your browser.
Where you do consent, Google Analytics also sets its cookies, which let it recognise the same browser from one page and one visit to the next, and collects the pages you view, roughly where in the world you are, and what kind of device and browser you use. IP addresses are truncated before they are stored. The figures we see are aggregate. Google is the processor for this and the transfer to the United States is covered by the EU-US Data Privacy Framework. You can withdraw consent by clearing this site's data in your browser, which brings the banner back.
We do not join your reading to your name. We built a component that would have done exactly that, linking pages viewed to a persistent identifier and then to an enquiry, and it is switched off in the code rather than merely unused, because our own data protection policy identifies that kind of tracking as requiring a data protection impact assessment and we have not done one. If that changes, this notice changes first and you will be asked again.
If you write to us through the form on the site we collect your name, email address, company, what you say you need, and your message.
We use it only to answer you. The lawful basis is our legitimate interest in replying to someone who has asked us a question, and we do not add you to a mailing list. It reaches us as email through Resend, a provider in the United States, under standard contractual clauses, and a copy is filed in our database in Ireland so that an enquiry is not lost if an email fails to deliver. We keep it for six months from our last meaningful contact, unless it becomes a client record and the retention below applies instead.
We also read the IP address the submission arrives from and count submissions against it for one hour, so that the form cannot be used to flood our inbox or somebody else's. The count is what we keep; it is deleted when the hour is up.
fw_analytics_consent: your answer to the banner, so we do not ask twice. Set whichever way you answer, including when you decline.If you decline, that first item is the only thing of ours on your device.
If you are reading this because of a cold email from us, this section is the one that applies to you. You did not give us your details, so we have to tell you where we got them.
What we hold. Your business name, its website address, the county it trades in, and a contact address published on that website. Alongside it we keep what an automated check of your own public website found: for example that it has no privacy notice, or that a form on it sends data somewhere it does not disclose. We also keep the email we sent you and whether it was delivered.
Where we got it. From your own website and from public business listings. Nowhere else. We do not buy lists.
Why. To tell a business something specific and checkable about its own website, and to offer to fix it. Our legal basis is legitimate interests under Article 6(1)(f): the interest is finding clients, and we have balanced it against your interests by writing only to a role address such as info@ or reception@, by saying something true about your own site rather than sending a generic pitch, and by stopping the moment anybody asks.
Under regulation 13 of SI 336/2011 we email role addresses about the recipient's own commercial activity. We do not send marketing email to a named individual's address this way.
How to make it stop. Every email has a one-click unsubscribe link, and mail clients like Gmail and Outlook show their own unsubscribe control on our messages. You can also simply reply and say so, or write to hello@fourwindsdigital.com. Any of those works, immediately and permanently, and you do not have to give a reason. This is an absolute right under Article 21(2) and we do not ask you to justify it.
When you object we record the refusal against a one-way hash of your address, not the address itself, so that we can be certain never to write to you again without keeping your details in order to do it.
Who else sees it. The email itself is sent through Resend, a provider in the United States, so the address and the message pass through their systems. The record of it is held in our database with Supabase, in Ireland. Nobody else receives it: we do not sell, share or rent these details, and there is no advertising network involved.
How long we keep it. Twelve months from the last email, after which the address and the message are redacted automatically. If you object, the refusal record is kept indefinitely, because forgetting it is how somebody gets emailed twice.
Everything else in this notice applies too, including your right to a copy of what we hold, to correction, to erasure, and to complain to the Data Protection Commission at dataprotection.ie.
Where your people use an AI tool of your own, that happens on your own vendor account under that vendor's terms. It does not pass through this portal and is not stored here.
The knowledge base and Ask FourWinds are the exceptions, and it is worth being exact about them. When somebody in your organisation asks either one a question, the question is sent to Anthropic on our account so an answer can be produced, with what the answer may be drawn from:
Nothing is sent unless somebody asks. The data processing agreement lists Anthropic as a sub-processor for this and gives the transfer basis.
We do store the question and the answer. Both are kept, with the passages that produced the answer, so that you can see what you have already asked and so that we can tell which documents are missing when the knowledge base keeps failing to answer. You can see your own on the Knowledge base page and download them from Settings.
Two things follow from that and you should know both. Only you can read your own questions: a colleague, including an administrator of your organisation, cannot. FourWinds staff can, because the same access that lets us support the product lets us read this table, and we would rather say so than let you find out. If a question would be a problem for us to see, ask it somewhere else.
An earlier version of this notice said the question and the answer were not stored. That was wrong when it was written and we have corrected it rather than quietly changing what the software does.
We share data with the processors that run this service: hosting, database, email delivery and the model provider the knowledge base uses, each under written terms. They are named in the data processing agreement. We do not use a payment processor; invoices are paid by bank transfer and no card data reaches us. We do not sell personal data.
Two of those are worth naming here rather than leaving to the agreement, because they apply to visitors who have no account and will never see it. Resend delivers our email, including the acknowledgement of an enquiry and the copy that reaches us; it is established in the United States and the transfer is covered by standard contractual clauses. Google is the processor for the analytics described above: the cookieless records from every visit, and the fuller measurement where you have consented. That transfer relies on the EU-US Data Privacy Framework.
The database and authentication for this portal are provisioned in Ireland (eu-west-1), and you can ask us for the provider's confirmation of the region at any time. Where a processor operates outside the EEA, transfers are covered by an adequacy decision or standard contractual clauses. We will tell you which mechanism applies to a given processor on request.
Account and support data is retained for the life of the engagement and for six years afterwards where required for legal and accounting purposes. You can request earlier erasure where no such obligation applies.
An enquiry that never becomes a client is kept for six months from our last meaningful contact and then deleted. Rate-limit counts are kept for one hour. Analytics data is retained by Google for fourteen months.
You have the right to access, rectify, erase, restrict, object to processing, and to data portability. You may complain to the Data Protection Commission at dataprotection.ie.