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What personal data we hold about you, why, and what you can make us do about it.
Version 2026-09-10.1Updated 10 September 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 Limited is in the process of being incorporated. Until that is complete the controller is Oscar Cobbe, trading as FourWinds Digital, at the same address and contact point.
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. It sets cookies on your device, and under regulation 5 of the ePrivacy Regulations (SI 336/2011) that is storage requiring your consent before it happens, not after. So nothing is loaded until you answer the banner: decline and the script is never added to the page, no cookie is 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.
Where you do consent, Google Analytics 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.
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.
Notus is the exception, and it is worth being exact about. When somebody in your organisation asks Notus a question, the question and passages from the documents you have marked ready are sent to Anthropic on our account so an answer can be produced. Only passages that match the question are sent, only when somebody asks, and only from documents marked ready. 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 Notus keeps failing to answer. You can see your own on the Notus 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 Notus uses, each under written terms. They are named in the data processing agreement. We do not use a payment processor; invoices are paid by direct debit 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, and only 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.