Annika de Friend Advisory Ltd Privacy Notice

Registered name: Annika de Friend Advisory Ltd

Last updated: November 2026

This privacy notice explains how Annika de Friend Advisory Ltd (“we”, “us”, “our”) collects, uses, shares and protects personal information about the people we deal with in running our strategic and commercial advisory business and the rights those people have.

We are the controller of your personal information. For more information on controllers and their responsibilities, please see the ICO’s guidance on data protection principles, definitions and key terms.

Contact details

Address

20 Wenlock Road, London, N1 7GU

Telephone

07956 283816

Email

annika@annikadefriend.co.uk

Who this notice applies to

This notice applies to:

What information we collect, use, and why

We collect or use the following information to provide our advisory services to clients:

We collect or use the following personal information to provide our online scorecards and personalised reports:

We collect or use the following personal information to run, secure and improve our website:

We collect or use the following personal information for the operation of client accounts:

We collect or use the following personal information for prospecting and marketing:

We collect or use the following personal information to manage our suppliers and business contacts:

We collect or use the following personal information to comply with legal requirements:

We collect or use the following personal information for dealing with queries, complaints or claims:

Sensitive information. We do not need, and do not ask for, special category information (such as information about health, ethnicity, religion or sexual orientation) or criminal offence information. We ask clients not to include this type of information in anything they share with us. If it is shared with us unexpectedly, we will delete it unless we have a lawful reason to keep it.

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. Which lawful basis we rely on may affect your data protection rights, which are set out in brief below.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide our advisory services to clients are:

Our legitimate interests are:

We have a legitimate interest in providing and improving our strategic and commercial advisory services to recruitment businesses. We use client representatives’ names, contact details, relevant correspondence, meeting notes and advisory records to communicate with them, understand their business priorities, tailor our advice and maintain continuity between sessions.

Clients may also share business information with us, such as financial information, client spend data and team performance information, which may identify members of their staff. We use this only to understand the client’s business and give relevant advice. We ask clients to share only what we need, we keep it confidential, we restrict access to it, and we do not use it to make decisions about individual staff members – those decisions remain with the client.

We also use relevant feedback to improve our services, using anonymised information wherever possible. Clients would reasonably expect this use of their information within an advisory relationship. We balance these benefits against potential privacy impacts by limiting the information we collect, protecting its confidentiality and restricting access to those who need it. Individuals can object to processing based on legitimate interests, and we consider each objection.

For more information on our use of legitimate interests as a lawful basis, please contact us using the details set out above.

Our lawful basis for collecting or using personal information to provide our online scorecards and personalised reports is:

Our legitimate interests are:

We have a legitimate interest in responding to founders who complete one of our scorecards or assessments and ask for a personalised report. We use the details and answers you submit to review your responses, prepare your report and send it to you. Nothing is sent to us unless you choose to submit your answers.

You would reasonably expect us to use your submission in this way, and we use it only for that purpose. We may follow up once to ask whether you would like to discuss your report. Completing a scorecard does not sign you up to our marketing emails, and we will only add you to them if you ask us to. Individuals can object to processing based on legitimate interests, and we consider each objection.

For more information on our use of legitimate interests as a lawful basis, please contact us using the details set out above.

Our lawful bases for collecting or using personal information to run, secure and improve our website are:

Our legitimate interests are:

We have a legitimate interest in running a secure, working website, responding to enquiries sent through it, and understanding in general terms how it is used so that we can improve it. We use only the technical and contact information needed for these purposes. Visitors would reasonably expect this, and the privacy impact is low.

Where the law requires consent for cookies or similar technologies that are not strictly necessary, such as some analytics cookies, we will ask for it through our cookie banner, and you can change your choice at any time.

For more information on our use of legitimate interests as a lawful basis, please contact us using the details set out above.

Our lawful bases for collecting or using personal information for the operation of client accounts are:

Our legitimate interests are:

We have a legitimate interest in managing client accounts efficiently and maintaining accurate records of our business relationships. We use client representatives’ names, contact details, billing addresses, service history and account correspondence to manage bookings, communicate about services, administer billing and resolve account queries. We also keep communication preferences so these can be respected.

This information is necessary to identify the correct client contacts, keep accounts accurate and provide a reliable service. Client representatives would reasonably expect this use of their information. We consider the limited privacy impact proportionate, provided we use only necessary information, keep it secure, restrict access and keep it only for as long as needed. Individuals can object to processing based on legitimate interests, and we consider each objection.

For more information on our use of legitimate interests as a lawful basis, please contact us using the details set out above.

Our lawful bases for collecting or using personal information for prospecting and marketing are:

Our legitimate interests are:

We have a legitimate interest in identifying and contacting businesses that may benefit from our strategic and commercial advisory services, and in sharing relevant insights, service updates and event invitations with business contacts. We use names, job titles, business contact details, LinkedIn profile URLs, publicly available company information and marketing preferences to identify appropriate contacts, check whether a business fits our target client profile, make our communications relevant to the recipient’s role, and respect their preferences.

We contact people in their professional capacity only, about services relevant to their role. We assess whether recipients would reasonably expect this contact, taking account of their professional role, how we obtained their details and any existing relationship. We balance the benefits against possible intrusion by limiting the information we use, keeping communications relevant and proportionate, and providing a clear, easy opt-out in every marketing email.

We send marketing emails to people at limited companies and other corporate bodies on the basis of our legitimate interests. Where the law requires consent – for example, for sole traders and some partnerships, unless they are existing clients who have not opted out – we will only send marketing emails with consent. If someone objects to direct marketing, we stop immediately and keep only the details needed to make sure we do not contact them again.

For more information on our use of legitimate interests as a lawful basis, please contact us using the details set out above.

Our lawful bases for collecting or using personal information to manage our suppliers and business contacts are:

Our legitimate interests are:

We have a legitimate interest in managing our relationships with suppliers, referral partners and other business contacts, so that we can receive the services we need, pay for them and keep in touch. We use only names, business contact details, correspondence and records of the services provided. People acting in a business capacity would reasonably expect this, and the privacy impact is low.

For more information on our use of legitimate interests as a lawful basis, please contact us using the details set out above.

Our lawful basis for collecting or using personal information to comply with legal requirements is:

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

Our legitimate interests are:

We have a legitimate interest in responding to queries, investigating and resolving complaints fairly, and establishing, exercising or defending legal claims. We use relevant names, contact details, correspondence, service history, client records and transaction information to understand what happened, check the facts, communicate with those involved and reach an appropriate resolution. People would reasonably expect relevant information to be reviewed when they raise a query, complaint or claim.

We recognise that these records may contain confidential information or disputed allegations. We balance the benefits against potential privacy impacts by considering only relevant information, checking its accuracy, restricting access and sharing it with advisers or insurers only where necessary. We keep records securely and only for as long as needed. Individuals can object to processing based on legitimate interests, and we assess objections in accordance with data protection law.

For more information on our use of legitimate interests as a lawful basis, please contact us using the details set out above.

Where we get personal information from

Where we obtain your details from someone other than you, we will give you this notice, or a link to it, when we first contact you or, if we do not contact you, within one month of obtaining your details.

How we use AI and prospecting tools

We use AI tools to help us run the business efficiently, including to research and identify potential clients, and to help with drafting, summarising and analysing information. Our prospecting system, Max OS, finds UK companies that match our target client profile (for example, a founder-led business with two or more staff), identifies a suitable person to contact and drafts a first email or LinkedIn message. It never sends anything: Annika reviews every lead and sends every message herself.

These tools support our decisions; they do not make decisions about you that have legal or similarly significant effects. The only outcome is whether we decide to contact you about our services, and you can ask us to stop at any time. We check information produced by AI tools before relying on it, and we correct or delete contact details that turn out to be inaccurate. When we use AI tools to help prepare a personalised scorecard report, we remove your name, contact details and agency name first.

How long we keep information

Information Retention period Reason / action
Company accounting and tax records – invoices, receipts, payment and supporting records Six years from the end of the company financial year they relate to, or longer where legally required. Meet accounting and tax requirements.
Client agreements and essential advisory records – agreed scope, final advice, decisions and relevant correspondence During the engagement, then six years after it ends. Evidence the services provided and deal with any potential claims. We keep relevant records, rather than everything.
Business information shared by clients, including team performance information about client staff During the engagement, then deleted or returned within three months of it ending. Only needed to give advice. Anything forming part of our final advice is kept with the client record above.
Meeting or call recordings and full AI transcripts, where used During the client relationship. Allow us to check back on notes when needed. Key points are kept in our meeting notes.
Prospects who haven’t responded 12 months from obtaining their details. Deleted (including from Max OS) if there has been no meaningful engagement or documented reason to keep them.
Engaged prospects, unsuccessful enquiries and “not now” contacts 24 months after the last meaningful interaction. Allow for a longer buying cycle. Extended only for a documented reason, such as an agreed future follow-up.
Scorecard and assessment submissions and personalised reports from people who don’t become clients 24 months after the last meaningful interaction. Support follow-up about the report. Submissions are deleted from our form provider once saved to our CRM. If you become a client, we keep only relevant information in your client record.
Recruitment Founder Reflection responses and discovery notes from people who don’t become clients 24 months after the last meaningful interaction, deleting unnecessary details sooner. Support relevant follow-up. If they become clients, we keep only relevant information within their client record.
Marketing subscribers and their preferences While subscribed and marketing remains relevant; reviewed after 24 months without meaningful engagement. Inactive records removed unless continued retention is justified. Marketing stops immediately on withdrawal or objection.
Marketing opt-outs / suppression list For as long as needed to make sure we do not contact you again. We keep only the identifiers needed, plus the date and scope of the opt-out.
Evidence of marketing consent While we rely on consent, then three years after the last marketing sent under it, unless needed for an ongoing complaint. Show how permission was obtained.
Website technical and security logs In line with our hosting provider’s settings, normally no longer than 12 months. Deliver and protect the website.
Website analytics information, where used No longer than 14 months. Understand how the website is used, in aggregate, so we can improve it.
Routine queries (including website enquiries) that don’t lead to an engagement 12 months after resolution. Handle follow-up questions, then delete unless another category applies.
Substantive complaints, disputes and claims Six years after final resolution, or longer where legal advice or insurance requirements justify it. Keep the evidence needed to explain the outcome or handle related proceedings.
Data protection requests and responses Three years after closure. Show how the request was handled. Identity documents are deleted once verification is complete.
Supplier contact details and correspondence During the relationship, then 12 months after it ends for routine information. Contracts and essential dispute records are kept for six years; invoices under the accounting rule.

For more information on how long we keep your personal information, or the criteria we use to decide this, please contact us using the details above.

Who we share information with

We do not sell personal information, and we do not share client or prospect contact details with other businesses for their own marketing.

Data processors

These organisations provide services to us and use personal information only on our instructions:

Name of processor What the data processor does for us
HubSpot Provides our CRM system, storing and organising prospect and client contact details, correspondence, marketing preferences and service records, and sending our marketing emails.
Max OS (Russell Bennett Ltd) Provides our AI-assisted prospecting system, which finds businesses that match our target client profile, provides business contact details for a suitable contact and drafts first messages for us to review. Data is stored on a dedicated server in London.
Formspree Receives and stores submissions from our online scorecards and forms and passes them to us.
Cloudflare (Cloudflare Pages) Hosts our online scorecards, this privacy notice and, when launched, our website, processing technical information such as IP addresses to deliver and secure the pages.
Microsoft – Microsoft 365 Provides business email, document storage, collaboration and online meetings, processing personal information within correspondence, files and meeting records.
Avensys Tech Provides IT management, support, security and backup services, with access to personal information where necessary to deliver those services.
Xero Provides accounting and invoicing software, storing client and supplier details, invoices and financial transaction records.
Calendly Manages appointment bookings, including names, contact details, booking responses and calendar information.
Jotform Provides online forms and document workflows for sending terms of business and collecting client details, responses and acceptance records, including electronic signatures where used.
Otter.ai Records and transcribes meetings and produces summaries, processing participants’ names, voices and information discussed during meetings.

Others we share personal information with

Sharing information outside the UK

Some of the organisations we use are based outside the UK, or use support teams and infrastructure outside the UK. When personal information is transferred outside the UK, we make sure it is protected in line with the UK GDPR, either because the country has been assessed by the UK as providing adequate protection, or by using an approved safeguard such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses.

For further information, or to obtain a copy of the safeguard for any of the transfers below, please contact us using the details above.

Organisation name: HubSpot, Inc. and its affiliates

Category of recipient: CRM and marketing email provider

Country the personal information is sent to: United States (and other countries where HubSpot’s support teams and sub-processors are based)

How the transfer complies with UK data protection law: The UK Addendum to the EU Standard Contractual Clauses in HubSpot’s Data Processing Agreement, and the UK Extension to the EU-US Data Privacy Framework.

Organisation name: Microsoft Corporation and its affiliates

Category of recipient: Email, document storage, collaboration and cloud provider

Country the personal information is sent to: European Union (where our Microsoft 365 data is stored), with limited remote access by Microsoft support teams in other countries, including the United States

How the transfer complies with UK data protection law: European Union: UK adequacy regulations. Remote support access from other countries: the UK Addendum to the EU Standard Contractual Clauses in Microsoft’s Data Protection Addendum, and, for the United States, the UK Extension to the EU-US Data Privacy Framework.

Organisation name: Specialist services used by Max OS (Anthropic, Apify, Hunter, Bouncer and MillionVerifier)

Category of recipient: Message drafting, public profile research, and email finding and checking for our prospecting system. Max OS stores our data in the UK and sends each service only the minimum information it needs

Country the personal information is sent to: United States (Anthropic; some Apify and Hunter processing) and the European Union

How the transfer complies with UK data protection law: European Union: UK adequacy regulations. United States: the EU Standard Contractual Clauses with the UK International Data Transfer Addendum, under each provider’s data processing terms.

Organisation name: Formspree, Inc.

Category of recipient: Online form provider for our scorecards and website forms

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The safeguards set out in Formspree’s data processing terms (details available on request).

Organisation name: Cloudflare, Inc.

Category of recipient: Website hosting and security provider

Country the personal information is sent to: United States and other countries in Cloudflare’s global network

How the transfer complies with UK data protection law: The UK Extension to the EU-US Data Privacy Framework, and the UK Addendum to the EU Standard Contractual Clauses in Cloudflare’s Data Processing Addendum.

Organisation name: Xero Limited and its affiliates and sub-processors

Category of recipient: Accounting software hosting, infrastructure and support

Country the personal information is sent to: New Zealand, the United States, Australia and other countries listed by Xero

How the transfer complies with UK data protection law: New Zealand: UK adequacy regulations. Other countries: the safeguards set out in Xero’s data processing terms.

Organisation name: Otter.ai, Inc.

Category of recipient: AI meeting recording, transcription and summarisation provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The recipient is certified under the UK Extension to the EU-US Data Privacy Framework (the “UK-US data bridge”), which the UK Government has assessed as providing adequate protection.

Organisation name: Calendly, LLC

Category of recipient: Online appointment scheduling provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The recipient is certified under the UK Extension to the EU-US Data Privacy Framework (the “UK-US data bridge”), which the UK Government has assessed as providing adequate protection.

Organisation name: Jotform Inc.

Category of recipient: Online forms and electronic document/signature provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The recipient is certified under the UK Extension to the EU-US Data Privacy Framework (the “UK-US data bridge”), which the UK Government has assessed as providing adequate protection.

Organisation name: JKS Outsourcing

Category of recipient: Accounting and tax services provider

Country the personal information is sent to: Sri Lanka

How the transfer complies with UK data protection law: We are putting a UK International Data Transfer Agreement (IDTA) in place with JKS Outsourcing.

Organisation name: OpenAI (ChatGPT)

Category of recipient: General AI assistant for research, drafting, summarisation and analysis

Country the personal information is sent to: United States and other countries where OpenAI operates

How the transfer complies with UK data protection law: We use this service under OpenAI’s standard terms. OpenAI is responsible for protecting the information it receives and, as described in its privacy policy, relies on adequacy regulations and standard contractual clauses for international transfers.

Organisation name: Anthropic (Claude)

Category of recipient: General AI assistant for research, drafting, summarisation and analysis

Country the personal information is sent to: United States and other countries where Anthropic operates

How the transfer complies with UK data protection law: We use this service under Anthropic’s standard terms. Anthropic is responsible for protecting the information it receives and, as described in its privacy policy, relies on adequacy regulations and standard contractual clauses for international transfers.

Keeping your information secure

We use appropriate technical and organisational measures to protect personal information, including access controls, security software and backups managed by our IT support provider. Access to personal information is limited to those who need it.

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: annika@annikadefriend.co.uk

We will acknowledge your complaint within 30 days, look into it without undue delay, and tell you the outcome.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Cookies and changes to this notice

This notice covers our website and online scorecards. Our scorecard pages do not currently use cookies or analytics. If we use cookies that are not strictly necessary, for example on our website, our cookie banner and cookie notice will explain them and ask for your consent where the law requires it.

We keep this notice under review and will update it if we change how we use personal information, for example if we start using a new supplier or tool. The date at the top shows when it was last updated.