Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
1. Contact details
2. What information we collect, use, and why
3. Lawful bases and data protection rights
4. Our Lawful bases and data protection rights
5. Where we get personal information from
6. How long we keep information
7. Where your data is stored and International Transfers
8. Who we share information with
9. How to complain
1 Contact Details
Telephone: 07957 488256
Email: info@blackfeatheruk.com
2 What information we collect, use and why
We collect or use the following information to provide and improve products and services for clients:
· Names and contact details
· Addresses
We collect or use the following personal information for the operation of client or customer accounts:
· Names and contact details
· Addresses
· Purchase or service history
We collect or use the following personal information for information updates or marketing purposes:
· Names and contact details
· Addresses
· Marketing preferences
· Purchase or account history
We collect or use the following personal information for research or archiving purposes:
· Names and contact details
· Addresses
· Purchase or client account history
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Addresses
· Account information
· Photographs
· Relevant information from previous investigations
· Correspondence
3 Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
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.
4 Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Managing our business operations and fulfilling our framework agreements.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Conducting credit risk assessments and managing short-term credit facilities.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Promoting Blackfeather's services and framework benefits to relevant B2B audiences to grow our business.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for research or archiving purposes:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Analyzing framework usage and market trends to improve our business model.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Protecting our business against legal liability and ensuring disputes are resolved efficiently.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
5 Where we get personal information from
· Directly from you
· Publicly available sources
· Market research organisations
· Credit reference agencies
· Suppliers and service providers
6 How long we keep information
See data retention schedule below:
| Data Category | Data Type Examples | Retention Period | Justification / Legal Basis |
|---|---|---|---|
| Client/Customer Account Information | Name, address, contact details, account history | 6 years after last transaction or contract end | Limitation Act 1980 - potential legal claims period; HMRC record-keeping requirements |
| Financial & Transaction Records | Invoices, payments, billing information | 6 years from end of financial year | Companies Act 2006; HMRC tax record requirements |
| Contractual Records | Signed contracts, agreements, terms of service | 6 years after contract expiry | Limitation Act 1980 - contractual claims limitation period |
| Marketing & Communications Data | Marketing preferences, consent records, correspondence | 2 years from last meaningful contact | ICO guidance on marketing consent; legitimate interest assessment |
| Enquiry & Correspondence Records | General enquiries, emails, letters | 2 years from resolution of enquiry | Business operational purposes; proportionate retention |
| Complaints & Disputes | Complaint details, investigation records, resolutions | 6 years from resolution | Limitation Act 1980 - potential litigation period |
| Consent Records | Records of consent given/withdrawn | Duration of consent + 6 years | GDPR Article 7(1) - demonstrable consent requirement |
| Employment Records (if applicable) | Staff personal data, HR records | 6 years after employment ends | Limitation Act 1980; Employment law requirements |
| Research & Statistical Data | Anonymised/aggregated data for analysis | Indefinitely (if truly anonymised) | Anonymised data falls outside GDPR scope |
| CCTV & Security Footage (if applicable) | Video recordings, access logs | 30 days unless incident occurs | ICO CCTV Code of Practice; proportionality principle |
| Website & Cookie Data | IP addresses, browsing behaviour, cookie identifiers | 13 months maximum | ICO guidance; PECR regulations; ePrivacy requirements |
7 Where your data is stored and International Transfers
Your data may be transferred to, and stored at, a destination outside the United Kingdom (such as the European Economic Area or the United States) by our cloud service providers. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are in place (such as UK Adequacy Regulations or Standard Contractual Clauses).
8 Who we share information with
Data Processors:
Manufacturers, Suppliers and Service Providers:
This data processor does the following activities for us: They market their companies products and services to our Client\'s as well as coordinate the supply and delivery of Products to the Client\'s businesses
Others we share personal information with:
· Debt collection agencies
· Suppliers and service providers
· Professional consultants
· Third Parties:
o Approved suppliers on the Blackfeather Framework
3 How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
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
Last updated: 28/04/2026

