Privacy Policy

Privacy Policy

Last updated: July 2025

This Privacy Policy explains how Mark Smillie / First Construction Finance Limited (“we,” “us,” “our”) collects, uses, discloses and protects personal data in connection with our AI-powered business advisory service (“RingRose AI”). We are committed to complying with the UK GDPR and the Data Protection Act 2018.

1. Data Controller

Name: Mark Smillie / First Construction Finance Limited
Address: 14th Floor, Lyndon House, 62 Hagley Rd, Birmingham, B16 8PE
Email: mark@ringroseandco.co.uk

2. Personal Data We Collect

2.1. Information You Provide Directly

  • Identity & contact details: name, business name, address, email, telephone.
  • Business profile: turnover, sector, number of employees, system and process details, goals and challenges (via our 20-question Business Health Check).
  • Payment data: card or bank details (securely processed and stored by our payment partner).

2.2. Automatically Collected Data

  • Website usage: IP address, device and browser type, pages visited and interaction timestamps (via cookies and analytics tools).
  • Communications records: emails and support tickets to help us assist you and improve our service.

3. Legal Bases for Processing

  • Contract performance: necessary to deliver the subscription service you’ve signed up for.
  • Legitimate interests: to maintain and improve our service, personalise your experience, detect fraud and ensure security.
  • Consent: for marketing communications and non-essential cookies, which you may withdraw at any time.

4. How We Use Your Data

  • Service delivery: building and training your bespoke AI model, producing monthly Profit Boosters and roadmaps.
  • Customer support: responding to enquiries, scheduling calls, and managing billing.
  • Improvement & insights: analysing trends and feedback to enhance our offering.
  • Marketing (where consent given): sending newsletters, updates, and special offers.

5. Data Sharing & Disclosure

  • Service providers: payment processors, email platforms, analytics and hosting providers—only as needed to operate RingRose AI.
  • Professional advisors: accountants and legal consultants, strictly for compliance and operational purposes.
  • No public AI training: your business data is never used to train public models or shared for external AI development.

6. International Transfers

We do not transfer your personal data outside the UK or the EEA, except where our subprocessors operate under UK-approved Standard Contractual Clauses or equivalent safeguards.

7. Data Retention

  • Subscription data: retained for the duration of your subscription plus 6 years for regulatory and tax compliance.
  • Marketing data: kept until you unsubscribe or withdraw consent.
  • Support logs: retained for up to 2 years to support ongoing service and quality improvements.

8. Your Rights

Under UK GDPR, you have the right to:

  • Access the personal data we hold about you.
  • Rectify inaccuracies or incomplete information.
  • Erase data (“right to be forgotten”), subject to legal retention requirements.
  • Restrict processing in certain circumstances.
  • Object to direct marketing or processing based on legitimate interests.
  • Data portability to receive your information in a machine-readable format.

To exercise any right, please email mark@ringroseandco.co.uk. We will respond within one month; if complex, we may extend by up to two further months.

9. Cookies & Similar Technologies

We use:

  • Strictly necessary cookies for essential website functions and security.
  • Performance cookies (analytics) with your consent, to understand and improve site performance.

You can manage or disable cookies via your browser settings, though this may affect website functionality.

10. Security Measures

We implement robust technical and organisational measures—such as access controls, secure development practices, and regular audits—to protect your personal data against unauthorised access, alteration or loss.

11. Changes to This Policy

We may update this policy to reflect changes in law or our operations. We will post the revised date here and notify you by email where significant.

12. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy, please email mark@ringroseandco.co.uk.

Thank you for trusting RingRose AI. We are committed to safeguarding your privacy while driving your business growth.