Privacy Notice
Last updated 13 October 2026
Who we are
Commercial Intelligence Partners ("CIP", "we", "us", "our") is the data controller for the personal data described in this notice. If you have any question or request about your data, contact us at info@commercialintelligencepartners.co.uk.
This notice covers visitors to our website, people who join our waitlist or contact us, our customers' account users (including staff users), and people who buy from our template shop. It does not cover business data our customers upload to the Service: for that data the customer is the controller and we process it on their behalf, as set out in our Data Processing Agreement (/legal/dpa).
Our clients are businesses such as pubs, cafés and delis, each using CIP to run reports, send invoices and keep records. When a client puts personal data into CIP — for example details of its staff, its customers or its suppliers — the client is the controller and we are its processor. If your data is held in CIP by a business you deal with, that business's own privacy notice explains how it uses your data, and you should contact that business first to exercise your rights. If you contact us, we will pass your request to the business.
Multiple venues
A client can run several venues (sites) in one account. Data about a venue belongs to the client. Users see only the venues the client gives them access to.
Staff of our clients
If your employer uses CIP, your employer may keep a staff record about you in CIP, such as your name, email, role, venue, reporting line and holiday requests. Your employer is the controller of that record and decides how it is used. We process it on your employer's behalf. Your employer's staff privacy notice explains more, and your employer is the right place to make requests about it.
If you log in to CIP as a staff user, we are the controller of your login account:
- Name, email address, sign-in and multi-factor records, session and device information — to create and secure your login and let you access your employer's account. Lawful basis: legitimate interests (running a secure service your employer has chosen to use). Kept: until you are removed from all client accounts, or 12 months after your employer's account closes.
- Security and audit logs of your activity — to protect the service and investigate misuse. Lawful basis: legitimate interests (security). Kept: as set out in our Data Retention and Deletion Policy (/legal/retention).
- Service emails, such as invitations and sign-in codes — to run your login. Lawful basis: legitimate interests. Kept: as above.
We do not use staff users' data for marketing, and we do not share it with your employer beyond what your employer can already see in its own account.
Customers and suppliers of our clients
If a business sends you an invoice or payment reminder through CIP, that business is the controller. It gave us your name, email address and (if on the invoice) postal address, and the invoice details. We send the email for the business through our email provider, Resend, and record whether it was delivered. Replies go to the business, not to us. The business is responsible for having a lawful basis to send you these emails; invoices and payment reminders are service messages about a transaction, not marketing. If you do not think you should be receiving these emails, contact the business. If you cannot resolve it, tell us at info@commercialintelligencepartners.co.uk and we will look into whether the business is following our rules.
What we collect and why
- Account and sign-in data: your name, email address and authentication details (your sessions, the public keys of any passkeys, hashed one-time codes and any authenticator-app secret), which we store ourselves in our UK database so you can sign in securely. If you choose to sign in with Google (or Microsoft, where offered), that provider tells us your name and email address; it acts as an independent controller of your account with it, under its own privacy policy, and is not our processor. Our sign-in page also uses Cloudflare Turnstile, a bot-protection check that runs when you ask for a sign-in code and sees your IP address and browser details. Lawful basis: performance of our contract with you (or your employer).
- Payment data: handled entirely by Stripe. Your card details are entered on Stripe's secure payment page and never reach our systems; we receive only confirmation of the payment and your billing contact details. Lawful basis: contract, and our legal obligation to keep accounting records.
- Waitlist signups: your email address and, if you give them, your name and business name, so we can tell you when a place opens up. Lawful basis: consent, which you can withdraw at any time.
- "Book a review" enquiries: the name, email address, business name, number of sites and message you send us, and your phone number if you give one, so we can reply and arrange your review. Lawful basis: legitimate interests (answering a business enquiry you sent us).
- Calculator "email me my results" requests: your email address and the figures you entered and the results, so we can send you the results you asked for. Lawful basis: legitimate interests (sending you what you asked for). If you also tick the separate box, we will send you occasional tips by email; that is marketing based on your consent, which you can withdraw at any time using the link in every email.
- Secure upload links: if we give you a secure link to send us files (for example sales or cost exports), the files you send are stored in the EU, used only to prepare your analysis, and deleted with your account. They are client data, so we handle them as your processor under our Data Processing Agreement (/legal/dpa).
- Spam protection: our "book a review", calculator and waitlist forms use Cloudflare Turnstile, a bot-protection check that sees your IP address and browser details when you send the form. Lawful basis: legitimate interests (keeping our forms free of spam and abuse).
- Support messages: your message, our reply and your contact details, so we can resolve your query. Lawful basis: our legitimate interest in supporting users.
- Template orders: the date, time and IP address at which you confirmed you wanted immediate delivery of digital content. This is our evidence of the consent the Consumer Contracts Regulations 2013 require, and we keep it with your order. Lawful basis: legal obligation and legitimate interests.
- Technical data: if you send us a support message, or your browser reports an error on our site, we store the browser and operating system your device reported (the "user agent") so we can reproduce the problem. Lawful basis: our legitimate interest in keeping the site working.
We do not make automated decisions about you, we do not profile you for marketing or advertising, and we never sell your personal data or share it for advertising.
AI features
Some clients choose to turn on AI features, which write narrative commentary about their business's performance. When a client has them on, we send the figures and context needed to write the commentary to Anthropic PBC in the United States, as our sub-processor. The numbers are calculated by CIP's own software; the commentary may include names that appear in the client's data (for example a supplier's name). Anthropic does not use this data to train its models, under its commercial terms with us, and keeps it only for the limited period those terms allow. The AI commentary is information for the client — it is not used to make decisions about individuals, and it is not financial advice.
Website analytics
We measure how our website and app are used in two ways.
Basic visit counting (everyone, unless you switch it off). Our own analytics are first-party and cookieless: unless you choose "Accept cookies", they store nothing on your device and read nothing stored on it, apart from checking your own cookie choice and opt-out setting. Instead, when a page loads, our server combines the network address and browser description your browser sends with every request with a secret that changes every day and is destroyed within 48 hours, and keeps only the resulting one-way code. We never store your IP address or your browser description. Once the day's secret is destroyed, the code cannot be linked back to you, and it cannot be used to follow you across days or websites. We record pages viewed, roughly for how long and how far you scrolled, roughly where in the world you are (country, region and city, from the network, never a precise location), the type of device and browser, and roughly how visitors found us. To stop abuse of the counter, we also keep a short-lived coded form of your network address for rate limiting, deleted within about two days. Choosing "Reject cookies" does not stop this cookieless count; you can object to it at any time on our Privacy choices page (/privacy-choices) by switching counting off for your browser. We use these statistics only to understand how the website is used and to improve it, and we share them with no one except the providers that host our systems for us. UK law allows this kind of measurement without consent (the statistical-purposes exception in the Privacy and Electronic Communications Regulations) provided we explain it, as we do here, and give you a simple free way to object, which the Privacy choices page does. Lawful basis under UK GDPR: our legitimate interest in improving the website.
Analytics cookies and session recordings (only if you say yes). If you choose "Accept cookies", we also:
- set a cookie, cip_vid, holding a random code, so our own analytics can recognise your browser when you come back (for up to 12 months). Your visits are then linked by that code instead of the daily one;
- keep a note, cip_seen, in your browser's local storage holding the date of your first visit, so we can count new and returning visitors. Only a yes/no answer ever leaves your device;
- use PostHog, a product analytics service hosted in the EU (Frankfurt, Germany), to record how you use our pages (clicks, scrolling and page changes) and to build heatmaps, funnels and returning-visitor journeys.
Session recordings replay what happened on a page so we can see where people get stuck. Anything you type into a form is always hidden before it leaves your browser. Inside the signed-in app, all text on screen is hidden too, so recordings show layout and clicks, not names or figures. We do not record admin pages, sign-in and sign-up pages, your account settings and purchases pages, the page shown after a template purchase, invitation links, shared report pages or invoice pages. Attributes of page elements (such as link addresses and image sources) are never sent. If you are signed in, PostHog knows you only by a coded id made from your user id, and by your business's account id. Never your name, email address or figures. We have set PostHog not to store your IP address. We use this information only to improve CIP. Lawful basis: your consent. You can withdraw it at any time on our Privacy choices page, and we stop straight away. Saying no does not affect your use of CIP.
Cookies and similar technologies
We do not use advertising cookies. When you first visit, we ask whether you agree to analytics cookies and session recordings. Nothing in the "analytics" group below is set until you say yes. You can change your choice at any time on our Privacy choices page (/privacy-choices).
Strictly necessary (no consent needed):
- __Secure-cip.session_token — set by CIP when you sign in, including with a passkey, Google or Microsoft. Keeps you securely signed in; holds only an unguessable token, and the session itself is stored in our database. 7 days, renewed while you use CIP; deleted on sign-out.
- cip_staff_org — set by CIP for staff users who work for more than one business. Remembers which business you chose. 30 days.
- cip_consent — set by CIP. Remembers your analytics choice, and holds a random consent id, your choice and the date. 12 months after "Accept cookies", 6 months after "Reject".
- Short-lived security cookies set by CIP while you sign in with Google or Microsoft, or connect Xero (such as cip_xero_oauth_nonce). A few minutes.
- Cloudflare Turnstile — set by Cloudflare when you ask for a sign-in code or send one of our public forms. May set a short-lived cookie or similar identifier to tell people from bots.
- cip_analytics_optout (local storage) — set by CIP only if you switch counting off on our Privacy choices page. Remembers that objection so we can honour it. Kept until you clear it.
Our cookieless visit count stores nothing in your browser and reads nothing stored in it, apart from checking your own cookie choice and opt-out setting.
Analytics (only with your consent):
- cip_vid — set by CIP. A random code so our own analytics can recognise returning visitors. 12 months.
- cip_seen (local storage, not a cookie) — set by CIP. Records the date of your first visit so we can count new and returning visitors. Only a yes/no flag ever leaves your device. Kept until you clear it, and removed if you reject, withdraw your consent or switch counting off.
- ph_…_posthog (cookie and local storage) — set by PostHog's script on our website. Identifies your browser and current visit for PostHog analytics and session recordings. 12 months. PostHog also keeps a note in session storage while a recording is running, deleted when you close the tab.
Other providers' cookies:
- Stripe's cookies apply only on Stripe's own checkout pages and are covered by Stripe's privacy policy.
- Video embeds from YouTube or Vimeo on some product pages load only after you press play. The provider then receives your IP address and may set its own cookies under its own privacy policy.
Record of your choice: when you accept or reject, we store a random consent id, your choice, the version of this notice, the time, and whether you chose in the banner or on the Privacy choices page. We do not store your IP address or browser details with it. We keep it so we can show what you agreed to.
Sub-processors and international transfers
We share personal data only with the service providers who help us run CIP, listed with their locations on our sub-processors page (/legal/subprocessors): Vercel (website and application hosting), Neon (database hosting, London, which also holds your sign-in and session records), Cloudflare (bot protection on our sign-in page and public forms, and storage of uploaded files, logos, PDFs and templates in the EU), Stripe (payments), Resend (sending emails you have asked for or that relate to your account or order), PostHog (product analytics and session recordings, hosted in the EU, only if you accept analytics), and, only if AI features are enabled, Anthropic. Each is bound by a contract that requires it to protect your data and use it only on our instructions.
Our database is hosted by Neon in London, United Kingdom, and backups are also held in the UK. Some providers (including Vercel, Cloudflare, Resend, Stripe and PostHog) are based in, or process data in, the United States. Where personal data is transferred outside the UK, we rely on UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework, where the provider is certified) or on the International Data Transfer Agreement or Addendum approved under UK law, after checking that the protection is not materially lower than in the UK. You can ask us for more information about these safeguards at info@commercialintelligencepartners.co.uk.
We may also disclose data where the law requires it, or to protect our rights or the safety of others.
How long we keep it
- Waitlist entries: until you ask us to remove them, you become a customer, or 24 months pass with no activity.
- "Book a review" enquiries: until 24 months after our last contact with you.
- Calculator results requests (your email, the figures and the results): until 24 months pass with no activity, or until you ask us to remove them.
- Files sent through a secure upload link: deleted with your account (see our Data Retention and Deletion Policy, /legal/retention).
- Account records and support messages: while your account is active, and afterwards only as long as needed for accounting, tax or legal reasons (normally up to six years).
- Template orders, including the immediate-delivery consent record: six years from the order, to meet our accounting and consumer-law obligations.
- Raw analytics events: deleted automatically after 13 months. For visitors who have not accepted analytics, the daily secret used to create the visitor identifier is destroyed within 48 hours, which makes older events permanently anonymous. For visitors who have accepted, events stay linked to the cip_vid code until they are deleted. Aggregate statistics may be kept longer.
- PostHog session recordings: deleted after 30 days. Other PostHog analytics events: deleted after 12 months.
- Records of your cookie choice: 25 months, so we can show the choice that applied at any time during its 12-month life. The marketing tick-box on a calculator results request is kept with that request, not with your cookie choice, and is deleted with it (24 months with no activity, or sooner on request).
- Staff users' login accounts and client account data generally: see "Staff of our clients" above and our Data Retention and Deletion Policy (/legal/retention), which gives full detail for every category.
How we protect it
Data is encrypted in transit and at rest, access is limited to the people who need it to run the Service, administrative access is logged, and each customer's data is kept separate from every other customer's. Our Security Overview (/legal/security) explains this in full.
Complaints to us
If you are unhappy with how we have handled your personal data, you can complain to us at info@commercialintelligencepartners.co.uk, with the subject line "Data protection complaint". We will acknowledge your complaint within 30 days, look into it without undue delay, and tell you the outcome. If your complaint is about data a client holds in CIP (for example your employer or a business that invoiced you), we will pass it to that client and help them respond.
Your rights
Under UK data protection law you have the right to: ask for a copy of your personal data; ask us to correct it; ask us to delete it; ask us to restrict or stop certain processing, or object to processing based on our legitimate interests; receive your data in a portable format; and withdraw consent at any time, where we rely on consent. You also have rights about automated decisions, though we do not use your personal data this way (see "What we collect and why" above).
To use any of these rights, email info@commercialintelligencepartners.co.uk. We will respond within one month, which can be extended by two further months for complex requests; we will make reasonable and proportionate searches for your data. If you are unhappy with how we have handled your data, please tell us first (see "Complaints to us" above) — you also have the right to complain to the Information Commission (which replaced the Information Commissioner's Office on 30 September 2026) at ico.org.uk or on 0303 123 1113.
Children
Our website and Service are intended for businesses and are not directed at children under 16. We do not knowingly collect their personal data.
Changes to this notice
We may update this notice from time to time. The date at the top of this page shows when it last changed, and we will tell account holders about any significant change.