ntrnl respects your privacy and is committed to handling personal information responsibly and transparently.
This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we may share it with, how long we keep it and the rights available to you.
It applies when you visit ntrnl.ai, submit a form, book a call, communicate with us, receive communications from us, become a client, or otherwise interact with ntrnl.
1. Who We Are
ntrnl provides client acquisition strategy, implementation and consulting services.
For personal data collected directly by ntrnl for our own business purposes, ntrnl acts as the data controller.
For privacy-related questions or requests, contact:
The information we collect depends on how you interact with us.
Information You Provide
This may include:
Your name
Email address
Telephone number
Company or business name
Job title or role
Website and social media profiles
Information submitted through application, qualification, contact or booking forms
Information about your business, offer, pricing, revenue, client acquisition activity and goals
Information you provide before, during or after a call
Messages, emails and other correspondence with us
Feedback, testimonials or survey responses
Client onboarding information
Billing and transaction information
Files, documents, marketing materials and other information provided during a client engagement
Account or platform access information where required to deliver agreed services
We ask that you do not provide sensitive personal information unless it is genuinely necessary for the relevant purpose.
Information Collected Automatically
When you use our website, we may collect information such as:
IP address
Browser and device information
Operating system
Pages viewed
Time spent on pages
Links or buttons clicked
Referral source
Approximate geographic information derived from IP address
Website and funnel activity
Advertising attribution information
Cookie identifiers and similar technologies
The exact information collected depends on the technologies enabled on the website and your cookie choices.
Information From Other Sources
We may receive information from:
Advertising platforms
CRM and marketing systems
Scheduling and booking platforms
Social media platforms
Analytics providers
Payment providers
Business partners
Referral partners
Publicly available business sources such as LinkedIn or company websites
Where we obtain personal information from another source, we use it only where we have a lawful basis to do so.
3. How We Use Personal Data
We may use personal data to:
Respond to Enquiries and Applications
This includes:
Responding to questions
Reviewing applications
Assessing whether our services appear suitable
Arranging calls
Sending appointment confirmations and reminders
Preparing for meetings
Following up after an enquiry or call
Deliver Our Services
For clients, we may use personal data to:
Onboard you
Communicate about your engagement
Provide strategy and consulting
Build and implement client acquisition systems
Create marketing assets and campaigns
Configure funnels, CRM systems and automations
Analyse performance
Provide documentation and resources
Manage projects
Provide support
Invoice and administer payments
Operate and Improve ntrnl
We may process information to:
Maintain business records
Improve our website, funnels and services
Understand how people interact with our website and marketing
Analyse business and marketing performance
Maintain the security of our systems
Prevent misuse, fraud or other harmful activity
Manage suppliers and service providers
Establish, exercise or defend legal claims
Comply with legal and regulatory obligations
Marketing
Where permitted by law, we may use personal data to:
Send useful content and resources
Send newsletters
Tell you about ntrnl services
Follow up on previous enquiries
Run advertising and retargeting campaigns
Measure marketing effectiveness
Build or use advertising audiences
Personalise marketing communications
You can object to direct marketing at any time.
4. Our Lawful Bases
Under UK data protection law, we must have a lawful basis for processing personal data.
Depending on the circumstances, we may rely on:
Contract
Where processing is necessary to enter into or perform a contract with you.
For example:
Delivering purchased services
Client onboarding
Billing
Project communication
Providing agreed deliverables
Steps Before Entering Into a Contract
Where you ask us to take steps before entering into an agreement.
For example:
Reviewing an application
Responding to a service enquiry
Holding a consultation or audit call
Preparing a proposal
Legitimate Interests
We may process data where it is reasonably necessary for our legitimate business interests and those interests are not overridden by your rights.
These interests may include:
Operating and improving ntrnl
Measuring business and marketing performance
Responding to business enquiries
Protecting our systems
Preventing fraud
Maintaining appropriate business records
Certain forms of B2B marketing
Developing and improving our services
Establishing or defending legal rights
Where we rely on legitimate interests, we consider the purpose, necessity and potential effect on the individual.
Consent
We rely on consent where required, including for certain:
Marketing communications
Cookies
Advertising technologies
Tracking technologies
You can withdraw consent at any time.
Legal Obligation
We may process information where necessary to comply with a legal obligation, including accounting, tax, regulatory and legal requirements.
5. Applications, Qualification and Booking
When you apply for or book a call with ntrnl, we may ask questions about your business to understand whether our services are likely to be appropriate.
These questions may relate to matters such as:
Your offer
Pricing
Business stage
Revenue
Current client acquisition activity
Challenges
Goals
Urgency
Ability or intention to invest in implementation
We may use rules, software and automation to organise, score or route enquiries.
For example, answers may determine whether you are shown a booking option, directed to another resource or followed up with differently.
We do not use solely automated decision-making that produces legal or similarly significant effects on individuals.
6. Email, SMS and Other Communications
We may communicate with you by email, telephone, SMS or other communication channels where appropriate.
Service and Appointment Communications
If you book a call, submit an application or become a client, we may send operational communications such as:
Booking confirmations
Appointment reminders
Preparation instructions
Requested resources
Client updates
Billing information
Support communications
These are separate from general promotional marketing.
Marketing Communications
We may send marketing communications where we have consent or another lawful basis and where permitted by applicable electronic marketing laws.
The rules can differ depending on whether the recipient is an individual, sole trader, partnership or corporate organisation.
Every marketing communication we send will provide an appropriate method of opting out where required.
You can also request that we stop sending marketing communications by emailing:
If you opt out, we may retain limited information on a suppression list so that we can respect your preference in the future.
7. Cookies, Pixels and Tracking Technologies
Our website may use cookies, pixels and similar technologies.
These technologies can be used for:
Strictly Necessary Functions
These help the website or funnel function properly, maintain security or provide a service you have requested.
Analytics
These may help us understand:
Website traffic
Page usage
Funnel performance
Conversion behaviour
Traffic sources
Advertising and Attribution
We may use technologies supplied by advertising platforms such as Meta, Google or LinkedIn to:
Measure advertising performance
Attribute enquiries and bookings
Understand interactions with campaigns
Create advertising audiences
Retarget website visitors where permitted
Non-essential cookies and similar technologies are not intended to be activated until the necessary consent has been obtained where consent is required.
You can manage your choices through the cookie controls provided on our website.
You can also control or remove cookies through your browser settings, although doing so may affect some website functionality.
8. Advertising Platforms
ntrnl may advertise through platforms including Meta, Google, LinkedIn and other digital advertising providers.
Where permitted, these platforms may receive information about interactions with our website or funnels.
Depending on the platform and configuration, this can include:
Cookie or device identifiers
Website events
Page views
Form activity
Conversion events
Advertising attribution data
Hashed contact information where appropriate
Advertising providers may process information under their own privacy terms in addition to acting as service providers to us.
We use consent controls and other measures where required by applicable law.
9. CRM, Automation and Service Providers
We use third-party software and service providers to operate ntrnl and deliver our services.
These may include providers for:
CRM and funnel management, including platforms such as GoHighLevel
Email and SMS delivery
Calendar and appointment booking
Website hosting
Analytics
Advertising
Payment processing
Accounting
Cloud storage
Business communication
Project management
Automation
AI-assisted tools
Data security and infrastructure
We only share personal information that is reasonably necessary for the relevant provider to perform its function.
Where required, we put appropriate contractual or other safeguards in place with service providers that process personal data on our behalf.
We do not sell personal data.
10. AI-Assisted Tools
ntrnl uses artificial intelligence and AI-assisted software as part of its operations and service delivery.
This may include tools used for:
Research
Analysis
Drafting
Content development
Marketing strategy
Process design
Automation
Summarisation
Internal productivity
Client delivery
AI providers may include services supplied by organisations such as OpenAI, Anthropic and other technology providers.
Where personal data is processed using AI tools, we aim to limit the information used to what is reasonably necessary for the relevant task.
We do not rely on AI alone to make decisions about individuals that have legal or similarly significant effects.
11. Client Data We Process on Behalf of Clients
During an engagement, ntrnl may process personal data controlled by a client.
For example, this may include:
Prospect information
Lead data
CRM records
Customer information
Advertising data
Email lists
Funnel submissions
Appointment data
Where we process this information solely on the client's instructions, the client generally acts as the data controller and ntrnl acts as a data processor.
In these circumstances, the client's own privacy notice determines how and why that data is processed.
Our processing is governed by the relevant client agreement and any applicable data-processing terms.
12. Sharing Personal Data
We may share information with:
Technology and software providers
Payment processors
Professional advisers
Accountants
Contractors or team members involved in delivering our services
Advertising and analytics providers
Business partners where appropriate
Government, regulatory or law-enforcement authorities where legally required
A purchaser, investor or successor in connection with a legitimate sale, merger, restructuring or transfer of the business
We do not sell or rent personal data to third parties.
13. International Data Transfers
Some of the technology providers we use may process or store information outside the United Kingdom.
This may include processing in the United States or other countries.
Where personal data is transferred internationally, we take reasonable steps to ensure that an appropriate legal transfer mechanism is in place where required.
Depending on the circumstances, this may include:
UK adequacy regulations
The UK International Data Transfer Agreement
The UK Addendum to approved Standard Contractual Clauses
Another transfer mechanism permitted by applicable data protection law
You may contact us if you would like further information about the safeguards relevant to a particular transfer.
14. How Long We Keep Personal Data
We keep personal data only for as long as reasonably necessary for the purpose for which it was collected and for legitimate legal, accounting, contractual or business requirements.
Retention periods depend on the type of information and why we hold it.
As a general guide:
Enquiry and application information may be retained while the relationship remains relevant and for a reasonable period afterwards
Client records may be retained for the duration of the engagement and afterwards where necessary for legal, contractual, tax or accounting purposes
Financial and transaction records may be retained for the period required by applicable law
Marketing information may be retained while you remain subscribed or while we have a lawful reason to contact you
Suppression records may be retained where necessary to ensure that marketing opt-outs continue to be respected
Website analytics and advertising data are retained according to our configuration and the relevant platform settings
When information is no longer reasonably required, we will delete, anonymise or otherwise securely dispose of it where appropriate.
15. Your Data Protection Rights
Depending on the circumstances and the lawful basis being used, you may have the right to:
Request access to personal data we hold about you
Request correction of inaccurate or incomplete information
Request deletion of your personal data
Request restriction of processing
Object to certain processing
Object to direct marketing
Request portability of certain personal data
Withdraw consent where we rely on consent
Raise concerns about automated decision-making where applicable
These rights are not absolute and may not apply in every circumstance.
Your Right to Object to Direct Marketing
You have the right to object to the use of your personal data for direct marketing at any time.
If you object, we will stop using your personal information for that purpose.
