Privacy

Privacy Policy

Last Updated: 28 November 2025

Swestun ("we", "us", or "our") is committed to protecting and respecting your privacy. This policy explains how we collect, process, and protect personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. WHO WE ARE

Swestun is a B2B client acquisition and infrastructure agency.
Controller: Luke Swestun
Email: legal@swestun.com
Website: swestun.com

2. THE DATA WE COLLECT

We collect data in two primary categories:

A. Client Data (Information about You)
If you hire us or book a strategy call, we collect:

  • Identity Data (Name, Job Title).

  • Contact Data (Email address, Phone number).

  • Financial Data (Billing address, Payment details via Stripe).

  • Transaction Data (Details of services purchased).

B. Prospect Data (B2B Lead Generation)
As part of our Services, we aggregate publicly available business data to help our clients identify potential business partners. This includes:

  • Name, Job Title, Company Name.

  • Corporate Email Address.

  • LinkedIn Profile URL.

  • Company Firmographics (Revenue, Location, Industry).

Note: We do not collect "Special Category" data (race, religion, health, etc.) for prospecting purposes.

3. HOW WE USE YOUR DATA (LEGAL BASIS)

We only use personal data when the law allows us to.

For Clients:

  • Purpose: To deliver our services, process payments, and manage our relationship.

  • Legal Basis: Performance of a Contract.

For Prospecting (Cold Outreach):

  • Purpose: To identify and contact B2B decision-makers who may benefit from our services or our clients' services.

  • Legal Basis: Legitimate Interest.

  • Explanation: We rely on "Legitimate Interest" (PECR Regulation 22) to conduct B2B marketing. We ensure our outreach is relevant to the recipient's professional role and offer an easy opt-out (unsubscribe) mechanism in every communication.

4. DISCLOSURE OF YOUR DATA

We may share your data with trusted third-party service providers who act as "Data Processors" to help us run our business:

  • Infrastructure: Google Workspace (Email & Cloud Storage).

  • Lead Intelligence: Apollo.io (Data sourcing).

  • Outreach Tools: Instantly.ai (Email sending).

  • Payments: Stripe (Payment processing).

  • Analytics: Google Analytics (Website usage).

We require all third parties to respect the security of your data and to treat it in accordance with the law.

5. INTERNATIONAL TRANSFERS

Some of our external third parties (e.g., Apollo, Stripe) are based outside the UK/EEA (specifically in the USA). Whenever we transfer your data out of the UK, we ensure a similar degree of protection is afforded to it by using specific contracts approved by the UK Information Commissioner’s Office (ICO) or ensuring the provider is part of the UK-US Data Bridge.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. Access to client data is limited to Swestun personnel who have a business need to know.

7. DATA RETENTION

Clients: We retain your data for as long as you are an active client and for 6 years thereafter for tax/legal purposes.
Prospects: We retain B2B contact data only for as long as it is accurate and relevant. If you opt-out or unsubscribe, we retain your email address on a "Suppression List" to ensure we do not contact you again.

8. YOUR LEGAL RIGHTS

Under the UK GDPR, you have the right to:

  • Request access to your personal data (Subject Access Request).

  • Request correction of your data.

  • Request erasure of your data ("Right to be forgotten").

  • Object to processing (specifically for direct marketing).

  • Request restriction of processing.

To exercise any of these rights, please email us at legal@swestun.com. We aim to respond to all legitimate requests within one month.

9. COOKIES

Our website uses cookies to distinguish you from other users. This helps us provide you with a good experience and allows us to improve our site. You can set your browser to refuse all or some browser cookies.

10. THIRD-PARTY LINKS

Our website may include links to third-party websites (e.g., LinkedIn, Twitter). Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

Questions?
If you have any questions about this privacy policy, please contact Luke Swestun at legal@swestun.com.

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