Privacy Policy

Last updated: 13 July 2026 . Holtwood Holdings Ltd trading as ownered.ai

ownered.ai is operated by Holtwood Holdings Ltd, a company registered in England and Wales. We take the privacy of our users seriously. This policy explains what data we collect, how we use it, and your rights under UK GDPR and the Data Protection Act 2018.

1. Who We Are

Data Controller: Holtwood Holdings Ltd
Trading as: ownered.ai
Registered in England and Wales
Contact: support@ownered.ai

2. What Data We Collect

We collect the following categories of data when you use our platform:

• Account data: your name, email address, and subscription plan when you register
• Usage data: campaigns created, targets saved, activity logs, and feature usage
• Payment data: processed securely via Stripe - we do not store card details directly
• Sender & outreach details: your sending email address and display name for email campaigns, and the sender details you provide for postal letters — name, job title, company name, postal address, phone number, contact email, and an optional signature image
• Target data: business contact information sourced from Companies House or enrichment services on your behalf
• Communications: support messages sent via our in-app assistant

3. How We Use Your Data

• To provide and operate the ownered.ai platform
• To process subscription payments via Stripe
• To send transactional emails (account confirmations, billing, product updates)
• To power the AI assistants (queries are processed by our platform AI infrastructure). Conversations with the Ownered Analyst and with in-app support are retained in your account so you can return to them and so we can provide continued assistance; you can request their deletion at any time (see Section 8)
• To improve the platform through aggregated, anonymised usage analytics
• To comply with legal obligations

4. Legal Basis for Processing

We process your data under the following legal bases:

• Contract: to deliver the service you have subscribed to
• Legitimate interests: to improve our product and prevent misuse
• Legal obligation: to comply with UK law (e.g. tax, fraud prevention)
• Consent: for marketing communications where applicable (you can opt out at any time)

5. Third-Party Services

We use the following third-party processors to operate the platform. Each processes personal data only as necessary to deliver the specific service described:

• Payment processing provider - secure processing of subscription payments and billing
• AI processing provider - AI assistant functionality, accessed via our platform infrastructure provider
• Email delivery provider - transactional and campaign email delivery

All third-party processors are contractually required to handle your data in accordance with UK GDPR.

6. Companies House Data

This section covers personal data retrieved from public sources on your behalf, rather than data you provide directly to ownered.ai. PSC records contain personal information about individuals such as directors and shareholders. We set out below how this data is sourced, handled, and governed.

ownered.ai makes available company registration information and People with Significant Control (PSC) records sourced from Companies House. This is publicly available information published by Companies House, an executive agency of the Department for Business and Trade, under the Open Government Licence v3.0.

This data is made available to power searches within the platform. Records are held internally and refreshed periodically from the public register. We do not sell, licence, or redistribute Companies House data. Our use is governed by the Companies House terms of use and the Open Government Licence v3.0.

7. Data Retention

We retain your account data for as long as your subscription is active, plus 6 years for accounting and legal purposes. Companies House register data is held internally and refreshed periodically from the public register. You may request deletion of your personal data at any time by contacting us - we will action requests within 30 days.

8. Your Rights

Under UK GDPR you have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your data (right to be forgotten)
• Restrict or object to processing
• Data portability (receive your data in a machine-readable format)
• Lodge a complaint with the ICO at ico.org.uk

To exercise any of these rights, email us at support@ownered.ai

9. Cookies

We use essential cookies only - required for authentication and session management. We do not use tracking or advertising cookies. No cookie consent banner is required for essential-only cookies.

10. Security

All data is transmitted over HTTPS (TLS encryption). API keys and sensitive credentials are encrypted at rest. We review our security practices regularly and are pursuing Cyber Essentials certification.

11. Changes to This Policy

We may update this policy from time to time. We will notify active subscribers of material changes via email. The latest version is always available at this URL.

12. Contact Us

If you have any questions about this policy or how we handle your data, please contact us at support@ownered.ai.