Who we are

Marketing Commando Ltd, trading as 47 Links, is the data controller for the personal information covered by this notice.

This notice covers personal information from all 47 Links services and interactions, free or paid, including visitors, applicants, clients, business contacts, and call participants.

It applies to individuals in their own capacity and people acting for a business.

We provide any additional privacy information needed before introducing service-specific processing not described here.

Our address is 65 St. Helier Ave, Morden, SM4 6HY, United Kingdom, and our company details are 08121390, registered in England and Wales.

Our ICO registration number is ZC090489.

Contact hello@47links.com about privacy or meetings@ws.47links.com about call arrangements.

Information we use

We collect contact and role details, company registration and website information, application answers, business estimates, agreements, and communication preferences.

We also process bookings, correspondence, voice and video, screen-shared content, transcripts, AI notes, our observations, reports, and agreed next steps.

Call records may include display names, chat messages, and join/leave times, while email records may include delivery and bounce events.

Website and short-link requests may involve IP addresses, requested URLs, timestamps, and security logs.

We also store cookie preferences and evidence of marketing choices.

Information comes from you, invited colleagues, your company, our calls, and public research such as your business website, company registers, and any professional profile you provide.

Sensitive information and children

Please do not share special-category information, such as health, ethnicity, beliefs, political views, union membership, genetic data, biometric identifiers, or sex-life information.

Also avoid criminal-offense records, identity documents, payment details, passwords, access codes, and unrelated personal or customer records.

If such information appears incidentally, we restrict its use and remove or redact it unless a lawful reason requires retention.

We do not treat ordinary legitimate interests as sufficient on its own for special-category or criminal-offense processing.

Our services are for people aged 18 or older, and we do not knowingly seek children’s information.

If we learn that a child’s information was supplied, we remove it unless legally necessary to retain it, with access restricted.

Tell hello@47links.com if you believe this has happened.

Why we use it

Purpose	Lawful basis proposed for this service
Review applications, communicate with business representatives, and deliver agreed business services	Legitimate interests in assessing and providing business services
Record calls, create AI transcripts/notes, prepare recommendations, and manage agreed follow-up	Legitimate interests in accurate service records and effective delivery, subject to the recording assessment
Improve presentations and analyze recurring questions, stated reactions, implementation choices, and next-step patterns	Legitimate interests in improving service quality, using minimized information and anonymous summaries where possible
Protect systems, manage complaints, and establish or defend claims	Legitimate interests in security and protecting rights, or legal obligation where a specific duty applies
Operate the website, redirects, and essential functions	Legitimate interests in providing and securing the website
Use optional website tracking, if enabled	Consent
Send optional marketing emails	Consent, which can be withdrawn at any time
Record privacy choices and prevent unwanted marketing	Legal obligations to respect rights and demonstrate compliance, where applicable

We assess the need and effect on people before relying on legitimate interests, and you may object to those uses.

The company’s contract does not automatically provide a contractual lawful basis for its employees’ information.

If you contract with us personally, we use contractual necessity only for processing needed to take requested pre-contract steps or perform that contract.

This does not make recording, improvement analysis, or marketing automatically necessary for a contract.

Required application fields support assessment and delivery; without them, we may be unable to proceed, while marketing remains optional.

Recording and AI

Calls are recorded automatically when the host joins, with AI transcription and note-taking.

We give advance notice and require each attendee to use a web browser or mobile app to respond to the platform prompts for recording, transcription, and AI note-taking.

This includes late arrivals and replaces a routine verbal check at the start.

Silence or remaining in the call does not count as explicit consent, and our stated lawful bases remain subject to your rights.

The platform choice concerns meeting capture and does not grant blanket consent for later AI use or replace the lawful bases and rights in this notice.

If you are uncomfortable, tell us or leave the call, and we will address the concern by email and assess any material already captured.

We use relevant text with AI for research, recommendations, summaries, and the service-improvement purposes above.

We minimize inputs, remove unnecessary contact details from analysis inputs, and keep model-training sharing disabled in the AI accounts used for this work.

AI may support our review, but a person makes application decisions and reviews recommendations.

We do not use solely automated decisions producing legal or similarly significant effects.

Automation routes records and messages, while AI helps assess business fit and service patterns under human review.

We do not use this analysis to rate employee performance or infer hidden emotions or sensitive traits.

Who receives information

Access is limited to team members and service providers needed for the work.

Provider categories include hosting/forms, automation, email/calendar, video calls and AI transcription, cloud storage, private version-control hosting, AI analysis, and cookie-consent/tag-management services.

These services may process or retain information under applicable contracts and their own legal obligations.

Relevant client representatives may receive a recording of their walkthrough for internal reference, with access restricted to approved email addresses and downloads permitted.

We do not routinely share transcripts, AI notes, or internal analysis with clients; requests for personal information are assessed under applicable rights.

We may also disclose necessary information to professional advisers, insurers, or authorities where justified or required.

We do not sell personal information or publish identifiable case studies without separate permission.

If our business is transferred, necessary records may pass to a successor under appropriate safeguards and any required notices.

Security

We use access controls and reasonable technical and organizational safeguards against unauthorized access, loss, misuse, or disclosure.

We review safeguards and respond to incidents, notifying affected people or authorities when legally required.

No system can guarantee absolute security, and this does not limit your statutory rights.

International processing

Some providers may process information outside the UK, even for UK-registered clients.

Our website uses UK hosting, and our automation account uses an EU region.

Other cloud, AI, support, and service-provider processing may take place in the United States and other countries where those providers operate.

Before a restricted transfer, we require UK adequacy coverage or appropriate safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to EU standard contractual clauses.

We assess the applicable transfer route and any further protections needed.

Contact hello@47links.com for details of the applicable safeguards and how to obtain a copy.

How long we keep information

We review retention every six months and apply these actions at the next review after the threshold.

Record	Rule
Rejected applications	Anonymize once more than one year old, measured from submission
Call recordings	Delete once more than two years old, measured from the call
Transcripts, notes, and reports	Anonymize once more than two years old, measured from the call or report issue date
Accepted-client applications, research, and service records	Delete or anonymize two years after engagement closure, at the next six-month review
Incomplete applications	Delete or anonymize one year after closure, at the next six-month review
Unnecessary AI chats/uploads	Remove once reviewed outputs are saved and the working copies are no longer needed
Website backups	Daily copies normally retained for up to 28 days under the hosting provider’s published schedule
Automation logs	Detailed execution logs normally available for 30 days; webhook logs for three days
Pending automation data	Remove after processing or resolving the failed transfer; review stuck items promptly
Local backups	Hourly copies retained until overwritten; removed data may remain in older copies

The review cycle can add almost six months after a threshold, rather than deletion occurring on the anniversary itself.

We delete identifiable source material where effective anonymization is not possible, and anonymous learning may be retained.

Some information may need longer retention for a specific legal obligation or claim, with access restricted and the reason reviewed.

Marketing opt-outs stop promotional emails but do not change the separate retention rules for application or service records.

If valid marketing permission remains when those records are removed, we retain only the contact details, preferences, and consent evidence needed for marketing.

We keep a minimal do-not-contact record for as long as needed to honor an opt-out.

Every six months, we remove marketing information that is more than one year old and no longer needed.

Necessary consent evidence and do-not-contact records are not deleted solely because they pass one year.

Provider-controlled copies may remain through backup, security, or legal retention cycles; contact us for the applicable details.

We restrict retained backup use and reapply removals before restored data returns to use.

Client-downloaded recordings are separate copies controlled by the recipient and are not removed when we delete our hosted copy.

Your rights and choices

Depending on the circumstances, you can request access, correction, erasure, restriction, or portability, and object to processing based on legitimate interests.

You can object to identifiable service-improvement analysis without losing the core service; we can use genuinely anonymous learning instead.

Unsubscribe from marketing emails or contact us to withdraw consent, without affecting earlier lawful use or essential service communication.

Contact hello@47links.com to exercise your rights; requests do not need special wording or a particular form.

We may ask for proportionate proof of identity and normally respond within one month, explaining any lawful extension or refusal.

Rights requests are handled when due and do not wait for a six-month cleanup.

You may complain to the Information Commissioner’s Office, and you can contact us first if you wish.

Website technologies and external links

We keep website tracking minimal and use cookies or similar technologies for site functions and remembering privacy choices.

A tag manager controls website scripts; optional tracking is enabled only with the relevant consent.

Short links in our pages and emails redirect you to their destination, where that website’s own privacy practices apply.

Review the notices of external tools or social platforms you choose to visit, as we do not control their independent data use.

This does not remove our duties when selecting providers or sharing information with them.

Use Cookie Settings to view cookie purposes and durations, reject optional cookies, or change your choice.

You can also manage cookies in your browser, although blocking required cookies may affect site functions.

Cookie choices and marketing-email permission are separate.

Notices and changes

We send essential service and privacy messages to the contact details provided, even when marketing is declined.

Tell us if those details change, or contact us through Who we are with questions or concerns.

We show the latest update date above and give additional notice of material changes where needed.

Before using information for a new purpose, we assess the lawful basis and provide any required notice or consent request.

Continuing to use our service does not itself provide consent to new processing.