Privacy Policy
Last updated: 17 October 2026. Version: 1.2
This Privacy Policy explains how Empirintel collects, uses, and protects personal data when you visit empirintel.com, contact us, request our free HubSpot Performance Snapshot, or engage us for paid services.
We’ve tried to keep this as clear and short as possible without skipping anything material. If anything is unclear, email us at info@empirintel.com.
1. Who we are
Empirintel is a sole trader operating in England and Wales.
For the purposes of UK data protection law, we are the data controller for the personal data described in this policy.
You can contact us about anything in this policy by emailing info@empirintel.com.
2. What data we collect
We collect personal data in a few different ways depending on how you interact with us.
2.1 Data you give us directly
When you fill in a form on our website (a Snapshot request, a Health Check request or a consultation request), we collect:
- Your name
- Your work email address
- Your company name and website
- Your job role (where asked)
- Information about your HubSpot setup (tier, size, current challenges)
- Any other information you choose to include in a message
When you book a call with us, we also collect your preferred time and any context you provide.
2.2 Data we collect automatically when you visit the website
When you visit empirintel.com, we (or our service providers) may collect:
- Your IP address (which gives us approximate location)
- Browser type and version
- Operating system
- Pages you visit and how long you spend on them
- The website you came from (referrer URL)
- The campaign link you arrived through, if any (for example a link in one of our emails), so that a form you send is credited to that campaign
- Device type
Some of this is collected via cookies and similar technologies. See our Cookie Policy below for details.
2.3 Data we receive when you authorise HubSpot access
If you take up the Snapshot offer or engage us for paid services, you may give us read-only access to your HubSpot portal — either through a HubSpot Private App access token or via a screen-share session.
When we run our diagnostic scripts, we read aggregated and anonymised information from your portal — pipeline structure, workflow names, contact counts, conversion rates, configuration details. We do not download personal data of your contacts (names, email addresses, individual records) unless this is explicitly required for the service and agreed with you in writing.
The token you create is stored securely while in use and deleted within 7 days of delivering your report or service, unless you ask us to retain it for ongoing work. You can revoke the token from your HubSpot settings at any time.
2.4 Data we receive from third parties
We may receive limited business information about you or your company from:
- LinkedIn (when you connect with us or engage with our content)
- Calendar booking tools (when you book a call)
- Email service providers (delivery and open data for messages we’ve sent you)
- Enrichment data providers, where we research a prospect before reaching out (publicly available business information only)
3. How we use your data, and why we’re allowed to
UK GDPR requires us to have a lawful basis for processing your personal data. The table below sets out what we use your data for, and the basis we rely on.
| What we use it for | Lawful basis |
|---|---|
| Responding to your enquiry, sending you the Snapshot report, delivering paid services you’ve engaged us for | Contract — processing necessary to provide the service you’ve requested |
| Sending you marketing emails about our services (only if you’ve opted in or are an existing client) | Consent (for prospects) / Legitimate interest (for existing clients on closely related services) |
| Counting page views without cookies, before you make a choice in the cookie banner, and recording which campaign link brought you when you send a form | Legitimate interest — running and improving our business, balanced against your right to privacy |
| Website analytics with cookies (Google Analytics and HubSpot), to understand which pages are useful and, if you fill in a form, to link your visits to your details | Consent — these cookies only run if you accept analytics cookies |
| Reaching out to a business contact who may be interested in our services | Legitimate interest — B2B prospecting on a professional contact at their work address, with an easy unsubscribe in every message |
| Complying with legal, tax, and accounting obligations | Legal obligation |
| Defending or making legal claims | Legitimate interest |
You have the right to object to any processing we do on the basis of legitimate interest. See section 6.
4. Who we share your data with
We do not sell your data. We share it only with:
4.1 Service providers we use to run the business
- Website hosting and infrastructure: Vercel
- Email hosting: Fasthosts
- CRM, website forms, email, website analytics and the cookie banner: HubSpot (our account’s data is held in HubSpot’s EU data centre)
- Calendar booking: HubSpot Meetings
- Analytics: Google Analytics
- The cookie banner’s font: Google Fonts (see below)
- AI tooling used in service delivery: Anthropic – where we use AI to help analyse your portal or draft reports
Each of these providers is a data processor acting on our instructions. We have data processing agreements in place where required.
Google Fonts is the exception. HubSpot’s cookie banner loads its font from Google Fonts, and HubSpot offers no way to change that. So on your first visit, before you make a choice, your browser fetches the font from Google, and Google receives your IP address and basic browser details as it does for any web request.
4.2 Professional advisers
Accountants, auditors, and legal advisers, where necessary.
4.3 If we’re legally required to
Courts, tax authorities, regulators, or law enforcement where required by law.
4.4 In a sale or restructure of the business
If the business is sold, merged, or restructured, your data may transfer to the new owner — subject to the protections set out in this policy.
5. International transfers
Some of our service providers are based outside the UK (most commonly in the EU, US, or other regions). When personal data is transferred outside the UK, we ensure protection equivalent to UK GDPR — typically via:
- Transfers to countries the UK has deemed “adequate” (such as the EU and certain others)
- The UK International Data Transfer Agreement (IDTA) or the UK Addendum to EU Standard Contractual Clauses
- The UK Extension to the EU–US Data Privacy Framework (where applicable to US providers participating in the framework)
You can request a copy of the safeguards in place by emailing us.
6. Your rights
Under UK GDPR, you have the following rights:
- Access — to ask what data we hold about you and get a copy
- Rectification — to correct inaccurate data
- Erasure — to ask us to delete your data (with some exceptions, e.g. legal records we have to keep)
- Restriction — to ask us to stop using your data in particular ways
- Portability — to receive your data in a portable format
- Objection — to object to processing based on legitimate interest, including direct marketing
- Withdrawal of consent — at any time, where we’re relying on consent
To exercise any of these rights, email info@empirintel.com. We will respond within one month (occasionally extended if the request is complex — we’ll tell you if so).
You can unsubscribe from marketing emails at any time using the link at the bottom of any marketing message.
Making a complaint
If you’re not happy with how we’ve handled your data, please tell us first — we’ll do our best to put it right. We have a formal data protection complaints procedure: send your complaint to info@empirintel.com and we will acknowledge it within 30 days.
If you remain unhappy, you can complain to the UK’s data protection regulator, the Information Commission (ICO), at ico.org.uk.
7. How long we keep your data
We keep personal data only as long as we need it. Typical retention periods:
| Data | Retention |
|---|---|
| Snapshot / enquiry data, where you didn’t become a client | Up to 2 years from last contact, then deleted |
| Client engagement records and correspondence | 7 years after the end of the engagement (tax/legal requirement) |
| HubSpot access tokens | Deleted within 7 days of service completion |
| Diagnostic data extracted from your HubSpot portal | Deleted within 30 days of service completion, unless we agree otherwise |
| Marketing email subscribers (active) | Until you unsubscribe |
| Marketing email subscribers (unsubscribed) | We keep your email on a suppression list indefinitely to honour your unsubscribe |
| Website analytics | Aggregated; individual session data retained per the provider’s settings (typically 14 months for Google Analytics) |
8. Security
We take reasonable steps to protect your data, including encryption in transit (HTTPS), encrypted storage of access credentials, access controls, and limiting who can see what. No system is perfectly secure — but we take it seriously, and if we ever have a breach affecting your rights we will notify the ICO within 72 hours and, where required, notify you.
9. Children
Our services are aimed at businesses. We do not knowingly collect data from anyone under 18. If you believe we have, please contact us and we will delete it.
10. Changes to this policy
We may update this policy from time to time. Material changes will be flagged at the top of this page. The “Last updated” date at the top tells you when the most recent change was made.
Cookie Policy
Last updated: 17 October 2026
This Cookie Policy is part of the Empirintel Privacy Policy. It explains the cookies and similar “storage and access technologies” we use on empirintel.com, why we use them, and how you can control them.
1. What are cookies (and what we mean by them)
A cookie is a small text file a website places on your device. The UK regulator (the ICO) now uses the broader term “storage and access technologies” — covering not just cookies but also pixels, local storage, fingerprinting, and similar techniques. We follow that broader definition in this policy.
For simplicity, we’ll just say “cookies” below.
2. The cookies we use
We group cookies into four categories. Some always run. Others only run if you give consent.
2.1 Strictly necessary cookies
These are essential to make the website work, deliver what you’ve actively requested (e.g. submitting a form), or maintain security. These don’t require your consent and you can’t turn them off.
On our site, the only one is the cookie that remembers your cookie choices.
2.2 Analytics cookies (limited statistical purposes)
We use analytics to understand which pages are useful and where people get stuck. Under the UK’s Data (Use and Access) Act 2025 (in force from 5 February 2026), some first-party analytics may not require explicit consent if they are used solely for aggregated statistical purposes and don’t share data with third parties.
We use Google Analytics 4. It only runs if you accept analytics cookies, and we have configured it to:
- Not share data with Google for other purposes
- Not store IP addresses
We also use HubSpot’s analytics, and a cookie set by our own site tag that remembers which campaign link brought you to the site, for the rest of that visit only. Both also run only with your consent. If you accept and later fill in a form, HubSpot links the pages you visited to your details. Before you make a choice in the banner, HubSpot still counts each page view, but without setting or reading any cookies.
2.3 Functional cookies
These remember choices you make on a site, such as a language or a log-in. We don’t currently set any functional cookies. If we add any, we will list them below and ask for your consent first.
2.4 Marketing and tracking cookies
These help us understand which marketing activities generate enquiries, retarget you with relevant content, or measure ad performance. These always require consent.
We don’t currently set any marketing cookies. If we add any, we will list them below and ask for your consent first.
3. Detailed cookie list
The table below lists the specific cookies on empirintel.com.
| Cookie name | Provider | Purpose | Category | Duration |
|---|---|---|---|---|
| __hs_cookie_cat_pref | empirintel.com | Stores cookie consent choices | Strictly necessary | 6 months |
| _ga | Google Analytics 4 | Aggregate analytics — page views, session length | Analytics | 90 days |
| _ga_[ID] | Google Analytics 4 | Keeps track of the current session | Analytics | 90 days |
| __hstc | HubSpot | Visit tracking and lead attribution | Analytics | 6 months |
| hubspotutk | HubSpot | Recognises you when you submit a form, so your record isn’t duplicated | Analytics | 6 months |
| __hssc | HubSpot | Tracks the current session | Analytics | 30 minutes |
| __hssrc | HubSpot | Detects whether the browser has been restarted | Analytics | End of session |
| emp_utm | empirintel.com | Remembers the campaign link you arrived through, so a form you submit during the same visit is credited to that campaign | Analytics | When you close the browser, or after 30 minutes without a page view |
4. How to control cookies
On our site
When you first visit empirintel.com, you’ll see a cookie banner. You can accept or decline non-essential cookies, or choose category by category. Until you choose, no non-essential cookies are set.
You can change your choice at any time by clicking “Cookie settings” in the footer of any page.
In your browser
Every modern browser lets you block or delete cookies. Be aware that blocking strictly necessary cookies will break parts of the site.
Global Privacy Control (GPC)
If your browser sends a Global Privacy Control signal, we treat it as a refusal of non-essential cookies: the banner tells you so, and we don’t set them.
5. Changes to this Cookie Policy
We update this Cookie Policy whenever we add, remove, or change the cookies on our site. The “Last updated” date tells you when. We’ll also re-prompt for consent if material new cookies are added.
If you have any questions about cookies on our site, email info@empirintel.com.