{ "title": "Privacy Policy", "version": "uhnwi-data-privacy-2026-10-20", "effectiveDate": "2026-10-20", "modifiedDate": "2026-10-20", "language": "en", "scopeNotice": "This Policy covers UHNWI Data products, research and customer services. It distinguishes shared research from private customer information and optional analytics.", "sections": [ { "heading": "1. Who We Are and Scope", "id": "section-1", "scope": "general", "blocks": [ { "type": "paragraph", "text": "UHNWI Data is responsible for the independent research database, Data websites, customer services and processing described in this Policy. Our legal notice address is UHNWI Data, 55 Broadway, New York, NY 10006, United States. Privacy enquiries and rights requests: privacy@uhnwidata.com. Legal correspondence: legal@uhnwidata.com." }, { "type": "paragraph", "text": "This Policy covers website visitors, customer representatives, people whose information is researched, customer-supplied contacts and service correspondents. It applies to database development, licensed research access, wealth intelligence, UHNWI Network and other Data functions actually supplied. It does not describe a purchase of the separate UHNWI Direct correspondence service." }, { "type": "paragraph", "text": "We use shared UHNWI identity, profile, billing and contact-matching infrastructure, including authenticated services hosted on UHNWI Direct. Only information needed for the requested function is exchanged. Using shared infrastructure does not authorise use of a customer’s private contact data for another customer or for shared research." }, { "type": "paragraph", "text": "This is a privacy notice, not blanket consent or a waiver. Accepting Terms of Service, placing an order, or appearing in a public source does not authorise every use of personal information. Where we process data solely on a customer’s documented instructions, applicable data-processing terms govern that activity." } ] }, { "heading": "2. Visitors, Accounts, Orders and Payments", "id": "section-2", "scope": "general", "blocks": [ { "type": "paragraph", "text": "We process information you provide for an account, enquiry or purchase: name, verified email, company and role, available profile and billing details, country and phone information, service choices, research briefs, selected people, requested quantities, matching decisions, saved drafts, support messages and attachments. Country codes used for telephone formatting do not establish residence." }, { "type": "paragraph", "text": "Email verification and, where enabled, Google sign-in establish identity. Google sign-in and Google Contacts access are separate permissions. We exchange the identity and profile information needed to keep your shared UHNWI account current; account access to one service is not permission to inspect another customer’s records." }, { "type": "paragraph", "text": "Project records can include accepted terms and acknowledgements, order references, research start and cancellation deadline, private service notifications, delivery scope, confirmations, correction reports, payment and refund status, and audit timestamps. These records administer the service and support payment or dispute review; a sent notification does not prove it was read." }, { "type": "paragraph", "text": "Stripe handles payment-card entry through its payment interfaces. We retain transaction amounts, billing information, payment/refund status and provider references needed for administration and reconciliation. Our application does not store full card numbers or card security codes." }, { "type": "paragraph", "text": "Sessions, request metadata, timestamps, error and security records support operation and abuse prevention. Hosting infrastructure may process IP addresses. Optional website analytics is separate and is described in Section 15." } ] }, { "heading": "3. Research Information and Sources", "id": "section-3", "scope": "general", "blocks": [ { "type": "paragraph", "text": "Research may include names, estimated wealth, age or birth information, country and residence context, business roles, education, professional associations, interests, company affiliations, assets, ownership, relevant family or professional relationships, and sources or analytical notes. Company records may identify directors, owners, employees and beneficial owners. Operational research may also hold email, telephone or professional-profile information where relevant and lawful." }, { "type": "paragraph", "text": "We assess sources such as official biographies, company publications, corporate and regulatory filings, professional profiles, reputable reporting, lawfully received correspondence and substantiated corrections. Public availability does not remove obligations concerning purpose, proportionality, accuracy, transparency or individual rights. We distinguish sourced facts, estimates, assessments and unassessed information." }, { "type": "paragraph", "text": "Family context can include information about relatives, including minors. It must be limited to a relevant, lawful research purpose, assessed for necessity and handled with appropriate safeguards. We do not offer the service to children. A family relationship in research does not make a child a customer or an appropriate marketing target." }, { "type": "paragraph", "text": "Where research contains criminal allegations, convictions or other legally restricted or sensitive information, an applicable specific legal condition and safeguards are required. An allegation must not be represented as a conviction. Public reporting and this notice alone do not establish the required authority. Wealth or relationship assessments are not certified financial, legal, creditworthiness or ownership findings." } ] }, { "heading": "4. Purposes and Legal Grounds", "id": "section-4", "scope": "general", "blocks": [ { "type": "paragraph", "text": "We use customer and project information to provide the requested research and access, authenticate users, manage scope and licensing, take payments, process eligible cancellations and refunds, respond to enquiries, correct errors and preserve accepted instructions. Necessary processing for an individual contracting customer may rely on contract; administration involving a business customer’s representatives may rely on legitimate interests in that business relationship." }, { "type": "paragraph", "text": "Independent research and database maintenance may rely on legitimate interests in supplying relevant business research and intelligence, where those interests are not overridden by the individual’s rights, expectations and circumstances. We consider necessity, proportionality and safeguards. The same assessment applies to security, fraud prevention and relevant service improvement; legitimate interests are not a universal permission to collect, disclose or contact anyone." }, { "type": "paragraph", "text": "Applicable legal obligations support required accounting, tax, disclosures and regulatory compliance. Where consent is required, including for optional analytics or particular marketing, it must precede the activity and can be withdrawn for the future. Restricted categories require any additional legal condition. An interface default or a saved preference alone does not establish lawful consent." }, { "type": "paragraph", "text": "Customers remain responsible for the lawful basis, notices and permissions for information they supply and their subsequent use of results. A corporate email address can still identify a person. Purchasing research does not supply a blanket permission for downstream contact or marketing." } ] }, { "heading": "5. Customer Views and Shared Network Research", "id": "section-5", "scope": "general", "blocks": [ { "type": "paragraph", "text": "Customers receive only the research, profiles, relationships, reports or licensed views included in their order, subject to verified access and delivery conditions. Public examples and aggregate availability are distinct from a private customer result. Buying access does not grant unrestricted access to the underlying database or private administrative records." }, { "type": "paragraph", "text": "For UHNWI Network, one canonical Network can support independent orders for the same central person. A customer receives a scoped, read-only result within the ordered Network Size. Smaller results prioritise stronger documented connected paths; unassessed strength is not treated as zero. Shared research can be updated or reused without increasing another customer’s entitlement or disclosing that customer’s private information." }, { "type": "paragraph", "text": "Cancelling or refunding one order stops that order and its access; it does not automatically delete or freeze the canonical Network or other orders. This contractual separation does not override an individual’s applicable correction, objection, restriction or erasure rights. Research ownership is not ownership of a person’s personal data." }, { "type": "paragraph", "text": "Private customer imports, matching annotations, order history, billing information, messages and account identifiers are not disclosed to other customers. Availability of a research field, export or integration follows the purchased service and access controls; no general right to download operational contact information is created by this Policy." } ] }, { "heading": "6. Projects, Support and Service Notifications", "id": "section-6", "scope": "general", "blocks": [ { "type": "paragraph", "text": "We store project messages, support enquiries, correction reports and authorised attachments to administer the requested service. Authorised staff can review relevant information to perform work, resolve a problem and maintain a service history. Messages and attachments should contain only information necessary for that purpose." }, { "type": "paragraph", "text": "For Network, the project-manager creation or attachment records that order’s research start and cancellation deadline. The private project notice explains the start, deadline and cancellation right. Eligible cancellation and provider-confirmed refund records are retained separately from the shared research. These are essential service records, not marketing consent." }, { "type": "paragraph", "text": "Account, security, invoice, payment and project communications may use the account and associated email where the relevant function supports it. In-app notices and email are distinct channels; this Policy does not promise an email for every project event." } ] }, { "heading": "7. Marketing and Optional Updates", "id": "section-7", "scope": "general", "blocks": [ { "type": "paragraph", "text": "Marketing and Database updates are optional subscription categories, separate from essential account, security, payment and service messages. Manage available topics in Profile & settings → Notifications or through an email preference link. An interface default does not replace consent or another legal permission required before sending." }, { "type": "paragraph", "text": "Where enabled, Resend supplies application email and newsletter delivery and receives the relevant address, available name and subscription information. Provider-configured delivery or engagement reports depend on that function. Unsubscribe preferences and minimal suppression information help honour objections. Rejecting browser analytics does not itself unsubscribe an email address." } ] }, { "heading": "8. Private Contact Imports and Matching", "id": "section-8", "scope": "general", "blocks": [ { "type": "paragraph", "text": "Eligible services may let you upload CSV, TSV or XLSX contacts or connect supported providers, including Google Contacts, Outlook / Microsoft 365 and available CRM services. Use only data you are authorised to supply and provide required notices or permissions. Provider availability and matching choices depend on the service and your order." }, { "type": "paragraph", "text": "The import workflow lets you review mapped identity fields and validation before confirming saved data. Supported values can include names, email addresses, telephone, country, birth information, job title and company. Skipped columns are not submitted. Connected imports read supported contacts and relevant connection metadata; contact import does not read Gmail or Outlook messages." }, { "type": "paragraph", "text": "The shared matching infrastructure processes imports and provider connections on authenticated UHNWI services. Credentials needed to maintain a connection are encrypted on the server, not placed in a browser preference. Some provider permission grants are broader than the implemented contact-read operation; the provider consent screen states the actual grant. The implemented import does not modify external CRM records or send the shared research database to the connected provider." }, { "type": "paragraph", "text": "Saved imports and matching annotations are private to the customer. They are used for identity comparison and the chosen service: database-development exclusions and Network known-contact comparison are different functions. Network matching does not remove people from research, increase the fee or promise an introduction. A name-only resemblance or conflicting identity requires review before it is treated as confirmed." }, { "type": "paragraph", "text": "Private contact data is not reused to enrich shared research, supply another customer’s result, create a separate marketing list or train general-purpose AI models. Our use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including Limited Use requirements. Authorised human access or transfers remain subject to applicable provider restrictions." }, { "type": "paragraph", "text": "Use available matching controls to delete saved uploads, manage applicable exclusions or disconnect a service, or request assistance. Disconnecting stops further reads and removes active connection credentials; it does not by itself delete previously saved uploads. Deleting one upload need not remove information independently retained in another authorised upload. Completed account closure and retained support copies require the applicable deletion process. Minimal audit records do not need to copy uploaded values." } ] }, { "heading": "9. Providers and International Processing", "id": "section-9", "scope": "general", "blocks": [ { "type": "paragraph", "text": "Information is available to authorised personnel and providers only as needed for the relevant service. These include Cloudflare for hosting, database and file infrastructure, Stripe for payments, Resend for email, shared UHNWI identity and contact-matching services, and external providers you choose to connect. Google processes optional analytics as described in Section 15. Professional advisers, competent authorities and payment-dispute recipients may receive information where necessary and lawful." }, { "type": "paragraph", "text": "A customer receives its purchased research result and its own service history; another customer does not receive private account, contact-matching, billing or message records. We do not sell customer-supplied contact lists. Whether research access constitutes a sale, sharing or another regulated disclosure depends on actual processing and applicable law; a service label or contract is not a blanket exemption. Contact our privacy team about applicable opt-out rights." }, { "type": "paragraph", "text": "Providers and authorised personnel may process data in the United States or elsewhere outside the individual’s country. Where applicable law requires a transfer mechanism, appropriate safeguards must cover the relevant processing, such as an adequacy decision or approved contractual clauses with necessary supplementary measures. Contact privacy@uhnwidata.com for information relevant to your data." }, { "type": "paragraph", "text": "Necessary disclosures can support valid legal process, abuse investigation, security incidents or a business reorganisation under confidentiality and applicable safeguards. Connected-provider restrictions continue to apply." } ] }, { "heading": "10. Retention, Cancellation and Account Closure", "id": "section-10", "scope": "general", "blocks": [ { "type": "paragraph", "text": "Retention follows the category and stated purpose rather than a promise that every record is deleted at once. Customer, project and service records support ongoing access and support. Accepted contracts, start and deadline evidence, notices, invoices, payments, cancellations, refunds and disputes may remain for applicable accounting, legal and claims requirements or a legal hold, with restricted use after the operational purpose ends." }, { "type": "paragraph", "text": "Shared research is maintained independently of a customer’s order. Order cancellation and a full refund do not by themselves require deletion of lawful underlying research. We assess continued relevance, accuracy, necessity and individual rights; proprietary status does not exempt research from applicable privacy law. Minimal suppression information may be retained to honour an objection and avoid reintroduction." }, { "type": "paragraph", "text": "Saved uploads and connector credentials follow the controls in Section 8. Browser storage lifetimes are in the Cookie Policy. Server-side drafts, research records and accepted order evidence are not removed merely by clearing cookies. Expiry of a session does not simultaneously erase all security and audit records." }, { "type": "paragraph", "text": "Account closure may require resolution of active services or assistance from the project team. Restricting access is distinct from erasing records. Request closure or a retention explanation through available account support or privacy@uhnwidata.com. Lawfully retained transaction history, audit evidence, downloaded support copies and backup copies follow their relevant retention and deletion process. We do not promise a single deletion deadline across all record categories." } ] }, { "heading": "11. Security", "id": "section-11", "scope": "general", "blocks": [ { "type": "paragraph", "text": "Safeguards include authenticated and role-based access, customer ownership checks, server-side validation, protected sessions, encrypted connector credentials and relevant audit records. Customer-visible results are scoped to authorised access. Downloaded support or operational files require restricted handling." }, { "type": "paragraph", "text": "No system or access restriction can prevent every unauthorised capture or disclosure. We assess incidents and provide notifications where applicable law requires them. Protect your account and devices, avoid confidential drafts on shared browsers and report suspected compromise promptly." } ] }, { "heading": "12. Your Choices and Privacy Rights", "id": "section-12", "scope": "general", "blocks": [ { "type": "paragraph", "text": "You can manage available account information, optional subscriptions, contacts and connections, Cookie Preferences and service settings through the relevant controls. For requests concerning researched information, copies outside those controls or account closure assistance, contact privacy@uhnwidata.com." }, { "type": "paragraph", "text": "Depending on applicable law, you may have rights of access, correction, erasure, restriction, eligible portability, objection, withdrawal of consent, opt-out of sale, sharing or certain profiling, and complaint to a supervisory authority. We do not penalise a protected exercise of privacy rights. Research subjects need not become customers or accept our customer arbitration terms to make a privacy request." }, { "type": "paragraph", "text": "An objection to direct marketing stops the relevant use; a minimal suppression record may remain. Other legitimate-interest objections are assessed under the applicable legal test. Withdrawal of consent affects future processing based on that consent, not processing with an independent lawful basis or earlier lawful activity." }, { "type": "paragraph", "text": "We may request proportionate identity or authority information and details needed to locate a record. We respond within applicable statutory deadlines and explain any lawful extension, limitation, refusal and complaint route. Requests are ordinarily free except where law permits otherwise. Any restriction must consider other people’s rights, security, privilege and legally required retention; proprietary research is not a blanket exception." } ] }, { "heading": "13. Selection, Matching and Automated Processing", "id": "section-13", "scope": "general", "blocks": [ { "type": "paragraph", "text": "Software supports research filters, counts, identity comparison, duplicate checks, licence scopes and connected Network selection. Network scope can rank documented paths by assessed relationship strength, interaction frequency and distance; it does not prove closeness, reciprocal trust, endorsement or influence. Uncertain identity matches and research assessments can require human review." }, { "type": "paragraph", "text": "These functions support research and customer service, not decisions about eligibility for employment, housing, credit, insurance or similar significant outcomes. The service is not designed to make solely automated decisions producing legal or similarly significant effects. Report a suspected incorrect match, relationship or assessment for review and correction." } ] }, { "heading": "14. Children and Restricted Information", "id": "section-14", "scope": "general", "blocks": [ { "type": "paragraph", "text": "The service is intended for adult business and professional users. Children must not register or purchase services. Limited family research context is different from providing a service to a child and remains subject to necessity, safeguards and applicable rights." }, { "type": "paragraph", "text": "Do not upload unnecessary information about children, health, criminal allegations or other sensitive matters. Contact our privacy team if inappropriate information has been supplied or researched. A commercial order or general legitimate-interest statement does not supply an additional legal condition required for restricted categories." } ] }, { "heading": "15. Cookies and Optional Analytics", "id": "section-15", "scope": "general", "blocks": [ { "type": "paragraph", "text": "The Cookie Policy lists Data authentication cookies, privacy preferences, temporary message and Network draft recovery, and optional analytics storage. Server-side projects and imports are distinct from browser storage. Optional analytics is off until an affirmative valid choice. The Data controls honour Global Privacy Control and Do Not Track by keeping analytics off." }, { "type": "paragraph", "text": "With consent, first-party analytics measures public visits and acquisition sources and can link a visit to registration, an enquiry and an order. Our internal attribution records can connect an account or order reference to the source; they are pseudonymous records, not a promise of irreversible anonymity. The website does not load analytics on account, administrator, API, checkout or legal pages. Essential security and payment processing are separate." }, { "type": "paragraph", "text": "Where enabled on production, Google Analytics receives public page paths and titles, referring website origins, acquisition-source classification, random analytics identifiers and ordinary browser/device information. Public action events include opening database development and a successful enquiry. Consent-linked server events can also describe eligible order creation, payments and refunds, using a random transaction reference, payment type, amount and currency. Internal account, order and licence numbers, names, email, research briefs, uploaded contacts, form contents and URL query parameters are not sent to Google." }, { "type": "paragraph", "text": "Advertising features and Google signals are disabled. The implementation configures consent, limits events and excludes private pages; external provider settings can affect their own processing. Google processing can involve international transfers. Server analytics event delivery additionally depends on integration and deployment configuration; a description of a supported event is not a guarantee that every product emits it." }, { "type": "paragraph", "text": "Use Cookie Preferences to withdraw consent. This clears applicable analytics cookies on this origin, stops collection and disables pending consent-linked server events when the withdrawal reaches the service. It does not automatically erase events already received by Google or accounting records needed independently for your purchase. Consent expires after 180 days; clearing this browser does not revoke choices on another device." } ] }, { "heading": "16. Updates and Contact", "id": "section-16", "scope": "general", "blocks": [ { "type": "paragraph", "text": "The version and dates identify this notice. We update it when Data products or processing change and give additional notice or obtain consent where required. Continued use alone is not blanket consent to a new purpose." }, { "type": "paragraph", "text": "Privacy enquiries, corrections, objections and rights requests: privacy@uhnwidata.com. UHNWI Data, 55 Broadway, New York, NY 10006, United States. Legal correspondence: legal@uhnwidata.com. Read this Policy together with the Cookie Policy and the Terms of Service for your purchased Data product." } ] } ], "slug": "privacy-policy", "url": "https://uhnwidata.com/privacy.html", "description": "How UHNWI Data handles research, customer projects, private contact matching, payments, privacy rights and optional analytics.", "audienceType": "Website visitors, customers, customer contacts and research subjects" }