1. Data Controller & UK GDPR Compliance
RevSwift Ltd is the Data Controller responsible for your personal and business data. We are fully compliant with the UK Data Protection Act 2018 and the General Data Protection Regulation (GDPR).
We process two categories of data:
- Personal Data: Founder contact details, email addresses, and account credentials
- Commercial Confidence Data: Revenue figures, marketing spend, business performance metrics, and strategic planning data
Contact: For data protection inquiries, email: privacy@revswift.com
2. Situation Analysis Data Collection
RevSwift performs a comprehensive "Situation Analysis" as part of the RevSwift Model. We collect:
- SWOT analysis data (Strengths, Weaknesses, Opportunities, Threats)
- Revenue goals and financial capacity
- Marketing budgets and historical spend
- Current technology stack and integrations
- Sales process data (lead handling, conversion rates, pipeline metrics)
- Resource constraints and team capacity
This data is used to calculate your Execution Readiness Score (ERS) and generate personalized action recommendations through our Action Priority Score (APS) system.
3. Third-Party API & System Orchestration
RevSwift acts as an aggregator, connecting to your existing marketing and sales tools through our System Orchestration layer. We may request OAuth tokens to access:
- Google Ads and Google Analytics
- Meta (Facebook/Instagram) Ads Manager
- CRM platforms (HubSpot, Salesforce, Pipedrive)
- Email marketing tools (Mailchimp, ActiveCampaign)
- Analytics platforms and attribution tools
Important: We process this data to generate insights and recommendations but do not own or control the data stored on external platforms. You retain full ownership of data in your third-party accounts.
We use read/write permissions only to:
- Pull performance metrics for analysis
- Execute approved actions (e.g., pausing underperforming campaigns)
- Update tracking parameters for attribution
4. AI Training & Feedback Loop
RevSwift uses a proprietary AI-driven Feedback Loop that learns from campaign outcomes to improve recommendations over time. The system analyzes:
- Sales conversions and revenue attribution
- Campaign performance and ROI
- Customer churn patterns
- Action effectiveness (which recommendations drove results)
Data Usage for Model Improvement: We use anonymized, aggregated performance data to train and improve the RevSwift scoring engine. Individual business data is never shared with other clients. Aggregated insights (e.g., "SMEs in retail see 34% better ROI with email sequences") help the system become more accurate for all users.
You may opt out of contributing to model training by contacting privacy@revswift.com, though this may reduce the accuracy of your recommendations.
5. Automated Decision Making & Profiling
RevSwift uses automated decision-making algorithms to:
- Calculate your Execution Readiness Score (ERS)
- Generate your Action Priority Score (APS)
- Create your "Do-Not-Do" List
- Recommend budget allocation and channel prioritization
Your Rights: Under GDPR Article 22, you have the right to:
- Request human review of automated decisions
- Challenge recommendations and provide context
- Understand the logic behind scoring decisions
If your ERS falls below the readiness threshold, certain execution features may be restricted until gaps are addressed. You can always request manual review of your score.
6. Waitlist & Referral Data
During our private beta phase, we operate a viral waitlist system that collects:
- Email addresses of waitlist participants
- Referral codes linking users to their referrers
- Waitlist position numbers (anonymized)
- Referral count for reward eligibility
Public Display: Your waitlist position is displayed only to you (e.g., "You are #2,401"). We never publicly display names alongside position numbers.
Referral Rewards: Referral data is used solely to track reward eligibility (e.g., "Free Reality Audit" at 3 referrals). Referrers cannot see the email addresses of people they referred.
7. Data Retention & Audit-Ready Logs
RevSwift maintains "Audit-Ready Performance Logs" to provide transparent ROI tracking. We retain:
- Performance Logs: 36 months (to track long-term trends and prove marketing ROI)
- Account Data: Duration of active subscription plus 12 months
- Financial Records: 7 years (UK tax compliance requirement)
- Waitlist Data: Until account activation or 24 months of inactivity
You may request deletion of your data at any time by emailing privacy@revswift.com. Note that deletion of performance logs will prevent historical ROI analysis.
8. Migration Data Handling
When migrating from previous tools, you may upload:
- CSV exports from old platforms
- Screenshots of historical performance
- Bulk contact lists
- Campaign archives
Secure Processing: Once data is ingested into RevSwift:
- Raw upload files are encrypted and stored for 30 days (for error recovery)
- After 30 days, raw files are permanently deleted
- Processed data is retained according to our standard retention policy
- You can request immediate deletion of upload files at any time
9. Your Data Rights
Under UK GDPR, you have the right to:
- Access: Request a copy of all data we hold about you
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data ("right to be forgotten")
- Portability: Receive your data in a machine-readable format
- Restriction: Limit how we process your data
- Objection: Object to automated decision-making or profiling
- Withdraw Consent: Revoke consent for data processing at any time
To exercise these rights, email: privacy@revswift.com. We will respond within 30 days.
10. Data Security
We implement industry-standard security measures:
- TLS/SSL encryption for data in transit
- AES-256 encryption for data at rest
- Multi-factor authentication (MFA) for account access
- Regular security audits and penetration testing
- Role-based access controls for internal systems
- Automated backup systems with 30-day retention
11. Cookies & Tracking
RevSwift uses cookies for:
- Essential: Session management, authentication, CSRF protection
- Analytics: Usage patterns, feature adoption, performance monitoring
- Attribution: Tracking referral sources and campaign effectiveness
You can manage cookie preferences in your browser settings. Disabling essential cookies may impact functionality.
12. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be communicated via:
- Email notification to active users
- Prominent notice on the RevSwift dashboard
- Updated "Last Modified" date at the top of this page
Continued use of RevSwift after changes constitutes acceptance of the updated policy.
13. Contact & Complaints
Data Protection Officer: privacy@revswift.com
Postal Address: RevSwift, 2nd Floor College House, 17 King Edwards Road, Ruislip, London, United Kingdom
If you are not satisfied with our response, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):
ICO: ico.org.uk
Phone: 0303 123 1113