1. About this policy
This policy explains how your personal data is collected and used when you visit www.46dc.com or www.dineshkoyyalamudi.com, contact me, subscribe to my newsletter, or book and buy 46DC consulting. It is written for everyone, wherever you live, and includes extra information for people in India in section 14.
2. Who is responsible for your data
There are two data controllers, depending on what you do:
- The websites, enquiries and the newsletter: Dinesh Koyyalamudi (“I”, “me”), 66 Paul Street, London EC2A 4NA, United Kingdom. ICO registration ZC243765.
- Consulting bookings, payments and client work: FourSix46 Global Ltd (“we”, “us”), company number 16712658, 66 Paul Street, London EC2A 4NA, United Kingdom. ICO registration ZC052022.
In sections 5 to 14, “we” means whichever of us is the controller for your data. For any privacy question or request to either controller, email dinesh@46dc.com.
3. When you book or buy consulting
FourSix46 Global Ltd is the controller for everything in this section.
What we collect
- Your name, email address and, if you give them, your company, website or social profile, country and time zone.
- Your answers to the booking questions, such as what you need help with and whether you are buying as a business.
- Booking details: the service, date, time, video link, reschedules and cancellations, and a record of the terms you agreed to and when.
- Payment records: amount, currency, date, and the card type and last four digits. Your full card details are handled by Stripe and never reach us.
- Emails, proposals, invoices, call notes and project files that you share with us or that we create for you. If we agree to record a call, the recording.
Most of this comes from you. Booking and payment details also reach us from Cal.com and Stripe when you book.
Why we use it, and our legal basis
- To take and manage your booking, run the calls and deliver the work: performance of a contract with you (or, if you book for a business, our legitimate interest in serving our client).
- To send booking confirmations and reminders: performance of a contract.
- To take payment, issue invoices and keep accounting and tax records: performance of a contract and legal obligation.
- To keep a record that you agreed to our terms and, if you are a consumer, that you asked us to start within the 14-day cancellation period: legal obligation and our legitimate interest in being able to show it.
- To handle complaints, refunds and legal claims: legitimate interests and legal obligation.
- To publish a case study or testimonial that names you: only with your consent, which you can withdraw at any time for the future.
You need to give us your name, email and payment to book. Without them we cannot take the booking.
Who processes it for us
- Cal.com: scheduling, the booking calendar on 46dc.com, booking forms, confirmation and reminder emails.
- Stripe: card payments and refunds.
- Google (Workspace, Calendar and Meet): calendar invites, video calls, email and file storage.
- Google Firebase: the website database, where a copy of each booking record is kept so we can manage bookings.
How long we keep it
- Accounting and payment records: 6 years from the end of the financial year they relate to, as UK company and tax law requires.
- Booking answers, call notes and project files: 2 years after the work ends, unless you ask us to delete them sooner or we agree otherwise.
- Call recordings, if any: deleted when the work ends unless you ask us to keep them.
- Records of the terms you agreed to: 6 years after the contract ends, in case of a dispute.
- Bookings that did not go ahead: 12 months.
Data you give us about other people
If our work gives us access to personal data you control, such as your website visitors in your analytics, we handle it only on your behalf as your processor, as set out in section 17 of the Consulting Terms.
4. When you visit the websites, contact me or subscribe
I am the controller for this section.
What I collect
- Contact form: your name, email address, enquiry type, subject and message.
- Newsletter: your first name and email address, and a record of your consent: when you signed up, the wording you agreed to, when you confirmed by email, where you signed up, and when you unsubscribed.
- Newsletter engagement: whether emails are opened and which links are clicked.
- Analytics (only if you accept analytics cookies): pages visited, how you arrived, time on page, approximate location (country and city), and device and browser type. See the Cookie Policy.
- Security and hosting logs: IP address, browser and time of request, kept by the hosting provider to run and protect the websites.
Why I use it, and my legal basis
- To reply to enquiries and manage speaking, media and collaboration requests: legitimate interests (being able to answer the people who contact me), or steps before a contract if you are asking about working together.
- To send the newsletter and understand which content is useful: consent.
- To understand how the websites are used: consent, given through the cookie banner.
- To keep the websites secure and prevent misuse: legitimate interests (protecting the websites and their visitors).
- To keep records of consent and comply with the law: legal obligation.
Who processes it for me
- Google Firebase: website hosting and the website database, which stores contact form messages and newsletter sign-ups.
- Google Workspace: email, where enquiries are also delivered.
- Brevo: newsletter sending and consent records.
- Google Analytics: website statistics, only with your consent.
- CookieYes: the cookie banner, which stores your cookie choice.
How long I keep it
- Contact enquiries: 12 months after the last message, unless they lead to ongoing work.
- Newsletter data: until you unsubscribe. After that, I keep your email address on a suppression list for as long as I send the newsletter, so you are not added again by mistake, and keep your consent record for 2 years.
- Analytics data: up to 14 months, then deleted automatically by Google Analytics.
- Hosting and security logs: up to 30 days.
5. What I do not do
- I do not sell personal data or share it for advertising.
- I do not make decisions about you using only automated means.
- I only collect what is needed for the purposes above.
6. Sharing
Stripe also uses payment data as an independent controller to prevent fraud and meet its own legal duties, and YouTube is responsible for data it collects when you play a video. Otherwise, personal data is shared only with the service providers named above, who act as processors under contracts that require them to protect it and use it only on our instructions, and with professional advisers, authorities or courts where the law requires it or to protect our legal rights. If FourSix46 Global Ltd’s business is sold or reorganised, client records may pass to the new owner under the same protections.
7. International transfers
Some of the providers above, including Google, Cal.com, Stripe and CookieYes, process data outside the UK, including in the United States and the European Union. Where data is sent to a country without a UK adequacy decision, the provider relies on a safeguard recognised under UK law, such as the UK International Data Transfer Addendum or the UK–US data bridge. You can ask us for details.
8. Security
We use HTTPS encryption, access controls, restricted access to admin systems and reputable cloud providers. No method of sending data over the internet is completely secure, but if a breach happens we will tell the ICO where the law requires, and tell you if it is likely to put your rights at high risk.
9. Cookies
Non-essential cookies, such as Google Analytics, are only used if you accept them. You can change your choice at any time using the cookie button on the websites. The Cookie Policy has the details.
10. Your rights
You have the right to:
- get a copy of your personal data;
- have inaccurate data corrected;
- have your data deleted;
- restrict or object to how your data is used, including objecting at any time to use based on legitimate interests;
- withdraw consent at any time, without affecting what was done before;
- receive data you gave us in a portable format, where the law provides for it.
To use any of these rights, email dinesh@46dc.com. We reply within one month. We may ask you to confirm your identity first. Using your rights is free.
11. Complaints
If you are unhappy with how your data has been handled, please complain to us first at dinesh@46dc.com. We will acknowledge your complaint within 30 days, look into it without undue delay, and tell you the outcome.
You also have the right to complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113.
12. Children
The websites and our services are not aimed at anyone under 18, and we do not knowingly collect their data. If we find we have, we will delete it.
13. Changes to this policy
We will update this policy when the way we use data changes. The date at the top shows when it last changed. If a change significantly affects you, we will tell you by email where we can.
14. If you are in India
If you are in India, we also handle your data in line with the Digital Personal Data Protection Act 2023 as its obligations come into force. The purposes, data and rights above apply to you. You can also ask us to name a person to act for you if you are unable to, and you can raise a grievance with us at dinesh@46dc.com; we will respond within 90 days. If you are not satisfied with our response, you can complain to the Data Protection Board of India.