Scope and responsibility
This policy covers Neural Flow’s own prospect research, business outreach, enquiries and associated working records. The responsible operating owner is Danion Hughes. Client campaign data, contracts, finance and disputes require the purpose-specific arrangements that apply to them.
NEURAL FLOW LTD is registered in England and Wales (company number 17122357). Registered office: Flat 6 Atlantic House 51-57 Upper Richmond Road, London, England, SW15 2RD.
The same criteria apply to raw exports, derived contact files, local research notes, rendered emails, Lemlist records and relevant correspondence. Publicly accessible professional information can still be personal information.
Retention criteria
Unused raw exports, duplicate working copies and uncontacted prospects: review at least monthly and by 90 days from acquisition. Remove unnecessary fields and records. Continued retention requires a recorded business purpose, owner and next review date.
Cold outreach without engagement: review for removal within 90 days of the final permitted touch, subject to any earlier necessity limit. A new export, campaign, model classification or internal note does not reset the original acquisition date.
Genuine enquiries and opportunities: review within 12 months of the last substantive two-way interaction and sooner when closed or no longer necessary. Continuing live negotiations or service fulfilment must be documented.
Objections: stop marketing use immediately. Retain only the identifiers, scope and date needed to prevent recontact; review the continued need annually. Do not delete the only suppression record and subsequently reimport the person.
Legal, contractual, finance and dispute records: use the specific justified schedule. This cold-prospect policy does not automatically delete records required for a live request, dispute or legal obligation.
Review and deletion process
The operating register records the source snapshot, known acquisition evidence, purpose, status, last substantive interaction where applicable, next review and any justified exception. A review runs before further batch staging or campaign release and at the monthly review date.
When information is no longer necessary, remove or anonymise the relevant operational copies and request appropriate removal from providers. Record what was removed, what remains under a specific lawful purpose, and any provider or backup completion still outstanding. Expiry blocks marketing release; it is not proof that every copy has already been erased.
Review and deletion are distinct. We do not claim that a software timer has automatically erased all local files, email copies or provider backups. Limited suppression and necessary compliance records are handled separately.
Existing prospect data
Neural Flow obtained the current Cognism export on 12 September 2026, as confirmed by the operating owner on 29 October 2026. A new import or internal research does not reset that acquisition date.
The existing population is under review now, with the next operational review due 28 November 2026 and a 90-day acquisition review point on 11 December 2026, subject to any earlier necessity limit. Retention review dates do not extend privacy-notice deadlines.
Questions or objections
Reply to the Neural Flow message you received or email contact@neuralflow.co.uk to object, ask about retention or raise a privacy concern. See our privacy notice for sources, purposes, recipients, transfers and individual rights.