Legal · draft

Privacy

Last updated 31 October 2026. This draft describes how HonestFunnels works today, and is waiting for legal review.

The short version

  • HonestFunnels is run by Virtascend Ltd, a UK company. We’re responsible for the personal data this policy describes, wherever you live.
  • For a free preview, we keep your answers, your first name and email address, and any files you send, to design your preview and email you its link and one follow-up, which you can refuse. If you don’t order, we delete it 90 days after you asked, with the few exceptions part 9 lists.
  • The AI that designs your preview gets your business’s answers, never the name and email address you give us, your links or your files. If it finds your business is one we don’t design for, a person will look again if you ask.
  • If you order, we keep what you tell us for your project and a record of your payment. Stripe takes your card details, and we never see them.
  • Our analytics count pages and steps, never who you are, and store nothing on your device. You can turn them off, and if your browser asks not to be tracked, we don’t count you.
  • We don’t sell personal data or show ads, and we don’t share it with Earncrest, the other business Virtascend runs.
  • Wherever you live, you can ask to see, correct or delete your data, object to how we use it, and complain to us or to the ICO.

1. Who we are

HonestFunnels (honestfunnels.com) is run by Virtascend Ltd, a company registered in England and Wales, company number 15192371, registered office Lytchett House, 13 Freeland Park, Wareham Road, Poole, BH16 6FA, United Kingdom. We’re the controller of the personal data this policy describes.

Contact us at hello@virtascend.com, or write to us at our registered office, with “Data protection” at the top of your letter. We haven’t appointed a data protection officer, as the law doesn’t require one for what we do.

2. Who this policy covers

  • People who ask for a free preview (part 3).
  • Customers who order a funnel build (part 4).
  • Anyone visiting honestfunnels.com (part 5).
  • Anyone who emails us or books a call with us (part 6).
  • People shown or named in pictures, pages or words someone sends us for a preview or a project: we use them only for that, and delete them as part 9 says.

3. Your free preview

What we collect:

  • Your business: the builder you use, how far along you are, your brand, what you sell, who it’s for, your website, the style and colour you pick, and your description of the page you want.
  • Pages you like and your logo: up to 3 links and up to 3 pictures, and your logo if you send one.
  • You: your first name and email address; whether you ticked “Also send me occasional funnel tips and offers. Unsubscribe anytime.”, with those words and when you ticked it; and whether you chose “Skip the follow-up”.
  • A code made from your internet address with a secret key that only we hold, kept instead of the address itself, to help us spot someone asking for many previews.

You don’t have to give us any of this, but without your answers we can’t design your preview, and without your email address we can’t send it to you. Please tell us only about your business, and leave out health details and other private information about yourself or anyone else: our AI reads what you write, and your preview doesn’t need them.

What we do with it:

  • We design your preview. The AI that designs it gets your brand, what you sell, who it’s for, the style and colour you picked, your description and any changes you ask for, so if your business carries your own name, it gets that as part of your brand. It never gets the first name or email address you give us at step 5, your website, links or files. It also writes short notes for our team about your answers, such as anything you might want to confirm, and we keep them with your preview. If your business is one we don’t design for, it tells us that instead (part 16).
  • We keep your links and files for our team, to use if you order. No server of ours ever opens your links. We make a clean copy of each file you send, and keep only that, without hidden details such as where a photo was taken.
  • We email you your preview’s private link, and one follow-up about it: a note that your design is ready if you haven’t seen it yet, or if you have, a reminder two days later. We note when you first open your preview, to know which to send. No follow-up comes if you press “Skip the follow-up” at step 5, and every email from us about your preview has a link that stops our emails, or you can reply “stop”.
  • If you use ClickFunnels, which we can’t build in yet, we keep your first name, email address and reference after your preview is deleted, to email you once if we can build there within a year of when you asked. Not if you refused the follow-up or stopped our emails.
  • Tips and offers, only if you ticked the box. Each email will have a link to unsubscribe, and you can ask us to stop at any time.
  • If you stop our emails, we keep a code made from your email address, never the address itself, so that we don’t email you by mistake if you ask for another preview.
  • We check you’re a person. Before step 5 sends your preview, Cloudflare’s security check (Turnstile) looks at your browser and internet address to tell people from bots, and also uses what it sees, as a company in its own right, to make its checks better. We also count requests from each internet address and email address, as codes made with a secret key, so nobody can ask for too many previews.

Why we’re allowed to: designing your preview and emailing you its link are steps you asked us to take before you might order (contract), or if you ask for a company, our legitimate interest in answering its request. The follow-up and the ClickFunnels email are in our legitimate interest in offering you the build you asked about, which the law lets us email you about while you can say no, as step 5 and every email let you. Tips and offers need your consent, which you can withdraw at any time. Keeping the code of an address that stopped our emails is in our legitimate interest in honouring that, as the law expects. Our AI’s notes, and its check of the kind of business, are in our legitimate interest in making sure what we show and build is honest, and only for businesses we can work for. The security check, the code from your address and our limits are in our legitimate interest in keeping HonestFunnels safe from abuse.

4. If you order

  • Your payment: Stripe’s checkout takes your card and billing details, and handles your payment as a company in its own right, under its own privacy policy. We give Stripe your email address and our references for your order, and get back a record of your payment: its references, the amount, whether it’s paid or refunded, and when. We never see your card details.
  • Your project: what you sell, your logo and the pages you like, your choices at kickoff, the design you approve, the changes you ask for, our notes about your project, and the emails we send you about it.
  • Your funnel: we build it in our systeme.io account and share it to yours. Once you’ve copied it, or 30 days after we share it if you haven’t, we remove it from ours. We never log in to your account, so we never see your own customers’ details.
  • The Earncrest box: if you tick it, we note it with your order, and when Earncrest.org’s verification opens, we email you its link once, from HonestFunnels. We don’t send anything about you to Earncrest.

You don’t have to give us these details, but without them we can’t take your order or build your funnel.

Why we’re allowed to: to do what we agreed with you (contract), and to keep the accounts the law requires of us (legal obligation). We send the Earncrest email only because you ticked its box (consent): tell us if you change your mind, and we won’t send it.

5. Visiting our site

  • Analytics. We count how visitors move through the site, with PostHog, in the EU: each page seen (a private page only by its kind, never its address), each step of the preview finished, and the Earncrest box ticked, with the campaign’s tags in the link you followed and the website that sent you on the first page you see. Our server also counts a preview asked for, with the campaign’s tags of the visit it came from, a design seen, a checkout started, a payment and a kickoff finished. Each count comes with a code made at random for that count alone, so no two counts share a code, and we never join one count to another or to our other records. A payment’s code is made from the payment instead, with a key we make afresh each day and never keep, so a payment we’re told of twice counts once. Nothing about your device or where you are goes with a count, and PostHog never gets your internet address. We only ever look at the totals.
  • Saying no. Press “Don’t count my visits” below and we count nothing from this browser, including a payment you make after it. If your browser sends Global Privacy Control or Do Not Track, we count nothing from it either.

    We count your visits as this part says. To stop, press the button: this browser then keeps your choice in a cookie that holds nothing else, for a year from your last visit.

  • Keeping the site safe. Cloudflare carries every visit between your browser and our servers and checks it for attacks, so it handles your internet address and what your browser sends. Our servers count requests from each internet address for a short time, to stop floods and abuse, and what our database keeps for this is a code made with a secret key, never your address.
  • Error reports. When something goes wrong in our code, Sentry gets a report of the error. It’s made to hold only the error and, at most, the reference of the preview or order it happened with, never your name, email address or answers, and anything in it that looks like an email address, internet address or key is removed before it’s sent.

Why we’re allowed to: our legitimate interests in understanding how the site is used and making it better, keeping it safe, and keeping it working. The law lets us count visits this way without asking first, as long as it’s only to improve the site and you can say no.

6. Emailing us, or booking a call

  • Emails: when you email hello@virtascend.com or reply to one of our emails, it reaches our team’s inbox. We keep your email and our replies, to answer you.
  • Calls: if you book a call through Calendly, it takes your name and email address, the time you choose and anything you write, and we use them for the call.

Why we’re allowed to: our legitimate interest in answering you, and for a customer, to do what we agreed (contract).

7. Who we share personal data with

Service providers who process it for us, under contracts that require them to protect it:

  • Supabase: our database, in London.
  • Fly.io: our servers, in London.
  • Cloudflare: on its global network, it carries our website and checks it for attacks, runs the security check at step 5, stores the files you send, the pictures of your design and our backups, forwards emails sent to our honestfunnels.com address, and runs our domain name system. It also uses what the security check sees to make its checks better, as a company in its own right (part 3).
  • Anthropic: the AI that designs previews, in the United States. It gets only what part 3 lists, doesn’t use it to train its models, and deletes it within 30 days, unless its safety checks flag it as breaking its usage rules, when it may keep it for up to 2 years.
  • Resend: sends our emails from the EU, and keeps its records of them in the United States.
  • PostHog: analytics, in the EU.
  • Sentry: error reports, which never hold your name, email address or answers (part 5).
  • Calendly: booking calls, in the United States.
  • systeme.io: where we build your funnel before we share it with you, in Ireland.
  • Our email provider: holds our team’s inbox, where your emails to us arrive.

Stripe handles your payment as a company in its own right (part 4). We may also share personal data with professional advisers, such as lawyers and accountants; with authorities, when the law requires it; and with a buyer of our business, if it’s ever sold.

Virtascend also runs Earncrest. HonestFunnels’ data is kept apart from Earncrest’s, in a database of its own, and we don’t share it with Earncrest. We never sell personal data.

8. Transfers outside the UK

Some of the companies in part 7 are based outside the UK, even where our data is kept in London:

  • Fly.io, Cloudflare, Calendly, Resend, PostHog and Sentry are US companies certified under the UK–US data bridge (the UK Extension to the EU–US Data Privacy Framework), which UK law treats as protecting your data adequately. Fly.io’s servers are in London and PostHog keeps our analytics in the EU, but their teams may reach them from outside the UK. Resend sends our emails from the EU, but keeps its records of them, such as who each email went to and when, in the United States. Cloudflare’s network includes countries outside the UK.
  • Anthropic is in the United States. Its contract with us includes the EU’s standard contractual clauses with the ICO’s UK Addendum.
  • Supabase keeps our database in London, but the company we contract with is in Singapore, and its team may reach the database from other countries to run it. Its contract with us includes the EU’s standard contractual clauses with the ICO’s UK Addendum.
  • systeme.io is in Ireland and keeps data in the EU, which UK law treats as adequate.

If you’re in the EU or the EEA, your data comes to us in the UK, which the EU recognises as protecting it adequately, in a decision renewed in December 2025 until 2031. Email us for a copy of any of these safeguards.

9. How long we keep it

  • A preview nobody orders: 90 days after it was asked for, or 30 days after you last started checkout without paying, if that’s later. Then we delete it, with your answers, your name and email address, our AI’s notes, your choices about our emails, our record of the emails we sent you, its private links, and any order you started but didn’t pay for.
  • The files you send, and pictures of your design: 90 days after they arrive or are made, whether or not you order.
  • If you use ClickFunnels: your first name, email address and reference, until we email you that we can build there, and at most a year after you asked.
  • If you stop our emails: the code made from your email address, until you ask for our tips and offers again.
  • If you order, your preview, order and project: 6 years after the end of the financial year you paid in, for our accounts and in case of a dispute. Your choice about tips and offers stays with them until you unsubscribe.
  • Analytics: 1 year, a period our analytics provider sets.
  • Error reports: 30 days, a period our error-reporting provider sets.
  • The counts for our limits: up to 3 days.
  • Backups: we keep each backup of our database 30 days, so what we delete is gone from our backups 30 days later.
  • Emails to us, and calls: 2 years after our conversation ends.
  • Your requests about your data: what you asked and what we did, with the code made from your email address, for 2 years.

10. Your rights

You can ask us:

  • to see the personal data we hold about you, and for a copy of it;
  • to correct it;
  • to delete it;
  • to limit what we do with it;
  • for what you gave us, in a form you can take elsewhere;
  • to stop tips and offers, or to withdraw any other consent, at any time, which doesn’t affect what we did before.

Your right to object. You can object at any time to anything we do because it’s in our legitimate interests, such as our analytics or the follow-up email. We’ll stop, unless we have compelling reasons to carry on that outweigh yours, or we need it for a legal claim. You can always stop our emails about our services, with the link in any of them, by replying “stop”, or by emailing us, and we’ll stop without asking why.

Email hello@virtascend.com, ideally from the address you used with us, or write to us. It’s free. We may need to check it’s you first. We answer within one month of getting your request, or of what we need to check it’s you, if that’s later. If your request is complex, or you’ve sent us several, we may take up to two more months, and we’ll tell you why within the first month. If we can’t do what you ask, we tell you why, and how to complain. We keep a record of each request, as part 9 says, in our legitimate interest in showing we handled it properly. If you’ve ordered, we keep what the law requires for our accounts, even if you ask us to delete it.

11. Complaints

If you’re unhappy with how we’ve handled your personal data, tell us first: email hello@virtascend.com with “Complaint” in the subject line, or write to us at our registered office. We acknowledge your complaint within 30 days, look into it without undue delay, keep you informed, and tell you the outcome.

You can also complain to the Information Commission (the ICO), the UK’s data protection regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113. If you live outside the UK, you can also complain where you live (part 12).

12. If you live outside the UK

  • Wherever you live, you can use the rights in part 10, in the same way and free of charge.
  • In the EU or the EEA, where the EU GDPR applies to how we handle your data, it gives you the same rights, and you can also complain to the data protection authority where you live or work: the European Data Protection Board lists them at edpb.europa.eu.
  • In the United States, we don’t sell personal information or share it for targeted advertising, and we don’t ask for sensitive personal information. Whichever state you live in, you can ask us what we hold about you, and to correct or delete it, and we won’t treat you differently for asking.
  • Anywhere else, such as Switzerland, Canada or Australia, you can also complain to your own country’s data protection or privacy regulator.

13. Cookies and your device

  • Cookies. If you press “Don’t count my visits” (part 5), the site sets a cookie that keeps that choice, and nothing else, for a year from your last visit. It sets no others of its own. If Cloudflare ever has to check a connection for attacks before letting it through, it may set a cookie of its own to remember that it passed.
  • Our analytics read, in your browser, which page you’re on, and on the first page the campaign’s tags in the link you followed and the website that sent you, to count them as part 5 says. They store nothing on your device.
  • Your answers as you go. While you answer the preview’s questions, your answers are kept in this browser tab, and the files you choose in this browser’s storage, so a refresh or the Back button loses nothing. They reach us only when you send step 5, and then they’re cleared from your browser. If you don’t finish, your answers go when you close the tab, and your files a day after you last chose one: the first page of ours you open after that deletes them, and clearing this site’s data does at any time.
  • The security check. At step 5, Cloudflare’s security check runs in a frame of its own, and may keep a little in your browser to tell people from bots.

These are needed for what you’ve asked us to do, to keep your choice, or to keep the site secure, and our analytics are only to improve the site, with a way to say no, so we don’t ask for your consent to them.

14. Children

HonestFunnels is for businesses and people aged 18 or over. We don’t knowingly hold children’s personal data.

15. Keeping it safe

Our database and servers are in London, and only our own servers and our team’s back office, with keys only we hold, can reach the database. A private link is stored only as a code made from it, so it can’t be read back from our database. The files you send are cleaned before anyone opens them. Our backups are encrypted, and only we can open them. Only our team can see what you’ve sent us, through tools that aren’t on the public internet.

If something ever went wrong that put your data at risk, we’d tell the ICO within 72 hours where the law requires it, and tell you without delay if it could seriously affect you.

16. Decisions made automatically

We don’t make decisions about you by automated means alone that have legal or similarly significant effects. Our AI designs a page from your answers. It also checks whether your business is one of the kinds we don’t design for, which our Terms list, and if it is, we don’t design your preview. That’s the only thing it decides, and it decides it from what you tell us about your business. If you think it got it wrong, email hello@virtascend.com with your preview’s reference, and a person will look again. Our limits can turn a request down automatically, to stop abuse: if you think one turned you down by mistake, email us and a person will look at it.

17. Changes to this policy

When we change this policy, we update the date at the top. If you’re a customer and a change matters to you, we’ll email you before it takes effect. Our Terms say what you agree to when you use HonestFunnels.

HonestFunnels is a service of Virtascend Ltd, registered in England and Wales, company no. 15192371. Registered office: Lytchett House, 13 Freeland Park, Wareham Road, Poole, BH16 6FA, United Kingdom. Questions: hello@virtascend.com