Legal

Privacy Policy

Last updated 12 September 2026

This Privacy Policy explains how Charlie Newnham (“we”, “us”, “our”) collects, uses and protects your personal data when you use Charlie Newnham AI (the “Service”), including our website, chatbot and related tools.

We are committed to protecting your privacy in line with the UK GDPR and the Data Protection Act 2018.

1. Who We Are

The Service is operated by CJNSOCIAL LTD (company number 15664429, VAT number GB486663049), whose business owner is Charlie Newnham.

Address: Castle Barn Farm, Denmead Road, Southwick, PO17 6EX

Contact email: charlie@dwsprogram.com

For the purposes of data protection law, CJNSOCIAL LTD is the “data controller”.

2. What Information We Collect

  • Account details — name, email address, login credentials.
  • Payment information — billing name, address, transaction details. Card details are processed directly by our payment provider and are not stored by us.
  • Chat and usage data — messages, prompts, inputs, usage patterns, timestamps, interaction history.
  • Technical data — IP address, browser type, device information, cookies (see Section 7).
  • Communications — emails, support requests, correspondence.

3. How We Use Your Information

  • To provide, operate and maintain the Service.
  • To process payments and manage your account and one-off purchase.
  • To respond to enquiries and provide support.
  • To improve and personalise the Service, including AI performance.
  • To send service-related updates and, where you have opted in, marketing communications.
  • To monitor for misuse, fraud or breaches of our Terms.
  • To comply with legal and regulatory obligations.

4. Legal Basis for Processing

  • Contract — to provide the Service you have signed up for.
  • Consent — for optional automatic personalization, marketing and non-essential cookies where these are used.
  • Legitimate interests — to improve the Service, prevent misuse and carry out general business administration.
  • Legal obligation — to comply with applicable law.

5. AI-Generated Content and Chat Data

  • Please do not submit sensitive personal data (such as health information, financial account numbers or confidential details) unless strictly necessary.
  • Chat inputs may be processed by third-party AI infrastructure providers (see Section 6).
  • We may review anonymised or aggregated chat data to improve the Service, but we will not sell individual chat content.

5a. Optional Personalization

Personalization can store your business details, audience, offers, goals and response preferences for use across chats. Both memory and automatic learning start switched off. If you enable automatic learning and save, we use your consent to process new messages in a separate AI request after a reply and save useful details to your profile. This does not scan your old chat history.

You can review, correct or remove saved details in Settings → Personalization. Turning automatic learning off and saving withdraws consent for future learning. Turning memory off also stops saved context being used in future replies. Forget everything clears the saved profile and turns both controls off. These actions do not delete information already in saved chats or recall processing already underway. Extraction can make mistakes; please review what is saved and avoid sharing sensitive information.

We record changes to these preferences and the notice version to demonstrate your choices, without copying chat or profile text into that record. AI processing contributes to your usage allowance.

6. Sharing Your Information

We do not sell your personal data. Ben Lucas, the developer, operates the software on CJNSOCIAL LTD’s instructions. We may share data with:

  • Service providers — hosting, AI model and API providers, payment processors, email and CRM platforms.
  • Professional advisors.
  • Regulators or authorities.
  • A buyer, on the sale or transfer of the business.

All third parties are required to handle your data securely and in line with data protection law.

7. Cookies

We use:

  • Essential cookies.
  • Local storage for your theme and interface preferences.

You can control or disable cookies through your browser settings. Disabling essential cookies may affect the Service.

8. International Transfers

Some of our providers may be based outside the UK. Where this is the case, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or an adequacy decision.

9. Data Retention

We retain personal data only for as long as necessary to provide the Service, meet legal or accounting requirements, and resolve disputes.

Your saved chats and attachments are kept while you keep them in your account, unless you delete them or request account deletion. Saved personalization is kept until you edit or remove it, use Forget everything, or request account deletion. Switching memory off stops its use but keeps the saved information.

9a. Deletion and Retained Records

Payment, usage, security and preference records may need to be kept separately to meet legal or accounting requirements, prevent fraud and resolve disputes. The relevant purpose and legal requirements determine how long these records are needed. Deleting a chat or memory does not delete those records. Backups and provider copies are handled under their retention and deletion processes; deletion from the app is not a promise of immediate erasure of every copy. Contact us for an account-wide deletion or data access request.

10. Data Security

We use reasonable technical and organisational measures to protect your personal data. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. Your Rights

You have the right to:

  • Access the personal data we hold about you.
  • Have inaccurate data corrected.
  • Have your data deleted.
  • Restrict or object to processing.
  • Data portability.
  • Withdraw consent.
  • Complain to the Information Commissioner's Office at ico.org.uk.

To exercise any of these rights, contact charlie@dwsprogram.com.

12. Children's Privacy

The Service is not intended for anyone under the age of 18. We do not knowingly collect children's data.

13. Changes to This Policy

We may update this policy from time to time. Any update will be posted with an updated date. Continued use of the Service constitutes acceptance.

14. Contact Us

CJNSOCIAL LTD
Company number: 15664429
VAT number: GB486663049
Email: charlie@dwsprogram.com
Castle Barn Farm, Denmead Road, Southwick, PO17 6EX