1. Introduction
1.1. We are committed to safeguarding the privacy of our website visitors, service users, and supplier,customer and partner personnel.
1.2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4. In this policy, "we", "us" and "our" refer to aiphoria Limited. For more information about us, see Section 11.
2. The personal data that we collect
2.1. In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2. We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer.
2.3. We may process your service user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, service settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by ourservices.
2.4. We may process information relating to our customer relationships ("customer relationship data").The customer relationship data may include your name, the name of your business or employer,your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.
2.5. We may process information contained in or relating to any communication that you send to us ort hat we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.6. Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2. Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3. Relationships and communications - We may process contact data, account data and/or communication data for the purposes of managing our relationships, communicating with you(excluding communicating for the purposes of direct marketing) by email, SMS, post, and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of ourservices, and the proper administration of our website, services and business.3.4. Personalisation - We may process account data, service data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
3.5. Direct marketing - We may process contact data, account data and/or customer relationship data for the purposes of creating, targeting and sending direct marketing communications by email,SMS, and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.6. Research and analysis - We may process usage data and/or service data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests,namely monitoring, supporting, improving and securing our website, services and business generally.
3.7. Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.8. Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.9. Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10. Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.11. Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.3. We may disclose personal data to our suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy. Where such suppliers or subcontractors are providing us with services that involve them processing personal data on our behalf, they are our dataprocessor. We have contracts in place with our data processors meaning they are not authorised to do anything with your personal data unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. The categories of our suppliers or subcontractors who may process personal data on our behalf are:• Customer relationship management (CRM) service providers• Accounting, billing and invoicing service providers• Electronic information storage service providers• Marketing service providers
4.4. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.We may also disclose your personal data where such disclosure is necessary for the establishment,exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of court procedure.
5. International transfers of your personal data
5.1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
5.2. We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
5.3. In relation to transfers outside of the UK or EEA, we will ensure that transfers to each of these countries will be protected by appropriate safeguards, such as Standard Contractual Clauses, the EU-US Data Privacy Framework and the UK-US data bridge mechanism. You can obtain a further details of such safeguards by emailing: dpo@aiphoria.co.uk.
6. Retaining and deleting personal data
6.1. This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
6.4. Notwithstanding the other rasingprovisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, orin order to protect your vital interests or the vital interests of another natural person.
7. Security of personal data
7.1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2. We will store your personal data on secure servers, personal computers and mobile devices, and insecure manual record-keeping systems.
7.3. The following personal data will be stored by us in encrypted form: your name, contact information,password(s) and cardholder data.
7.4. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
7.5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to ourwebsite).
8. Your rights
8.1. In this Section 8, we have listed the rights that you have under data protection law.
8.2. Your principal rights under data protection law are:
8.3. the right to access - you can ask for copies of your personal data;
8.4. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
8.5. the right to erasure - you can ask us to erase your personal data;
8.6. the right to restrict processing - you can ask us to restrict the processing of your personal data;
8.7. the right to object to processing - you can object to the processing of your personal data;
8.8. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
8.9. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
8.10. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.11. These rights are subject to certain limitations and exceptions. You can learn more about the rightsof data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdprguidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-todata-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.12. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. Updating information
9.1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
10. Acting as a data processor
10.1. In respect to data captured, transmitted, stored and processed by our products/services, we do not act as a data controller; instead, we act as a data processor.
10.2. Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Ourl egal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
11. Our details
11.1. This website is owned and operated by aiphoria limited.
11.2. We are registered in England and Wales under registration number 14968896, and our registered office is at Arboretum House Horn Hill Road, Adderbury, Banbury, England, OX17 3EW.
11.3. You can contact us:
11.3.1. by post, to the postal address given above;
11.3.2. using our website contact form;
11.3.3. by telephone, on the contact number published on our website; or
11.3.4. by email, using the email address published on our website.
12. Data protection registration
12.1. We are registered as a data controller with the UK Information Commissioner's Office.
12.2. Our data protection registration number is ZB810902.
13. Data protection officer
13.1. Our data protection officer's contact details are: dpo@aiphoria.co.uk.
Last updated: 2025-08-10 10:15
