Our Privacy Policy

‍

Introduction

Welcome to AI AGENT GROUP LTD’s privacy policy for Customers, Members and prospective Members.

AI AGENT GROUP LTD is incorporated and registered in England and Wales with company number 15558569 with our registered office is at 11 Laura Place, Bath, Somerset, England BA2 4BL. We trade as SalesAPE.ai. We respect your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our services and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can navigate to the specific areas set out below.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
CONTACT DETAILS
COMPLAINTS
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
THID-PARTY LINKS
GLOSSARY

Important information and who we are

Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of our website and app, including any data you may provide when you book a call with us, register with us, and your use of our services.

Our website and app are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice, including our Cookie Policy (available here), that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Controller
AI AGENT GROUP LTD incorporated and registered in England and Wales with company number 15558569 whose registered office is at 11 Laura Place, Bath, Somerset, England BA2 4BL  (T/A SalesAPE.ai) is the controller and responsible for your personal data (referred to as "SalesAPE", "we", "us" or "our" in this privacy policy).

We have appointed a privacy team which is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the privacy team using the details set out below.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes full name, username or similar identifier, date of birth and gender.

Contact Data includes email address and telephone numbers.

Financial Data includes card number, expiry date and security code.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes device information (such as your hardware model, operating system version, unique device identifiers and mobile network information), log information (including search queries, telephone calls, IP address, device event information such as crashes, browser type and system activity), location information (from signals sent by your device GPS or sensor data from your device), unique application number (for example the operating system type and application version number), cookies and identifiers (please see our cookie policy). We may associate your Technical Data with your Account Data.

Account Data includes your email address and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. If you want to take full advantage of the sharing features we offer, we might also ask you to create a publicly visible SalesAPE Profile which may include your name and photo.

Usage Data includes information about how you use our website or app, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also collect, store and use the following "special categories" of more sensitive personal information:

- Information about your health and any disabilities which we, or our Partners, may need to know about
- Information about your race or ethnicity which our Partners may need to know about

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. Many of our services require you to sign up for a SalesAPE Account. When you do, we’ll ask for Identity Data.

Automated technologies or interactions. As you interact with our website and app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie policy available here for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
  
  • analytics providers such as Google based outside the EU;
  • social media networks such as Facebook based outside the EU; and
  • survey information providers such as AskNicely based outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.
• Identity and Contact Data from data brokers or aggregators such as Databroker Ltd based inside the EU.
• Identity and Contact Data from your employer or benefit provider based inside or outside the EU.
  ‍

How we use your personal data

We will only use your personal data when the law allows us to. The law requires us to have a legal basis for doing so. Most commonly, we will rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Legal obligation:
  Where we need to comply with a legal or regulatory obligation.
• Consent: Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to:
  
  • processing special categories of personal data. A specific example of where your personal information is processed is when you upload knowledge documentation about your business to the product portal, and that information is used to form a query to a foundational model. You have the right to withdraw consent to our processing special category personal data at any time by contacting us but please bear in mind that this may affect our ability to provide our services to you; and
  • sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Please see the Marketing section below for more information.
    ‍

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the contact information set out in the Contact Details section below if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

‍

‍

‍

‍

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Account Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if:

• you have signed up for our services and you have not opted out of receiving that marketing; or
• if you have enquired about our services and have provided opt-in consent at the point of submitting your details.
  SalesAPE also engages with Royal Mail for non-targeted postcode mail drops.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the our group of companies for direct marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into your SalesAPE account, navigating to your contact preferences, and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies
You can use the cookies manager tool on our platforms or set your browser to refuse all or some browser cookies, or to alert you when websites and apps set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy available here.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact information set out in the Contact Details section below.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

Many of our services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines. Our services provide you with different options on sharing and removing your content. We may ask for ratings or feedback at any time and may use any replies to display public ratings and reviews on our website and app. This may be shared along with your online profile photo provided on online public accounts such as Google or Facebook.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

External Third Parties such as:

- Partners providing services to you as a Member, acting as data controllers, based inside the EU/UK.
- Service providers acting as processors based inside and outside the EU/UK who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers, based inside the EU/UK, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Market research providers such as MailChimp, based outside the EU/UK.
- Email service providers such as MailChimp, based outside the EU/UK.
- Market research providers such as Brokkr, based inside the EU/UK.
- Social media providers such as FaceBook, based outside the EU/UK.
- Marketing companies such as AskNicely, based outside the EU/UK.
- Customer relationship management database providers such as Hubspot, based outside the EU/UK
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We share your personal data within the SalesAPE group. This will involve transferring your data outside the United Kingdom (UK) and the European Economic Area (EEA) in the United States.

Many of our external third parties are also based outside the UK and the EEA so their processing of your personal data will involve a transfer of data outside these regions.

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• In the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. We rely on the adequacy regulation for transfers to the United States pursuant to the UK extension to the Data Privacy Framework.
  
  
• In the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the GDPR. We rely on adequacy decision for transfers to the United States pursuant to the Data Privacy Framework.
  
  
• In the case where no adequacy regulation or adequacy decision has been issued, 
  
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; 
  • you expressly consent to such transfers; or
  • a specific exception applies under relevant data protection law.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

Additional Jurisdiction-Specific Disclosures

We may choose or be required by local data privacy laws to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions, or states. If you reside in California (United States) or Canada, please read the below sections, as applicable.

1. Privacy Disclosures for California Residents

This Disclosure is made in accordance with California law, including the California Consumer Privacy Act (CCPA). If you are based elsewhere in the world this Disclosure does not apply to you.

Under the California Consumer Privacy Act of 2018 (CCPA), California residents have specific rights regarding their personal information. This section outlines these rights and how to exercise them:

Categories of Personal Information Collected

In the last twelve (12) months, we have collected the following categories of personal information from California residents or households:

• Identifiers (e.g., name, email address, IP address).
• Commercial information (e.g., purchase history).
• Internet or other electronic network activity (e.g., browsing history on our site).
• Geolocation data.
• Professional or employment-related information.
• Inferences drawn from the above to create a profile.

For a complete list of the categories of personal information we collect, refer to ‘The Data we Collect About you” section above.

Categories of Personal Information Disclosed for a Business Purpose.

In the last twelve (12) months, we have disclosed all of the categories of personal information outlined above for business purposes to the recipients identified in our Privacy Policy available here. See also the section below on “No Sale of Personal Information”.

Your Rights Under the CCPA

As a California resident, you have the following rights:

1. Right to Know: Request details about the personal information we collect, use, and share.
2. Right to Delete: Request that we delete your personal information, subject to certain exceptions.
3. Right to Opt-Out: Opt out of the sale or sharing of your personal information, if applicable.
4. Right to Non-Discrimination: We will not discriminate against you for exercising any of your rights under the CCPA.

To exercise either your rights, please contact us using the information set out in the Contact Details section below. 

Do Not Sell My Personal Information

We have not sold personal information in the last twelve (12) months as those terms are defined under CCPA. To the extent that, in the future, we engage in data transfers that constitute a “sale” of your Personal Information under CCPA, we will update this policy and provide a “Do Not Sell My Personal Information” link.

2. Privacy Disclosures for Canadian Residents

This Disclosure is made in accordance with Canadian law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws. If you are based elsewhere in the world, this Disclosure does not apply to you.

Consent Mechanism

We obtain your consent before collecting, using, or disclosing your personal information, except in circumstances permitted by law. Consent may be:

• Express: Given explicitly, such as when you check a box agreeing to terms.
• Implied: Based on your actions, such as providing information to complete a transaction.

In certain situations, we may collect, use, or disclose your personal information without your consent as described in the Privacy Policy here where:

• It is necessary for the performance of a contract to which you are a party.
• It is required to comply with legal obligations.
• It is reasonable for legitimate interests, provided such processing is not contrary to your rights or reasonable expectations.

You may withdraw your consent at any time by contacting us using the information set out in the Contact Details section below. However, please note that withdrawing consent may affect our ability to provide certain services or fulfill our obligations to you.

Your Rights Under PIPEDA

As a Canadian resident, you have the following rights:

1. Access and Correction: Request access to the personal information we hold about you and correct any inaccuracies.
2. Withdrawal of Consent: Withdraw your consent for us to use your personal information, subject to legal or contractual restrictions.
3. Complaint Handling: File a complaint with us or with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated.

To exercise either your rights, please contact us using the information set out in the Contact Details section below. We will respond to your request within 30 days, as required by law.

Data Transfers and Storage

Your personal information may be transferred to and stored on servers located outside Canada. By using our services, you consent to the transfer of your personal information to these jurisdictions, which may not have equivalent privacy laws.

‍

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For instance, these measures include encryption of personal data in transit and at rest, separation of production and development cloud environments, access controls following the principle of least privilege, a secure software development lifecycle, and static code analysis to identify and patch known vulnerabilities. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 from us by contacting us.

Your legal rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to: 

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us.

Our full details are:

Attn. Privacy Team

AI AGENT GROUP LTD 

11 Laura Place, Bath, Somerset, England BA2 4BL 

Email address: dpo@salesape.ai

Complaints

You have the right to make a complaint at any time to:

• the Information Commissioner's Office (ICO), the supervisory authority for data protection issues in the UK; or
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA. 

The UK’s Information Commissioner may be contacted using the details at: https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details see https://edpb.europa.eu/about-edpb/abouedpb/members_en

We would, however, appreciate the chance to deal with your concerns before you approach the ICO or other EEA data protection supervisory authority, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 06 August 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website and app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the privacy policy of every website you visit.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

‍