Privacy notice 

Finley AI’s Privacy Commitment

We are Finley AI (INATIGO), a company registered in England and Wales. Throughout this privacy notice, we will refer to ourselves as ‘we’, ‘us’, or ‘our’. As the Data Controller, we take full responsibility for the personal information we collect, hold, and process about you, as detailed in this notice.

Our commitment to your privacy, which includes the security and integrity of your personal information, is paramount. This privacy notice is crafted to clearly inform you about our methods of collecting personal information about you and the ways in which we utilise this information. We encourage you to read this notice thoroughly to fully understand our practices regarding your personal information and the reasons behind them.

While we do not have a designated data protection officer, our team is fully equipped to handle inquiries or concerns about this privacy notice or any related issues. Should you have any questions, you can reach out to our data protection team using the contact details provided above.

Please be aware that we may update this privacy notice occasionally. The current version was last revised on 15 December 2023.

Finley AI’s Data Privacy Approach

At Finley AI, we are committed to developing sophisticated AI technologies with an emphasis on dependability, clarity, and user empowerment. This policy is intended to transparently explain how we manage your personal data when you interact with our website or use any of Finley AI’s services, including APIs and other products intended for consumer use (“Services”). Furthermore, this document outlines your rights related to your personal data. Comprehensive details about these rights and the methods to exercise them can be found in= this policy.

Note that this Privacy Policy applies primarily where Finley AI acts as a data controller—where we directly collect and decide how your personal data is processed. However, this policy does not encompass scenarios where Finley AI serves as a data processor, such as when you use Finley AI’s AI services via a business entity. In these cases, the business entity is the data controller of your personal data, and their privacy policy should be referred to for information on their data handling practices.

1. Key definitions

1.1. The key terms that we use throughout this privacy notice are defined below, for ease:

1.2. Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.

1.3. Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email-marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer base.)

1.4. Personal Information: in this privacy notice, we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information that has been anonymised.

1.5. Special Information – certain very sensitive personal information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life and sexual orientation and also includes genetic information and biometric information.

2. Details of personal information that we collect and hold about you

2.1. Set out below are the general categories and details of retention periods in relation to those categories (see section 8 below for more details about retention) and in each case the types of personal information that we collect, use and hold about you:

3. Details of special information that we collect and hold about you

3.1. Special information is explained in section 1 above. We do not collect or hold any special information about you.

3.2. We do not collect information from you relating to criminal convictions or offences.

4. Details of how and why we use personal information

4.1. Usage of Inputs and Responses in AI Services: Our AI services allow you to submit various forms of content, such as text, documents, or other data (“Inputs” or “Prompts”), which are processed to generate relevant responses or outputs (“Responses”). When your Inputs or Prompts include personal data, this data is collected and may be incorporated into the Responses. The management of Inputs/Prompts and Responses adheres to strict data protection and retention guidelines as outlined in our policy.

4.1.1. Redaction of Personal Data: We offer the option to redact personal data within your Inputs and Responses. This functionality allows you to control the visibility and use of your personal data within our services, aligning with our commitment to uphold your privacy and data protection rights.

4.1.2. Customization of Redaction Settings: You have the ability to customize the redaction settings of your personal data. While default settings are in place for your protection, you can adjust these settings to modify the level of data redaction according to your preferences. This customization feature ensures you have control over how your personal data is processed in our AI services.

4.2. Legal Reasons for Using Personal Information: We are only able to use your personal information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below; but, in most cases, we will use your personal information for the following legal reasons:

• Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;
• Legitimate Interests Reason: this is where the use of your personal information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests;
• Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and
• Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons.

4.3. So that we are able to provide you with goods and services, we will need your personal information. If you do not provide us with the required personal information, we may be prevented from supplying the goods and services to you.

4.4. It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know. If you do not do this, then we may be prevented from supplying the goods and services to you .

4.5. Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information – in which case, we will confirm that reason to you.

4.6. We have explained below the different purposes for which we use your personal information and, in each case, the legal reason(s) allowing us to use your personal information. Please also note the following:

• if we use the Legitimate Interests Reason as the legal reason for which we can use your personal information, we have also explained what that legitimate interest is; and
• for some of the purposes, we may have listed more than one legal reason on which we can use your personal information, because the legal reason may be different in different circumstances. If you need confirmation of the specific legal reason that we are relying on to use your personal data for that purpose, please contact us using the contact details set out at the start of this privacy notice.

4.7. Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together with other personal information and you are not identifiable from that combined data we are able to use this.

4.8. Under data protection laws, we can only use your personal information for the purposes we have told you about, unless we consider that the new purpose is compatible with the purpose(s) we told you about. If we want to use your personal information for a different purpose that we do not think is compatible with the purpose(s) we told you about, then we will contact you to explain this and what legal reason is in place to allow us to do this.

5. Details of how we collect personal information and special information

5.1. We usually collect Identity Information, Contact Information, Payment Information, Transaction Information, Survey Information, Marketing Information, Special Information; directly from you when you fill out a form, survey or questionnaire, purchase goods, services and/or digital content from us, contact us by email, telephone, in writing or otherwise. This includes the personal information that you provide to us when you subscribe to our mailing list enter a competition or survey.

5.2. We may receive some of your personal information from third parties or publicly available sources. This includes:

• Contact Information and Payment Information from our selected third-party suppliers, such as Stripe, PayPal, Mastercard;
• Identity Information and Contact Information from selected data brokers;
• Identity Information and Contact Information from publicly available sources such as Companies House;
• Website, Device and Technical Information from third parties such as analytics providers (like Google);

5.3. We may also receive Website, Device and Technical Information automatically from technologies such as cookies that are installed on our website. To find out more about these please see our cookie policy, which is available www.inatigo.com/cookie-policy.

6. Details about who personal Information may be shared with

6.1. We may need to share your personal information with other organisations or people. These organisations include:

• Other companies in our group (who may might act as joint data controllers or as data processors on our behalf) and who describe the services they provide that require them to have access to personal information, e.g. IT services, or describe the reasons it may be shared with them, e.g. for management reporting.
• Third parties who are not part of our group. These may include:
  • Suppliers: such as IT support services, payment providers, administration providers, marketing agencies who are based in United States countries;
  • Government bodies and regulatory bodies: such as HMRC, fraud prevention agencies;
  • Our advisors: such as lawyers, accountants, auditors, insurance companies;
  • Email platforms ;
• any organisations that propose to purchase our business and assets, in which case we may disclose your personal information to the potential purchaser.

6.2. Depending on the circumstances, the organisations or people who we share your personal information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor, we will ensure that we have in place contracts that set out the responsibilities and obligations of us and them, including in respect of security of personal information.

6.3. We do not sell or trade any of the personal information that you have provided to us.

7. Details about transfers to countries outside of the EEA

7.1. If any transfer of personal information by us will mean that your personal information is transferred outside of the EEA, then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information as is given to it within the EEA and that the transfer is made in compliance with data protection laws (including, where relevant, any exceptions to the general rules on transferring personal information outside of the EEA that are available to us – these are known as ‘derogations’ under data protection laws). We may need to transfer personal information outside of the EEA to other organisations within our group or to the third parties listed above in section 6 who may be located outside of the EEA.

7.2. The safeguards set out in data protection laws for transferring personal information outside of the EEA include:

• where the transfer is to a country or territory that the EU Commission has approved as ensuring an adequate level of protection;
• where personal information is transferred to another organisation within our group, under an agreement covering this situation, which is known as ‘binding corporate rules’;
• having in place a standard set of clauses that have been approved by the EU Commission;
• compliance with an approved code of conduct by a relevant data protection supervisory authority (in the UK, this is the Information Commissioner’s Office (ICO);
• certification with an approved certification mechanism;
• where the EU Commission has approved specific arrangements in respect of certain countries, such as the US Privacy Shield, in relation to organisations that have signed up to it in the USA.

8. Data Storage and Handling Practices

8.1. Retention Periods: We will only hold your personal data for as long as is necessary, as explained in this section. How long is necessary will depend upon the purposes for which we collected the personal information (see section 4 above) and whether we are under any legal obligation to keep the personal information, such as in relation to accounting or auditing records or for tax reasons.

8.2. Legal Claims: We may also need to keep personal information in case of any legal claims, including in relation to any guarantees or warranties that we have provided with the goods, services, or digital content.

8.3. Data Security: We take data security seriously. Your personal information is stored securely, and we implement appropriate technical and organizational measures to protect it from unauthorized access, disclosure, alteration, or destruction.

8.4. Access to Retention Policy: You can contact us (using the details at the beginning of this notice) to request a copy of our retention policy, which sets out how long different types of personal data will be kept for.

8.5. Data Portability: If you wish to receive a copy of your personal data held by us or have it transferred to another organization, please contact us, and we will facilitate this process as per applicable data protection laws.

8.6. Data Deletion: If you believe that your personal information is no longer necessary for the purposes for which it was collected, you have the right to request its deletion, subject to any legal obligations we may have to retain certain data.

8.7. Updates to Data Handling Practices: We may update our data storage and handling practices from time to time to ensure compliance with evolving legal requirements. Any significant changes will be communicated to you in accordance with applicable laws.

9. Automated decision making

9.1. ‘Automated decision making’ is where a decision is automatically made without any human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences).

9.2. Data protection laws place restrictions upon us if we carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you.

9.3. We do not carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you. If we do decide to do this then we will notify you and we will inform you of the legal reason we are able to do this.

10. Your rights under data protection law

10.1. Under data protection laws, you have certain rights in relation to your personal information, as follows:

• Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information that we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.
• Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
• Right to erasure: (this is often called the ‘right to be forgotten’).This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
• Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
• Right to data portability: this right allows you to request us to transfer your personal information to someone else.
• Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section 4 above) and there is something about your particular situation that means that you want to object to us processing your personal information. In certain circumstances, you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing).

10.2. In addition to the rights set out in section 10.1, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent. Further details about this are set out in section 4.5.

10.3. If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. If you do make a request, then please note:

• we may need certain information from you so that we can verify your identity;
• we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and
• if your request is unfounded or excessive, then we may refuse to deal with your request.

11. Marketing

11.1. You may receive marketing from us about similar goods and services, where either you have consented to this, or we have another legal reason by which we can contact you for marketing purposes.

11.2. However, we will give you the opportunity to manage how or if we market to you. In any email that we send to you, we provide a link to either unsubscribe or opt out, or to change your marketing preferences. If you have an account with us, you can login to your account and manage your preferences there too. To change your marketing preferences, and/or to request that we stop processing your personal information for marketing purposes, you can always contact us on the details set out at the beginning of this notice.

11.3. If you do request that we stop marketing to you, this will not prevent us from sending communications to you that are not to do with marketing (for example in relation to goods services digital content that you have purchased from us).

11.4. We do not pass your personal information on to any third parties for marketing purposes.

12. Complaints

12.1. If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.

13. Third-party websites

Our website may contain links to third-party websites. If you click and follow those links, then these will take you to the third-party website. Those third-party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them.

14. Contact

You can get hold of us in any of the following ways:

• by emailing us at info@finleyai.com; or
• by writing to us at Inatigo, 20 – 22 Wenlock Road. London N1 7GU