Last updated: March 25, 2025

General Data Protection Regulation (UK GDPR) Compliant

This Privacy Policy explains how 3a-AI ("we", "our", or "the Company") collects, uses, shares, and protects personal data when providing AI chatbot services to clients and subscribers, and when users interact with our website. We are committed to safeguarding personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are and What We Do

3A-AI Ltd provides AI chatbot and agent solutions and services to property owners, managers, and individual subscribers with a focus on supporting communication and customer service for independent living and related property management sectors.
We act as:

• - A Data Controller when we collect and use personal data for our own purposes, such as from website visitors, newsletter subscribers, and direct customers.

• - A Data Processor when we process personal data on behalf of our clients through our chatbot services. In these cases, the client is the Data Controller..

2. Personal Data We Collect

When you visit our website or engage with us directly, we may collect:

• - Name
  - Email Address

This is primarily for account setup, support, and business communications.

When chatbots process data on behalf of clients, we may process:

- Any personal information voluntarily shared by users (e.g., name, apartment number, service queries, or other identifiers).

Such data may be temporarily retained to deliver services and enhance user experience.

3. Purpose and Legal Basis for Processing

We process personal data based on the following lawful bases:

• - Your consent (e.g., signing up via our website);

• - To fulfil a contract (e.g., providing services to clients or subscribers);

• - Legitimate interests (e.g., for business operations and service improvement);

• - Legal obligations (e.g., where required by UK law).

4. Data Retention

• - Personal data collected for sales and marketing purposes may be retained for several years to maintain business relationships.

• - Personal data processed on behalf of clients via the chatbot will be retained short-term (e.g., for service delivery or support purposes), after which it is securely deleted or anonymised.

• - Data used for analytics is fully anonymised.

5. Data Sharing & Sub-Processors We do not sell or lease your personal data.

We may share data with trusted third-party service providers (sub-processors) to deliver our services. All sub-processors are GDPR-compliant, and data remains hosted within the UK/EU only.

6. When We Act as a Data Processor

When we provide chatbot services to clients:

• - Clients are the Data Controllers and are responsible for ensuring that their end-users (e.g., residents or customers) are informed about how their personal data will be processed by the chatbot.

• - Clients must ensure that their users are provided with an appropriate privacy notice explaining the chatbot's data processing activities.

• - Clients should not instruct us to process any data unlawfully or in breach of data protection regulations.

6A. No Ownership of User Content

We do not claim ownership over any text, media, or other content you submit to our chatbots. All intellectual property rights in such content remain with the original owner or the party who has legitimately licensed those rights.

7. Security Measures

We implement appropriate technical and organisational measures to safeguard personal data, including:

• - Secure data storage and encryption

• - Access controls and employee confidentiality agreements

• - Regular data protection audits Incident response protocols for data breaches

8. International Data Transfers

All personal data is processed and stored within the United Kingdom and European Union. We do not transfer personal data outside of these regions.

9. Cookies and Website Analytics

We use cookies to improve website functionality and gather analytics data (e.g., via Google Analytics). For details on specific cookies, please review our Cookie Policy. You can manage or disable cookies via your browser settings.

10. Your Data Protection Rights

If you wish to exercise any of your data protection rights, please note:

• - When 3A-AI is the Data Controller (e.g. for website visitors or newsletter subscribers), you can contact us directly.

• - When we act as a Data Processor, you should contact the relevant client acting as the Data Controller. We will assist them with fulfilling your request where required.

As a data subject, you have the right to:

• - Request access to your personal data

• - Request correction or deletion of your personal data

• - Object to or restrict processing

• - Withdraw consent at any time (where consent is the basis of processing)

• - Data portability

• - Lodge a complaint with the UK Information Commissioner’s Office (ICO) if you believe your rights have been infringed

11. Profiling & Automated Decision-Making

We do not engage in profiling or automated decision-making that could produce legal or significant effects on individuals.

12. Contact Details

For any privacy-related queries or to exercise your rights, please contact our Data Protection Officer: Email: [email protected]

13. Updates to this Privacy Policy

We may update this policy from time to time. Please review periodically to stay informed.