This Privacy Notice explains how we collect, use, and look after your personal data when you use:

• Our website,
• Our mobile applications (including the Say Hello app on the App Store, Google Play Store, and via browser access), and
• Any products or services we provide.

It also explains your privacy rights and how the law protects you.

1. Important Information

• Our website and apps are not intended for children under 16. We do not knowingly collect data from children.
• This Privacy Notice supplements our other notices (including our Terms & Conditions) and does not override them.
• Controller: Add People Limited (“we”, “us”, “our”) is responsible for your personal data.

Data Privacy Manager (DPM) Contact:

• For the attention of: Paul Davies
• Email: technical.support@addpeople.co.uk
• Post: Data Privacy Manager, Add People, 8 Scott Dr, Hale, Altrincham WA15 8AB

You have the right to make a complaint to the Information Commissioner’s Office (ICO) at www.ico.org.uk. However, we ask that you contact us first so we can address your concerns.

Your duty to inform us of changes:
Please keep us updated about changes to your personal data.

Third-party links:
The App may include links to third-party services. We are not responsible for their privacy notices.

2. Data We Collect About You

We collect data to provide and improve the Say Hello app. This includes:

a) Personal Data You Provide

• Name, email, phone number, and company details
• Account credentials, subscription details, preferences
• Marketing and communication preferences

b) Data Generated

• Messages, voicemail recordings, call logs, SMS history processed to generate AI responses
• Metadata such as call time, duration, caller ID, and app usage logs

c) Device & Technical Data

• Device type, operating system, app version, IP address, unique identifiers, crash logs
• Location data, if enabled

d) Permissions

• Microphone access: to process voicemails
• Notifications: to send push alerts about messages or subscription updates
• Storage access (if applicable): to temporarily store AI-processed messages
• You can enable or disable these permissions in your device settings, but some features may not function if disabled

e) Third-Party Data

• Cloud hosting, telephony/SMS providers, analytics platforms
• Publicly available sources (Companies House, credit reference agencies) if relevant

f) Aggregated Data

• Non-identifiable data for analytics, research, and service improvement

3. How We Collect Your Data

• Direct interactions: Account creation, subscribing, surveys, contacting support
• Automated collection: Technical and usage data via the App and cookies
• Communications Data: We process call recordings, voicemails, SMS, and transcriptions handled through the Say Hello app. These may include information relating to your customers. Where we process such data on behalf of our clients, we act as a data processor, and the client is the data controller. Clients are responsible for ensuring they have provided appropriate notice to their customers and have a lawful basis for collecting and processing this data. You have the right to disable call recordings on the Say Hello platform, should you wish to.
• From third parties: Service providers, analytics platforms, publicly available sources

4. How We Use Your Data

We use your personal data to:

• Provide the AI assistant service and subscription functionality
• Process calls, messages, and voicemails
• Manage subscriptions and payments
• Communicate with you about your account, subscription, updates, or support
• Analyse usage to improve services and AI performance
• Comply with legal obligations

Call Recordings and Transcriptions

• Calls handled through Say Hello may be recorded, stored, and transcribed.
• Recordings are processed for service delivery, quality monitoring, dispute resolution, AI training and analytics.
• Recordings and transcriptions are encrypted in transit and at rest.
• Clients must ensure they comply with applicable telecommunication and privacy laws, including notifying callers that calls may be recorded.

Lawful basis:

• Contract: Providing the AI assistant and subscription
• Consent: Optional features like marketing, push notifications, or location services
• Legitimate interests: Analytics, fraud prevention, and service improvement

Marketing:

• Only sent with your consent
• You can withdraw consent anytime via the App or contacting the DPM
• We do not sell personal data for marketing purposes

Change of purpose:

• We will notify you if we need to use your data for a purpose other than that originally collected

5. Sharing Your Data

We may share your personal data with:

• Service providers: Cloud hosting, telephony/SMS, analytics
• Professional advisors: Lawyers, auditors, insurers
• Regulators: HMRC or other legal authorities
• Business transfers: If we merge, sell, or transfer assets

All third parties must comply with data protection laws and protect your personal data.

6. International Transfers

• Some communications data, including call recordings and transcriptions, may be processed by our telephony or hosting providers outside the UK/EEA. Where this occurs, we ensure safeguards such as EU/UK Standard Contractual Clauses or adequacy decisions are in place.

7. Data Security

• Appropriate technical and organisational measures are in place to protect your personal data
• Access is limited to authorised personnel and third-party providers
• Procedures exist to detect and respond to data breaches

8. Data Retention

• Personal and AI-processed data is retained only as long as necessary to provide the service
• Billing and subscription data is kept according to legal/accounting requirements
• Users can request deletion of their account and personal data
• Aggregated or anonymised data may be retained indefinitely

9. AI Processing & Automation

• AI processes messages, voicemails, and calls to generate automated responses
• Users are responsible for compliance with applicable laws for messages sent via AI
• AI may make errors; we are not liable for missed, delayed, or incorrect responses beyond our general liability limits

10. Your Rights

You have rights under data protection law, including:

• Access, correction, erasure, object, restrict processing, data portability, withdraw consent

Requests can be submitted to the DPM.

11. Cookies & Tracking

• The App may use cookies or similar technology for analytics and performance
• You may disable cookies via device or browser settings, but some features may be affected

12. Children

• The App is not intended for children under 16
• We do not knowingly collect data from children

13. Changes to This Privacy Policy

• We may update this Privacy Policy from time to time
• Significant changes will be communicated via the App or email

14. Contact

Add People Ltd
8 Scott Dr, Hale, Altrincham WA15 8AB
Email: technical.support@addpeople.co.uk

Schedule 1

Part 1 – Types of personal data

(see Section 2 above for full list: Identity, Contact, Financial, Transaction, Technical, Profile, Usage, Location, Media, Marketing, Aggregated).

Part 2 – Lawful basis for processing and activities

Part 3 – Your legal rights

In addition to your rights under law, you may also:

• Disable push notifications via device or app settings.
• Revoke permissions (camera, microphone, location, photos) through your device settings at any time.
• Request deletion of in-app content you have shared (e.g. photos, videos, messages).

Part 4 – Third parties

We may share personal data with:

• Service providers – IT, cloud hosting, app hosting, and system administration.
• Analytics & crash reporting providers – e.g. Google Analytics, Firebase, Crashlytics, Mixpanel.
• Payment processors – for in-app purchases or subscriptions.
• Professional advisers – lawyers, accountants, insurers.
• Regulators and authorities – HMRC, ICO, or others as required by law.
• Business transfers – in the event of a sale, merger or restructuring.

Part 5 – Glossary

• Aggregated Data – statistical or demographic data derived from personal data but not identifying you.
• Controller – the person or body that decides how and why personal data is used.
• Data Subject – an individual identified by personal data (you).
• Personal Data – information that identifies you directly or indirectly.
• Processor – a person or organisation that processes data on behalf of a controller.
• SDK (Software Development Kit) – third-party code built into apps to enable analytics, crash reporting, and other features.
• Device Identifier – a unique number linked to your mobile device (such as Apple’s IDFA or Google’s GAID).
• Special Categories of Personal Data – sensitive data such as health, religion, political opinions (not collected by us).
• ICO – Information Commissioner’s Office, the UK data protection regulator.