Draft for review. This document is a plain English draft and has not yet been approved by a solicitor. It may change before it is final.
Privacy policy
Last updated 26 October 2026.
Who we are
This policy is from Cygnoverse Ltd (company number 16560846, registered in England and Wales), registered office 70 Wembley Hill Road, Wembley, HA9 8EA ("Cygnoverse", "we", "us"). We are the controller for personal data about our own customers, website visitors and people who contact us. You can reach us at hello@cygnoverse.com.
When a business uses Cygnoverse to talk to its own customers, that business is the controller of its customers' data and we process it on its behalf as a processor, under our terms and a data processing agreement.
What we collect
- Account details: name, email, business name, password (stored as a secure hash) and two factor settings.
- Billing details: packages, AI credit top ups, itemised usage and balance. Card details are collected and held by Stripe, not by us.
- Service content: products, policies, conversations, orders, bookings, contacts and files that you or your customers add.
- Technical data: IP address, device and browser information and logs needed to run and secure the service.
- Messages you send us, for example through the contact form or by email.
How we use it and why
- To provide the service you signed up for (contract).
- To take payments, keep accounts and meet tax and legal duties (legal obligation).
- To keep the service secure, prevent fraud and improve reliability (legitimate interests).
- To send service messages such as low credit or security alerts (contract and legitimate interests).
- To send marketing only where you have agreed or where the law allows a soft opt in, with an easy way to unsubscribe (consent or legitimate interests, under PECR).
AI providers and international transfers
AI replies are generated by third party AI providers, currently including DeepSeek. To generate a reply we send the relevant conversation text and the business content needed to answer it. These providers may process data outside the UK, including in countries that do not have UK adequacy regulations. Where that happens we rely on appropriate safeguards such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, and we limit what is shared to what is needed.
[To confirm before publishing: the full list of AI providers, where each processes data, whether any provider retains data or uses it for training, and the transfer mechanism in place for each.]
Who else we share data with
We use carefully chosen service providers to run Cygnoverse, including hosting, email delivery, payments (Stripe), telephony (Twilio, for Voice AI) and messaging platforms such as Meta when those channels are enabled. They may only use data to provide their service to us. We do not sell personal data.
How long we keep it
We keep account data for as long as your account is open and for up to 6 years afterwards where needed for tax, accounting or legal claims. Service content is kept while your account is active and deleted or returned when you close it, subject to backups that expire on a rolling basis. [Retention periods to be confirmed.]
Your rights
You have the right to access, correct, delete or restrict the use of your personal data, to object to certain uses, to data portability and to withdraw consent at any time. Email hello@cygnoverse.com. If your data was collected by a business using Cygnoverse, contact that business first and we will help them respond.
You can complain to the Information Commissioner's Office at ico.org.uk. We would appreciate the chance to put things right first.
Security
We use encryption in transit and at rest, two factor authentication and access controls. See our security page.
Cookies
This website does not use analytics or advertising cookies. See our cookie policy.
Changes
We will update this policy when our practices change and show the date at the top. Significant changes will be notified to account holders by email.