Privacy Policy
This privacy notice for Access4 Limited (company number 15351856), whose registered office is at Fourth Floor, The Tower, Deva City Office Park, Trinity Way, Salford M3 7BD (‘Company‘, ‘we‘, ‘us‘, or ‘our’), describes how and why we might collect, store, use, and/or share (‘process‘) your information when you use our services (‘Services‘), such as when you:
- Visit our website or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact the privacy officer at privacy@access4.com
Some of what we offer – including our AIX products and services – is AI-enabled, meaning it uses artificial intelligence, machine learning and automated processing to handle interactions and generate responses. This privacy notice applies to personal information handled through those Services in the same way as it applies to our other products and services.
Our role. We act as a controller in respect of the personal information we process for our own purposes, such as operating our website, managing our customer and supplier relationships, and marketing our products and services. In some cases, in particular where we provide our AIX products and services to our partners and their customers, we act as a processor or sub-processor and process personal information on the instructions of the relevant partner or customer, who is the controller for that processing. Where we act as a processor or sub-processor, the controller’s own privacy notice governs that processing and you should direct any request to exercise your rights to that controller. This privacy notice describes how we handle personal information where we act as a controller, and the sections below on our legal bases for processing and your privacy rights apply in that context.
Where we act as a processor or sub-processor for one of our partners, our processing of personal information on that partner’s behalf is governed by our Data Processing Addendum (DPA), which is available on our website. The DPA forms the data protection terms between us and the partner and is incorporated into the partner’s contract with us. This privacy notice describes our data-handling practices and does not vary the DPA; to the extent of any inconsistency between this notice and the DPA in relation to that processing, the DPA prevails.
Summary of Key Points
This summary provides key points from our privacy notice, but you can find out more in the full sections below.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any special category data? Our AI-enabled Services are not designed to collect special category data (sometimes referred to as sensitive personal data), such as data concerning health or biometric data used to identify you. We will only process such data where the law permits and any required conditions, consents, approvals and safeguards are in place.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by contacting us at privacy@access4.com . We will consider and act upon any request in accordance with applicable data protection laws.
What Information Do We Collect?
Personal information you disclose to us.
We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
We collect personal Information from Business Partners. We may receive information from our business partners, such as joint marketing partners or resellers, to enhance our service offerings and marketing efforts.
We collect personal Information from Social Media Platforms and Networks. We may collect information from social media platforms and networks if you interact with us through these channels. This may include your profile information, interactions, and any information you make public on these platforms.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- phone numbers
- email addresses
- job titles
- contact preferences
Information related to job applications. If you apply for a job with us, we collect personal information necessary to process your application, such as your resume, contact information, and employment history.
Special Category Data.
Our AI-enabled Services are not designed to collect special category data (sometimes referred to as sensitive personal data), such as data concerning health or biometric data used to identify an individual. They are also not designed to collect payment card or financial account data, or information about children. We will only process special category data through those Services where a condition under Article 9 of the UK GDPR applies and, where required, your explicit consent has been obtained, we have approved the relevant use case in writing, and any authorisations and safeguards required by us and our suppliers are in place. Where such data is provided to us without the necessary conditions, consents, approvals or safeguards, we may remove or delete it, unless we are required to retain it by law.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected.
Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Device data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Our mobile app Snap HD shares phone numbers and email addresses; phone numbers are shared in order to place a call and email addresses in order to display the Gravatar.
Phone numbers (users’ contact list phone numbers). These are collected only if the user allows it by accepting the in-app disclosure message. If accepted, the numbers are shared only to our API in order to establish a call.
Email addresses (users’ contact list email addresses). These are collected for all contacts in the list only if allowed via settings and configs. The app shares the MD5 hash of the email address with Gravatar in order to provide avatar images.
AIX products and services data. Where you interact with our AIX products and services, we (and our supplier) collect voice and call recordings and transcripts, the content of your messages, calls and enquiries, and related metadata such as call time, duration and interaction logs. We use this data to handle and respond to interactions, generate summaries and structured records, and to provide, support, secure and improve the Services, as further described below.
How Do We Process Your Information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To administer programs. We may process your information to effectively manage and administer programs that you are enrolled in or have shown interest in.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see ‘WHAT ARE YOUR PRIVACY RIGHTS?’ below.
For personalisation. We may process your information to personalise your experience with our Services, tailoring content and recommendations to better suit your preferences.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
De-identified and aggregated data.
Notwithstanding the above, we may create and use de-identified, aggregated or schema-level data derived from customer usage and feature-adoption data that does not identify, and is not reasonably capable of identifying, any individual. We use such data to operate, support, secure and improve our Services and to produce analytics, reporting and volume-based or other statistical insights. In particular, we may process this data to generate internal business insights and to identify product and service opportunities that we may share with our channel partners. This processing is carried out at an aggregate level only and is not used to profile, or to conduct direct marketing to, individual customers or end users.
Use of third-party AI tools.
To generate these insights, we may process de-identified, aggregated or schema-level data using third-party artificial intelligence tools, including large language models (LLMs). Providers of these AI and LLM tools act as technology and infrastructure recipients (including cloud hosting and data-processing providers and, where applicable, sub-processors) engaged to help us operate and deliver our Services, and are described in the third-party recipient categories set out in the section ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?’ below. Because this processing uses only de-identified, aggregated or schema-level data that does not contain personal information, it operates at an aggregate level and not at the level of any identifiable individual.
Automated processing and AI-enabled services. As noted above, some of our Services, including our AIX products and services, are AI-enabled and use automated processing to handle interactions and generate responses, summaries and structured records. These systems operate probabilistically and may produce inaccurate, incomplete or unintended outputs and, where enabled, may take automated actions such as making, altering or cancelling bookings or appointments. Our AI-enabled Services do not make legally binding decisions about individuals.
AI system disclosure and recording of communications. Where you interact with our AIX products and services, you will be informed that you are interacting with an AI system and not a human, and that communications may be recorded, monitored, transcribed and processed to provide and support the Services. Such communications, including voice recordings and transcripts, may be shared with our supplier and its artificial intelligence or large language model (LLM) providers for these purposes. Where we provide these Services to our partners and their customers, the relevant partner or customer acts as the controller for those interactions and is responsible for providing the required notices to, and obtaining any consents required by law from, end users (including for the recording and monitoring of communications); we process this information as a processor or sub-processor on their instructions under the applicable data processing terms.
Use of data for AI training. We do not use data handled through our AI-enabled Services to train or fine-tune general AI models outside the service environment in which it was collected. We may use de-identified, aggregated or schema-level data that does not identify any individual to improve system performance, configuration and accuracy, to produce aggregated analytics, and to detect systemic issues or misuse. No personal information is intentionally retained in any training datasets used outside your service instance. Our upstream vendors and suppliers do not use personal data handled through our AI-enabled Services to train or improve their own general AI models, other than as necessary to provide and support the Services to us. Where we rely on supplier settings or contractual commitments to give effect to this, we maintain those controls.
What Legal Bases Do We Rely On To Process Your Information?
We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal bases) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
For core business functions. We may process your information to support our core business functions, including business management, operational reporting, and compliance monitoring.
The General Data Protection Regulation (GDPR) and UK GDPR requires us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services
- Analyse how our services are used so we can improve them to engage and retain users
- Support our marketing activities
- Understand how our users use our products and services so we can improve user experience
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
When and With Whom Do We Share Your Personal Information?
We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Service Providers, Sub-Processors and AI/LLM Providers. We may share your information with third-party technology and infrastructure providers (including cloud hosting and data-processing providers) and, in relation to our AIX products and services, with our supplier and its artificial intelligence and large language model (LLM) providers, who process the information as our processors or sub-processors to help us operate, deliver, secure and support our Services. We require these providers to maintain appropriate security measures and to impose substantially equivalent obligations on their own sub-processors.
- Affiliates. We may share your information with, and allow it to be accessed and processed by, our affiliates and group companies (which include entities in Australia and New Zealand), in which case we will require them to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us, and we and our group operate certain shared systems, infrastructure and support functions across these entities. We store and process your personal information primarily on servers in the United Kingdom (UK), but it may be accessed, stored or processed by our affiliates, suppliers and sub-processors in other countries outside the UK for the purposes described in this Privacy Policy. Any such transfers outside the UK are subject to the safeguards described in the section ‘HOW DO WE KEEP YOUR INFORMATION SAFE?’ below.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
- We do not sell your personal information.
Cookies and Other Tracking Technologies
We may use cookies and other tracking technologies to collect and store your information.
Cookies are identifiers we transfer to your browser or device that allow us to recognise your browser or device and tell us how and when pages and features in our services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.
How long do we keep your information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
How do we keep your information safe?
We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In cases where we transfer your personal information to countries outside of the UK – including to our group companies, suppliers and sub-processors – we ensure that such transfers are made on the basis of UK adequacy regulations or, where these do not apply, appropriate safeguards required by the UK GDPR, such as the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU standard contractual clauses.
We store AIX voice recordings and transcripts on servers located in the UK. Where you use our AI-enabled Services, however, your information may be processed – but not stored – by our supplier and its sub-processors (including third-party large language model and voice-processing providers) located outside the UK, for purposes such as converting speech to text and text to speech and generating responses. Any such transfers are subject to the safeguards described above.
Do we collect information from minors?
Our services are not intended for children under the age of 18. We do not knowingly collect data from or market to children under 18 years of age.
By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@access4.com
What are your privacy rights?
In some regions, such as the European Economic Area (EEA) and the UK, you have rights that allow you greater access to and control over your personal information, as described below. This section concerns your data protection rights only and does not affect the term, termination or other provisions of any contract between you and us for our products or services, which continue to govern your account and service commitments.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ico.org.uk/
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
If you have questions or comments about your privacy rights, you may email us at privacy@access4.com
Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and applications include a ‘Do Not Track’ (DNT) setting that you can enable to signal your preference not to be tracked online. However, there is currently no universally accepted standard for recognising or responding to DNT signals, and as a result, many websites and services do not respond to them.
Do We Make Updates to This Notice?
Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Last updated’ date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may email us at privacy@access4.com or by post to:
Access4 Limited – Fourth Floor, The Tower, Deva City Office Park, Trinity Way, Salford M3 7BD
How Can You Review, Update, Or Delete the Data We Collect From You?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email us at privacy@access4.com
Last updated: August 2026