Privacy Policy

Effective date: 1 January 2026  ·  Version 1.0

⚠ Draft — Replace with your finalised legal text This page is a structural skeleton for a UK GDPR-compliant privacy notice. The section structure and data category tables reflect common SaaS/API platform practices; however, the body text must be reviewed and approved by your legal counsel and a qualified DPO before this page goes live.

Contents

  1. Who We Are
  2. What Data We Collect
  3. How We Use Your Data
  4. Legal Basis for Processing
  5. Third Parties and Data Sharing
  6. International Transfers
  7. Data Retention
  8. Security
  9. Your Rights
  10. Cookies
  11. Children's Privacy
  12. Changes to This Policy
  13. Contact & Complaints

1. Who We Are

1FRX Ltd ("1FRX", "we", "us", "our") is the data controller responsible for your personal data in connection with the 1FRX platform and services. We are registered in England and Wales.

[PLACEHOLDER — Company registration number, registered address, ICO registration number.]

Questions or requests relating to this Privacy Policy should be sent to hello@1frx.com.

2. What Data We Collect

We collect the following categories of data, depending on how you interact with us:

Category Examples Source
Account data Name, email address, company name, billing address Provided directly by you on sign-up
Authentication data Hashed passwords, API key identifiers (not raw keys) Generated on account creation
Usage data API call timestamps, endpoint called, response codes, credit consumption Automatically collected during API use
Technical data IP address, browser type, device OS, referring URL Automatically collected via server logs and analytics
Payment data Last 4 digits, card type, billing postcode Provided by payment processor (we do not store full card numbers)
Content data Prompts, uploaded documents, configuration inputs submitted to the API Provided directly by you during API use
Communications data Emails, support messages Provided directly by you
Camera and voice data (Aria / video call features): If you use the voice assistant or video call features, your microphone and camera may be accessed in your browser. Audio frames are processed in real time for voice recognition and are not stored or logged after processing. Camera frames used for contextual awareness are discarded immediately after analysis.

3. How We Use Your Data

We use your data for the following purposes:

PurposeLegal basis
Providing the contracted ServicesPerformance of a contract (Art. 6(1)(b))
Billing and financial recordsLegal obligation (Art. 6(1)(c))
Security, fraud preventionLegitimate interests (Art. 6(1)(f))
Product analytics (aggregated)Legitimate interests (Art. 6(1)(f))
Marketing emails (opted-in)Consent (Art. 6(1)(a))
Marketing emails (existing customers)Legitimate interests (Art. 6(1)(f)), subject to soft opt-out

5. Third Parties and Data Sharing

We do not sell your personal data. We may share data with the following categories of third parties as necessary to operate the platform:

6. International Transfers

Some of our service providers are located outside the UK and EEA. Where data is transferred internationally, we ensure that appropriate safeguards are in place, such as the UK International Data Transfer Agreement (IDTA) or equivalent standard contractual clauses. [PLACEHOLDER — list specific countries/regions if known.]

7. Data Retention

Data typeRetention period
Account dataDuration of account + [X years] after deletion
API usage logs[90 days] rolling
Billing records7 years (UK legal requirement)
Support correspondence[2 years] from last interaction
Voice / camera framesNot retained — processed in real time and discarded
Submitted content (prompts, documents)[PLACEHOLDER — state whether you retain these and for how long]

8. Security

We implement appropriate technical and organisational measures to protect your data, including:

No transmission over the internet is 100% secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and affected individuals without undue delay where required.

9. Your Rights

Under the UK GDPR, you have the following rights with respect to your personal data:

Access Request a copy of the personal data we hold about you.
Rectification Request correction of inaccurate or incomplete data.
Erasure Request deletion of your data where there is no lawful reason to retain it.
Restriction Request that we limit the processing of your data in certain circumstances.
Portability Receive your data in a structured, machine-readable format.
Object Object to processing based on legitimate interests or for direct marketing.
Withdraw consent Where processing is based on consent, withdraw it at any time.
Automated decisions Not be subject to solely automated decisions that significantly affect you.

To exercise any of these rights, email hello@1frx.com. We will respond within one calendar month. We may ask you to verify your identity before processing the request.

10. Cookies

We use cookies and similar tracking technologies as follows:

CookieTypePurpose
sessionStrictly necessaryMaintains your authenticated session.
[PLACEHOLDER]AnalyticsAggregated, anonymised usage statistics.

Strictly necessary cookies cannot be disabled without impacting the functionality of the Services. Analytics cookies require your consent where applicable.

11. Children's Privacy

The Services are not directed at persons under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at hello@1frx.com and we will delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the effective date above and notify account holders by email at least 14 days before the changes take effect. The current version is always available at 1frx.com/privacy.html.

13. Contact & Complaints

For privacy-related queries or to exercise your rights:

If you are not satisfied with how we handle your request, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.