Privacy Notice

While at this stage it is not intended that any information used to prompt the GB1 chatbot will be retained, you should still be careful not to input any sensitive personal information, or information which might be commercially or personally damaging if it were to be disclosed. Some information, if you choose to provide it when configuring the chatbot, may be collected, stored and otherwise processed, in which case such processing will occur in accordance with this policy.

Thank you for taking the time to read our privacy notice. This explains what we do with any personal data you input during the onboarding process for our chatbot GB1, when you provide your contact details for us to communicate with you, call our offices, or purchase a product or service.

It is important that you read this privacy notice carefully. It includes explanations for some of the specialised terms we use (like "personal data" and "processing", as well as information which is relevant to you and the information you are providing to us. If you have any questions, you can contact us on the details given below.

PLEASE NOTE: This notice deals with the position where we (Locai Labs) are the controller of your information. Although this means that we remain responsible for your personal data, for your reassurance our personnel have no access to the data processed by the AI tools which we develop, and those tools are designed to protect privacy and limit the spread of personal data. This includes having in place robust encryption to the protect the data that is entrusted to us, and rules which require data to be made anonymous and/or deleted as soon as possible after it has been used by the tool.

1. What is GB1?

Locai Labs is launching an AI chatbot called GB1. GB1 is intended to be a UK sovereign chatbot, with outputs reflecting the languages of the British Isles, and trained on a corpus of information about Britishness, British information, and cultural norms.

2. Important Information and Who We Are

Locai Labs Limited is the controller of any personal data that you provide to us, which means that we are responsible for that personal data, including what it is used for and how it is used and protected. In this document we explain what decisions we have taken about how we use your personal data, and what rights you have as a result.

We have appointed someone to be specifically responsible for how personal data is used within the business. At the moment, that is our CEO and co-founder, James Drayson. If you have any questions about this privacy notice or our data protection practices, please contact James using the details below.

3. The Data We Collect About You

If we have access to information which would allow us to identify you (either on its own, or when combined with other information) or which tells us anything about your individual activities or characteristics, that is "personal data". Personal data does not include data which cannot be connected to an identifiable individual (anonymous data).

There are different types of personal data about you which we might collect, use, store, or transfer. We have grouped these together as follows, and provided some illustrations of the type of personal data which might fall into each grouping:

• Identity Data could include your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth or gender
• Contact Data could include your address, email address, telephone numbers or another unique identifier for use with electronic communications such as instant messaging
• Financial Data could include bank account and payment card details
• Transaction Data could include details about payments to and from you and other details of products and services you have purchased from us
• Technical Data could include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and information about other technology on the devices you use to access this chatbot
• Profile Data could include your username, name, email address and password, purchases, or orders made by you, your interests, preferences, feedback, and survey responses
• Voice Recording Data could include digital recordings of your voice from calls to our offices that are captured and analysed by our conversational AI system, including transcripts of those voice recordings
• Marketing and Communications Data could include your preferences in receiving marketing from us and your communication preferences.

We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We will not use the personal data that we do collect about you to make inferences about any of those special categories of personal data. Please do not input this data into the chatbot or during the onboarding process.

4. If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services), or we may not be able to comply with one of our legal obligations. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time, if we can.

5. How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • ask for information about our products or services;
  • create an account to use our chatbot;
  • request marketing to be sent to you;
  • or give us feedback or contact us.
• Automated technologies or interactions. If you call our offices, your voice may be recorded and stored by a third-party VoIP provider or by our conversational AI tools. These will generate a text transcript of the words you speak when interacting with the provider or our conversational AI (your Voice Recording Data) and we do not retain any recording of the actual audio of your call with us. You will hear a warning to let you know that any information you provide on the call is being recorded and processed in this way.
• Generated Data. We may generate Transaction, Usage, Marketing and Communications Data about you, by way of records of the direct and automated interactions that you have with us.
• Data stored in the chat. Old conversations will be saved for you to return to and therefore any personal data you choose to input into the chatbot will be stored there (please note the general recommendation, above, that personal information, and in particular any sensitive personal information, should not be input into the chatbot).

Data input into the chatbot will be subject to automated and human review to ensure compliance with terms of use, and any responsible use policy, as well as ensuring that personal data is not included in any material which is used for training or refinement. Where possible, we intend to give you control of whether or not we process your data in this way, by allowing you to opt in. Please note, however, that this will not result in the processing of such data being on the basis of consent – once given, it will not be possible for your permission to be revoked, or for material once used to train or refine future models to thereafter be extracted or erased from the corpus of information available to that model.

6. How We Use Your Personal Data

PLEASE NOTE, WE WILL NOT COLLECT PERSONAL DATA ABOUT OUR USERS FOR THE PURPOSES OF TRAINING FUTURE MODELS OR REFINING THE CURRENT ONES EXCEPT WHERE YOU HAVE SPECIFICALLY AGREED TO ALLOW US TO DO SO, AS DETAILED ABOVE.

We will only use your personal data for the purpose for which we collected it which include the following:

7. How We Share Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• External Third Parties, including GCP and Linkup, who provide or host the conversational or analytical AI tools and associated databases that we use to provide the GB1 chatbot.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. International Transfers

We do not currently intend, to store your personal data outside the United Kingdom. Our handling of personal data, wherever it is submitted from, is undertaken in accordance with the requirement of UK data protection law (including the UK GDPR and Data Protection Act 2018). It is your responsibility to ensure that any use you make of our system is lawful under the laws of the country in which you are located (where this is not the UK). If, at any time, we do make a transfer of your personal data to, and/or otherwise cause there to be processing of your personal data by, a recipient in another country, we will ensure that the recipient is:

• either located in a country in relation to which the relevant UK Secretary of State (for the purposes of the UK GDPR and the Data Protection Act 2018) has made a finding of adequacy which is either unconditional, or conditional on other factors which we are satisfied have been complied with (such as, in the case of transfers to a recipient in the United States, the recipient's confirmation of their compliance with the US-UK data bridge requirements), in connection with its data protection regime; or
• where no finding of adequacy has been made in relation to that country, subject to adequate safeguards which will be documented in a data sharing agreement using the model clauses approved by the UK Government and the Information Commissioner's Office in relation to such international data transfers.

Some of our third-party processors or sub-processors may be located outside of the UK, and if so, we will enter into agreements with them to ensure that their handling of your personal data is undertaken in a compliant manner, consistently with the commitments given above.

9. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data Retention

We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

This section 10 does not apply to any personal data you choose to enter into the chatbot. We have no intention to collect or otherwise process such data, other than by storing it as noted above in the history of previous prompts. Nonetheless, if ever such data is retained and becomes incorporated into the corpus of information on which the chatbot or its underlying model are trained, it may not be possible to effectively erase such information, and we would not be able to guarantee that it might not resurface in response to a future prompt by you, or another user.

11. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk). These rights include the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Rights in respect of automated processing of your personal data. We do not use automated technologies, such as our conversational AI tool, to make any decisions which might impact you. The technologies are, however, used to support human-led decision making about, for example, the priority in which incoming calls are picked up or responded to. If you consider that the automated component of this processing has caused you any prejudice as a result of your personal circumstances or other individual characteristics, please contact us so that we can investigate this further and address this.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

While this section 11 does apply to any personal data you inadvertently enter into the chatbot, please be aware that for the reasons set out in the warning above it may be impossible to give effect to the rights set out in this section in relation to personal data which has been inadvertently ingested into our chatbot training model.

NO FEE USUALLY REQUIRED: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.