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Privacy Policy

Effective Date: 11 August 2026

Last Updated: 11 August 2026

1. Introduction

Refluent AI Ltd ("Refluent AI", "we", "our", "us") is committed to protecting your privacy and handling personal data lawfully, fairly and transparently.

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We operate an AI voice automation platform that provides businesses with an AI Receptionist (inbound call handling) and AI Outreach (outbound calling) service, primarily for home-services and trades businesses.

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This Privacy Policy explains how we collect, use, store, share and protect personal data when you use our website, products and services. It is written to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).

2. Who We Are and Our Role

Data Controller: Refluent AI Ltd Registered address: Amba House, 15 College Road, Harrow, England, HA1 1BA Company number: 16708045 ICO registration number: ZC237093 Contact: privacy@refluentai.com

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Our role in relation to your data depends on the context:

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  • As a Controller — for data about our own website visitors, account holders, prospects and business contacts, we decide how and why the data is processed.

  • As a Processor — when we handle calls, recordings and end-customer data on behalf of a business client using our platform, that business is the Data Controller and we act as their Processor under a Data Processing Agreement (DPA). In those cases, the business client's own privacy policy governs how that data is used, and individuals should direct requests to that business.

3. Information We Collect

a. Personal Information

  • Name, email address, phone number

  • Business details (company name, industry, role)

  • Account login credentials

  • Billing and payment information

b. Usage Data

  • IP address, browser type, device information

  • Pages visited, time spent, and interaction data

c. Call and Communication Data 

As part of our AI voice platform, we may process:

  • Call audio recordings

  • Call transcripts

  • Caller telephone numbers and metadata (time, duration, outcome)

  • Bookings, enquiries and other information shared during a call

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Where this data relates to the customers or callers of a business using our platform, we process it as that business's Processor (see Section 2).

4. Lawful Bases for Processing

We rely on the following lawful bases under UK GDPR:

  • Contract — to provide our services to account holders and process billing.

  • Legitimate interests — to operate, secure and improve our platform, and to conduct business-to-business communications, balanced against your rights.

  • Consent — where required, for example certain outbound marketing calls and non-essential cookies. You may withdraw consent at any time.

  • Legal obligation — where we must retain or disclose data to comply with the law.

5. AI Voice Calls and Recording

  • Our platform uses automated AI voice agents to place and receive calls on behalf of businesses.

  • At the start of interactions, the AI agent identifies itself as an automated/AI voice assistant.

  • Calls may be recorded and transcribed for service delivery, quality, training and record-keeping. Callers are notified that calls may be recorded, and recording is carried out in line with the instructions of the relevant business Controller.

6. Outbound Calling and Consent (PECR)

Where our platform is used for outbound calls:

  • Calls are placed only to contacts who have a lawful basis to be contacted — for example an existing business relationship, a prior enquiry, or valid consent.

  • We and our business clients are responsible for screening against the Telephone Preference Service (TPS) / Corporate TPS (CTPS) where applicable.

  • Recipients may opt out of further calls at any time by telling the AI agent, or by contacting privacy@refluentai.com. Opt-out requests are actioned promptly.

7. How We Use Your Information

We use personal data to:

  • Provide, operate and improve our AI voice services

  • Automate customer interactions (calls, bookings, follow-ups) on behalf of business clients

  • Manage accounts, billing and customer support

  • Send service updates and notifications

  • Analyse performance and generate insights

  • Maintain the security and integrity of our platform

  • Comply with legal and regulatory obligations

8. Data Sharing and Sub-Processors

We do not sell your personal data.

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We share data with:

  • Trusted sub-processors and service providers who help us deliver our services, including telephony providers (e.g. Twilio), cloud hosting and infrastructure, AI/voice model providers, billing providers, and CRM and analytics tools. These parties are bound by contract to protect your data and process it only on our instructions.

  • Legal and regulatory authorities where required by law.

  • A business client's authorised users, where we act as their Processor.

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A current list of sub-processors is available on request from privacy @refluentai.com.

9. International Data Transfers

Some of our sub-processors may process data outside the UK/EEA. Where they do, we ensure appropriate safeguards are in place, such as UK adequacy regulations, the International Data Transfer Agreement (IDTA), or Standard Contractual Clauses.

10. Data Storage and Security

We use secure cloud infrastructure and industry-standard safeguards, including:

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  • Encryption in transit and at rest

  • Access control and authentication

  • Regular security monitoring

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While we take reasonable steps to protect your data, no method of transmission or storage is completely secure.

11. Data Retention

We retain personal data only as long as necessary to:

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  • Provide our services

  • Meet legal, accounting and regulatory obligations

  • Resolve disputes and enforce agreements

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Call recordings and transcripts are retained in line with our agreements with business clients and are then deleted or anonymised. You may request deletion at any time (subject to Section 2, where a business client is the Controller).

12. Your Rights

Under UK GDPR you have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request erasure ("right to be forgotten")

  • Restrict or object to processing

  • Data portability

  • Withdraw consent where processing is based on consent

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To exercise your rights, contact privacy @refluentai.com. Where we act as a Processor for a business client, we will direct your request to that Controller.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

13. Cookies

We use cookies to:

  • Improve website performance

  • Analyse user behaviour

  • Enhance user experience

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You can control or disable cookies via your browser settings. Non-essential cookies are set only with your consent.

​14. Third-Party Integrations

Our platform integrates with tools such as CRM systems, calendars and communication platforms. These services have their own privacy policies, and we encourage you to review them.

15. Children's Privacy

Our services are intended for businesses and are not directed at children under 16. We do not knowingly collect data from children.

16. Updates to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with a revised effective date.

17. Contact Us

If you have questions or concerns about this Privacy Policy or your data:

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Refluent AI Ltd Email: privacy @refluentai.com Amba House, 15 College Road, Harrow, England, HA1 1BA

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