PRIVACY POLICY OF FICIENTAI

1. INTRODUCTION

FicientAI is committed to protecting the privacy of its users and ensuring the security of their personal data. This policy outlines how we collect, use, store, and protect personal information in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and applicable US privacy laws (where relevant).

2. WHAT IS FICIENTAI AND HOW IT WORKS

FicientAI provides an AI-powered marketing and lead reactivation platform, accessible through our website and services, enabling businesses (our Business Users) to:

▪️Reactivate and engage existing customer databases

▪️Automate follow-up communication with leads and customers

▪️Optimise client engagement and operational efficiency

▪️Analyse customer behaviour and feedback

Our Business Model and Data Processing

FicientAI primarily acts as a Data Processor on behalf of our Business Users (e.g., service-based businesses such as private healthcare, cosmetic clinics, coaching businesses, home improvement services). This means that when our Business Users utilise our platform to reactivate customer leads or send marketing communications, we process the personal data of those customers (the "End Customer Data") according to the instructions and under the authority of our Business Users. Our platform automates communications via email, SMS, and other channels.

FicientAI also acts as a Data Controller for:

▪️Business User Data: The personal data of individuals who register and use our platform as representatives of businesses (e.g., name, email, business details, payment information).

▪️Site Visitors: Limited technical data from visitors to our website (e.g., IP addresses, device/browser details, and cookies).

White Label Service

We may offer white-label services that allow Business Users to provide branded AI solutions or communication tools to their clients through our platform. In such cases, FicientAI acts as a Data Processor, processing personal data as instructed by the Business User.

Our Data Protection Officer is Wezam Obanor, who can be contacted at [email protected] for any privacy-related inquiries or to exercise your rights.

3. DATA COLLECTION AND CATEGORIES

We collect and process the following types of data:

▪️Business User Data: Name, email, business name, address, phone number, payment information, platform usage data.

▪️End Customer Data: Name, contact details (email, phone number), communications, marketing engagement data, and feedback (processed as a Data Processor on behalf of our Business Users).

▪️Technical Data: IP addresses, device/browser details, cookies, referral data, and interaction logs.

4. LEGAL BASIS FOR PROCESSING

We process personal data based on:

▪️Contractual necessity (e.g., user registration, payments, providing the service)

▪️Legitimate interest (e.g., improving services, fraud prevention, customer relationship management)

▪️Consent (e.g., marketing emails where required, storing payment details)

▪️Legal obligations (e.g., compliance with UK or US laws and regulations)

For End Customer Data, our legal basis for processing is typically the legitimate interest of our Business Users in engaging with and reactivating their customer base, or consent where explicitly obtained by the Business User. It is the responsibility of our Business Users to ensure they have a lawful basis (including obtaining valid consent where required) to provide us with their customers' data for processing.

5. DATA STORAGE & INTERNATIONAL TRANSFERS

We store data securely on servers located in the United Kingdom, European Union, and Microsoft Azure or AWS data centres (which may be located in various regions, including the United States).

When transferring data outside the UK/EEA to countries that do not provide an adequate level of data protection, we ensure that appropriate safeguards are in place, including:

▪️Standard Contractual Clauses (SCCs) approved by the UK government and the European Commission;

▪️Contractual and technical safeguards to ensure compliance with UK and US privacy requirements.

6. DATA RETENTION POLICY

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including for legal, accounting, and reporting requirements.

▪️Business User Data: Retained for the duration of the business account + 6 years (for tax, accounting, and legal compliance).

▪️End Customer Data: Retained until deleted by the Business User or upon valid request for erasure.

▪️Technical data (logs, cookies): Retained for up to 24 months.

7. USER RIGHTS

Users in the UK and US (where applicable) have rights to:

▪️Access, correct, or delete their personal data.

▪️Object to the processing of their data.

▪️Request data portability.

▪️Withdraw consent for marketing communications.

▪️Lodge a complaint with the Information Commissioner’s Office (ICO) in the UK or the appropriate US state regulator where applicable.

To exercise these rights, please contact: [email protected]

8. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or data processing practices. The latest version will always be available on our website.

We encourage you to review this Privacy Policy periodically.

9. CONTACT INFORMATION

FicientAI (trading name of Wezworks Ltd)

Company Number: 16296393

Registered Office: Nautilus Apartments, 2 Norah Smyth Road, Canning Town, London

Email: [email protected]