Privacy
Policy

Last Updated: 29 November 2025

1. Introduction

Imperius Ltd ("Imperius," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered sales automation platform, including our website, mobile applications, and related services (collectively, the "Service").

This Privacy Policy should be read in conjunction with our Terms and Conditions. By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Service.

This Privacy Policy is designed to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection laws.

2. Data Controller Information

For the purposes of UK data protection legislation, the data controller is:

Imperius Ltd

Email: [email protected]

Data Protection Officer: [email protected]

We act as a data controller for your personal information (e.g., account details, billing information) and as a data processor for personal data about prospects, candidates, and contacts that you upload or collect using our Service.

3. Information We Collect

We collect several types of information from and about users of our Service:

3.1 Information You Provide Directly

Account Information: When you create an account, we collect your name, email address, company name, job title, phone number, and password.

Billing Information: Payment card details, billing address, and transaction history. Payment information is processed by our third-party payment processors and is not stored on our servers.

Profile Information: Information you provide in your user profile, including profile pictures, preferences, and settings.

Content and Communications: Information you provide when using the Service, including email content, campaign data, guidelines, knowledge base articles, contact information, and communications with our support team.

Prospect and Contact Data: Information about prospects, candidates, and contacts that you upload, import, or collect through the Service, which may include names, email addresses, phone numbers, job titles, company information, and other professional details.

3.2 Information We Collect Automatically

Usage Data: Information about how you access and use the Service, including pages viewed, features used, time spent, search queries, and interaction patterns.

Device Information: Information about the device you use to access the Service, including hardware model, operating system, browser type and version, unique device identifiers, IP address, and mobile network information.

Location Data: General location information based on your IP address (country and city level).

Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities. See Section 10 for more details.

Log Data: Server logs that record information about your use of the Service, including access times, pages viewed, error logs, and referral URLs.

3.3 Information from Third-Party Sources

Third-Party Integrations: If you connect third-party services (e.g., email providers, CRM systems, calendar applications) to your account, we may receive information from those services in accordance with their authorization processes.

Publicly Available Data: We maintain a database of professional profiles compiled from publicly available sources, business directories, and data providers. This data is used to provide our prospect discovery features.

Business Partners: We may receive information about you from our business partners, resellers, or referral sources.

3.4 AI and Machine Learning Data

Training Data: We may use aggregated, anonymized data derived from your use of the Service to train and improve our AI models, including Sania AI. This data cannot be used to identify you or any individual.

AI Interaction Data: Information about how you interact with AI features, including prompts, queries, generated content, and feedback on AI outputs.

4. Legal Basis for Processing (UK GDPR)

Under UK GDPR, we process your personal data on the following legal bases:

4.1 Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide the Service you have subscribed to). This includes account management, service delivery, billing, and customer support.

4.2 Legitimate Interests: Processing is necessary for our legitimate interests, including:

  • Improving and optimizing the Service
  • Detecting and preventing fraud and security threats
  • Conducting analytics and research
  • Marketing our services to existing customers
  • Developing new features and AI capabilities

We have balanced these interests against your rights and freedoms and believe the processing is proportionate and not overridden by your interests or fundamental rights.

4.3 Consent: Where required by law, we obtain your explicit consent before processing your personal data, such as for marketing communications or non-essential cookies. You may withdraw consent at any time.

4.4 Legal Obligation: Processing is necessary to comply with legal obligations, such as tax reporting, responding to legal requests, or enforcing our rights.

5. How We Use Your Information

We use the information we collect for the following purposes:

5.1 Service Provision and Management

  • Creating and managing your account
  • Providing access to the Service and its features
  • Processing payments and maintaining billing records
  • Providing customer support and responding to inquiries
  • Sending service-related communications and updates
  • Authenticating users and maintaining security

5.2 AI and Service Improvement

  • Developing new features and functionality
  • Analyzing usage patterns to optimize user experience
  • Conducting research and analytics
  • Monitoring Service performance and reliability

5.3 Personalization

  • Customizing content and recommendations
  • Tailoring AI outputs to your preferences and usage patterns
  • Remembering your preferences and settings

5.4 Security and Fraud Prevention

  • Detecting and preventing fraud, abuse, and security threats
  • Monitoring for suspicious activity
  • Enforcing our Terms and Conditions
  • Protecting the rights, property, and safety of Imperius and our users

5.5 Marketing and Communications

  • Sending promotional communications about new features and services (with your consent where required)
  • Conducting surveys and soliciting feedback
  • Analyzing the effectiveness of our marketing campaigns

5.6 Legal Compliance

  • Complying with legal obligations and regulations
  • Responding to legal requests and court orders
  • Enforcing our legal rights and defending against claims

6. Data Sharing and Disclosure

We do not sell your personal information to third parties. We may share your information in the following circumstances:

6.1 Service Providers

We engage third-party service providers to perform functions on our behalf, including:

  • Cloud hosting and infrastructure providers
  • Payment processing services
  • Email delivery services
  • Customer support tools
  • Analytics and monitoring services
  • Security and fraud prevention services

These service providers have access to personal information only as necessary to perform their functions and are contractually obligated to maintain the confidentiality and security of such information.

6.2 Business Transfers

If Imperius is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

6.3 Legal Requirements and Protection of Rights

We may disclose your information if required to do so by law or if we believe in good faith that such action is necessary to:

  • Comply with legal obligations, court orders, or government requests
  • Enforce our Terms and Conditions and other agreements
  • Protect and defend our rights, property, or safety
  • Prevent fraud, security breaches, or illegal activity
  • Protect the rights, property, or safety of our users or the public

6.4 Aggregated and Anonymized Data

We may share aggregated, anonymized data that cannot be used to identify you with third parties for research, marketing, analytics, or other purposes.

6.5 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

7. International Data Transfers

Our primary servers and databases are located within the European Economic Area (EEA) and the United Kingdom. However, some of our service providers may be located in countries outside the EEA/UK.

When we transfer personal data outside the EEA/UK, we ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions by the UK government or European Commission
  • Other legally recognized transfer mechanisms

You can obtain more information about our international data transfer safeguards by contacting us at [email protected].

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

8.1 Retention Periods

Account Data: We retain your account information for the duration of your subscription and for up to 30 days after termination, unless you request earlier deletion or we are required to retain it for legal purposes.

Billing Data: Financial and transaction records are retained for up to 7 years to comply with tax and accounting regulations.

User Content: Content you create (campaigns, contacts, guidelines) is retained for up to 30 days after account termination to allow for data retrieval. After this period, data is permanently deleted.

Usage Data: Analytics and usage data is typically retained for 24 months for analytical purposes.

Support Communications: Customer support tickets and communications are retained for up to 3 years.

8.2 Deletion

After the applicable retention period, we securely delete or anonymize your personal information. You may request deletion of your personal data at any time, subject to legal retention obligations.

9. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

9.1 Technical Measures

  • Encryption of data in transit (TLS/SSL) and at rest (AES-256)
  • Secure authentication and password hashing
  • Regular security testing and vulnerability assessments
  • Intrusion detection and prevention systems
  • Automated backup and disaster recovery procedures
  • Network security and firewall protection

9.2 Organizational Measures

  • Access controls limiting personnel access to personal data
  • Employee training on data protection and security
  • Confidentiality agreements with employees and contractors
  • Security incident response procedures
  • Regular security audits and compliance reviews

9.3 Limitations

While we use reasonable efforts to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity on your account.

9.4 Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by UK GDPR.

10. Your Rights Under UK GDPR

Under UK data protection law, you have the following rights regarding your personal data:

10.1 Right of Access: You have the right to request a copy of the personal information we hold about you. We will provide this information free of charge, subject to verification of your identity.

10.2 Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. You can update most information directly through your account settings.

10.3 Right to Erasure ("Right to be Forgotten"): You have the right to request deletion of your personal data in certain circumstances, including when:

  • The data is no longer necessary for the purpose it was collected
  • You withdraw consent (where consent is the legal basis for processing)
  • You object to processing and there are no overriding legitimate grounds
  • The data has been unlawfully processed

10.4 Right to Restriction of Processing: You have the right to request that we restrict processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

10.5 Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.

10.6 Right to Object: You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

10.7 Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing prior to withdrawal.

10.8 Right to Lodge a Complaint: You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:

Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Tel: 0303 123 1113

Website: www.ico.org.uk

10.9 Exercising Your Rights

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month, though this may be extended by up to two months for complex requests. We may need to verify your identity before processing your request.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver personalized content.

11.1 Types of Cookies We Use

Essential Cookies: Required for the Service to function properly, including authentication and security features. These cookies cannot be disabled.

Performance Cookies: Collect information about how you use the Service to help us improve functionality and user experience.

Functional Cookies: Remember your preferences and settings to provide enhanced, personalized features.

Marketing Cookies: Track your browsing activity to deliver targeted advertising and measure campaign effectiveness. These cookies require your consent.

11.2 Third-Party Cookies

We may use third-party services that set cookies, including analytics providers (e.g., Google Analytics), advertising networks, and social media platforms. These third parties have their own privacy policies governing their use of cookies.

11.3 Managing Cookies

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Service. You can also manage your cookie preferences through our cookie consent tool available on the Service.

12. AI and Machine Learning Privacy

12.1 AI Model Training

We use aggregated, anonymized data from your use of the Service to train and improve our AI models, including Sania AI. This process involves:

  • Analyzing patterns in how users interact with AI features
  • Using aggregated data to improve content generation quality
  • Testing and validating AI model performance
  • Developing new AI capabilities

Important: We do not use your specific prompts, generated content, or identifiable information to train AI models. All training data is anonymized and aggregated so that it cannot be traced back to you or any individual.

12.2 AI Data Processing

When you use AI features, your inputs may be temporarily processed to generate outputs. These inputs are:

  • Processed in real-time to generate responses
  • Not stored long-term unless necessary for Service functionality
  • Protected by encryption and access controls
  • Not shared with third parties except as disclosed in this policy

12.3 Automated Decision-Making

Our AI features may provide automated recommendations, content suggestions, and prospect scoring. However, these AI outputs are designed to assist, not replace, human decision-making. You retain full control over how you use AI-generated content and recommendations.

We do not use AI for automated decision-making that produces legal effects or similarly significantly affects you without human oversight.

13. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child under 18 without parental consent, we will take steps to delete that information as quickly as possible.

If you believe we have collected information from a child, please contact us immediately at [email protected].

14. Marketing Communications

We may send you marketing communications about our products, services, and features if you have consented to receive such communications or where permitted by law (e.g., based on our legitimate interests for existing customers).

Opting Out: You can opt out of marketing communications at any time by:

  • Clicking the "unsubscribe" link in any marketing email
  • Updating your communication preferences in your account settings
  • Contacting us at [email protected]

Please note that even if you opt out of marketing communications, we will still send you transactional and service-related communications necessary for the operation of your account.

15. Third-Party Links and Services

The Service may contain links to third-party websites, applications, or services that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services before providing them with your personal information.

When you integrate third-party services with our Platform (e.g., email providers, CRM systems), those services may collect and process your data according to their own privacy policies. You should review those policies to understand how your data will be handled.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

  • Update the "Last Updated" date at the top of this policy
  • Notify you by email or through a prominent notice on the Service
  • Obtain your consent where required by law

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes indicates your acceptance of the updated Privacy Policy.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Imperius Ltd

Email: [email protected]

Data Protection Officer: [email protected]

Website: www.Imperius-ai.com

We will respond to your inquiry within 30 days. For data subject rights requests, we will respond within one month as required by UK GDPR.

Your Privacy Matters to Us

At Imperius, we are committed to transparency and protecting your privacy. This Privacy Policy is designed to help you understand how we collect, use, and safeguard your information. If you have any questions or concerns, please don't hesitate to contact us.