Privacy Policy
Last updated: 3 August 2026 — extended account data retention to up to 6 months after your account ends for fraud and chargeback prevention (previously 30 days after cancellation)
ShadowPartner — AI Receptionist & Automation Platform
Effective Date: March 2026
1. Introduction
This Privacy Policy explains how ShadowPartner ('we', 'our', or 'us') collects, uses, stores, and protects personal information in connection with our AI receptionist and business automation platform.
We are committed to complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We collect only what we need, we are transparent about how we use it, and we respect your rights at all times.
2. Who We Are
The data controller responsible for your personal information is:
| Item | Detail |
|---|---|
| Legal entity | ShadowPartner Ltd (registration pending in England and Wales) |
| Trading name | ShadowPartner |
| Contact | privacy@shadowpartner.co.uk |
| Website | shadowpartner.co.uk |
3. What Information We Collect
3.1 Information You Give Us (Business Clients)
When you create an account or use our platform, we collect:
- Name and email address
- Business name, phone number, website, and business premises address
- Business configuration — opening hours, services, FAQs, voice preferences
- Password (stored as an encrypted hash — never in plain text)
3.2 Call Data — Collected on Behalf of Our Clients
Our AI receptionist answers calls on behalf of our business clients. When a call is handled, the following data may be collected from the caller:
| Data Type | Purpose | Always Collected? |
|---|---|---|
| Caller phone number | Call routing and callback capability | Yes |
| Call timestamp and duration | Service delivery, billing, usage reporting | Yes |
| Call transcript (text) | Service quality, AI improvement, client dashboard | Yes — see retention below |
| Caller name | Booking and appointment management | Only when caller provides it |
| Appointment details | Booking confirmation and calendar sync | Only when applicable |
| Address | Required for trades services (e.g. painter quoting a job) | Only when client configures it |
| Additional custom fields | Configured per client (e.g. vehicle registration for garages) | Only when client configures it |
Important — Variable Data Collection
The data collected during a call depends on how each business client has configured their AI receptionist. Each client (the business you are calling) is the data controller for their customers' data. They are responsible for ensuring they have a lawful reason to collect it. If you have questions about data collected during a specific call, please contact the business you called directly.
3.3 What We Do NOT Collect
- Call audio recordings — we do not store audio files. Voice is processed in real time and not retained.
- Payment card numbers — these are processed directly by Stripe and never stored by us.
- Sensitive personal data — we do not permit collection of health information, government ID numbers, financial account details, or data relating to children through our platform.
3.4 Technical Data
- IP address and browser type — collected by our hosting infrastructure when you visit our website
- Session cookies — essential authentication cookies only (see Section 9)
- Usage statistics — call counts, minutes used, plan usage
4. Legal Basis for Processing
| Legal Basis | What We Use It For |
|---|---|
| Contract Performance (Art. 6(1)(b)) | Providing the AI receptionist service, processing bookings, sending account notifications |
| Legitimate Interest (Art. 6(1)(f)) | Service improvement, fraud prevention, security monitoring, AI quality improvement |
| Legal Obligation (Art. 6(1)(c)) | Retaining financial records as required by UK tax law (7 years) |
5. How We Use Your Information
- To provide and operate the AI receptionist service
- To process appointment bookings and handle caller enquiries on behalf of our clients
- To send transactional emails — booking confirmations, account alerts, usage notifications
- To process subscription payments via Stripe
- To provide customer support — including AI-assisted responses to support queries
- To improve our AI models and service quality
- To detect and prevent fraud or abuse
- To comply with legal obligations
AI-Powered Voice Calls and Customer Support
We use Anthropic's Claude AI as the primary intelligence powering live voice call conversations. When a caller speaks to your AI receptionist, their speech is transcribed to text by Deepgram, and that text is processed by Claude to generate a response. No audio is ever sent to Anthropic — only transcribed text. In the event of primary provider unavailability, we may use OpenAI as a fallback to ensure call continuity. The same data types are shared with OpenAI as with Anthropic (transcribed text only, no audio). OpenAI does not use API data for model training. Claude is also used to assist with customer support enquiries. Escalations involving complex issues are handled by a human.
6. Third-Party Data Processors
We share data only with the following processors, all of whom are contractually bound (or in the process of executing data processing agreements) to protect your data and process it only according to our instructions.
| Provider | Purpose | Data Shared | Location | Agreement |
|---|---|---|---|---|
| Twilio | Phone number provisioning and call routing | Caller phone numbers, call timestamps, duration. Twilio retains call detail records on their own infrastructure subject to their retention policy and telecommunications regulations. | Ireland (EU) | Automatic with Terms of Service |
| Stripe | Subscription billing and payment processing | Name, email, billing details. Stripe retains payment and billing data as required by financial regulations, typically for 7+ years. | EU / UK | Automatic with Terms of Service |
| Anthropic | AI language model — primary provider powering voice call conversations and customer support | Call transcript text (transcribed speech), system prompts, tool call arguments. No audio is sent to Anthropic — text only. | USA | Direct agreement — DPA with UK IDTA |
| OpenAI | AI language model — fallback provider for voice call conversations during primary provider outages | Call transcript text (transcribed speech), system prompts, tool call parameters. Same data as primary AI provider. No audio. | USA | DPA with Standard Contractual Clauses — API data not used for model training |
| Deepgram | Speech-to-text — converts caller audio to text for AI processing (Twilio sub-processor) | Caller audio (real-time streaming, zero retention) | USA | Covered under Twilio DPA |
| Google Cloud | Text-to-speech — converts AI responses to speech (Twilio sub-processor) | AI response text (real-time, not stored) | EU (EEA processing via Twilio IE1 region) | Covered under Twilio DPA |
| ElevenLabs | Text-to-speech — premium voice synthesis (available for select voice configurations) | AI response text (real-time, converted to speech) | EEA processing not yet confirmed | DPA available — EEA processing pending confirmation |
| Hostinger | Server and database hosting | All platform data stored in our database | EU (Paris, France) | Data Processing Agreement |
| IONOS | Domain hosting, inbound and outbound email | Inbound support email; outbound transactional email content (booking confirmations, owner notifications, password-reset) containing caller name, email, phone and booking details | EU (Germany) | EU-based, GDPR compliant |
| Vercel | Website frontend hosting and delivery | Visitor IP addresses, web request data | USA | Standard contractual clauses |
| Sentry | Error monitoring and application stability | Error reports, stack traces, request metadata. No personal data collected by default (sendDefaultPii disabled). | EU (Frankfurt, Germany) | Data Processing Agreement |
| Google / Microsoft | Calendar integration (optional — only if you connect your calendar) | Calendar event data for booking sync only. Calendar events created during your subscription remain in your calendar account unless you remove them directly. | USA | Via customer OAuth authorisation |
What happens to third-party data when you delete your account?
When you delete your account, we delete your personal data from our own systems, with limited exceptions. We retain: (a) financial records for up to 7 years as required by UK tax law; (b) anonymised statistics that cannot identify you; (c) your account data (such as your name, email and business details) for up to 6 months after your account ends, which we keep under our legitimate interest in preventing fraud and payment chargebacks (Article 6(1)(f) UK GDPR) and then delete; and (d) a minimal record — your email address, the plan you last held, and your payment-provider reference — kept solely to prevent repeated misuse of our free-trial offer. We hold this minimal record under our legitimate interest in preventing fraud and abuse (Article 6(1)(f) UK GDPR) for up to 2 years from the date of your first trial, after which it is deleted. We also take reasonable steps to notify our sub-processors who hold copies of your data, as required by Article 17(2) UK GDPR. For services where we have a deletion API (such as Stripe), we will request deletion on your behalf. You may also contact any sub-processor directly to exercise your rights under their respective privacy policies.
7. Data Retention
| Data Type | Retention Period | Reason |
|---|---|---|
| Account data (name, email, business info) | For the duration of your subscription, then up to 6 months after your account ends (by cancellation or termination), for fraud- and chargeback-prevention, after which it is deleted. | Service delivery; fraud and chargeback prevention (legitimate interest). |
| Call transcripts | Maximum 30 days from date of call | Service quality and AI improvement only — removed automatically thereafter |
| Call metadata with caller details (phone number, transcript, summary) | 30 days | Callback capability and service quality — personal details removed automatically thereafter |
| Anonymised call statistics (date, duration, status) | Retained indefinitely | Billing, usage reporting, aggregate service quality — no personal data retained |
| Booking details (appointment, service, contact) | 30 days after appointment date | Service delivery and dispute resolution |
| Financial records | 7 years | UK tax law requirement — non-negotiable |
| Support correspondence | 12 months | Customer service and dispute resolution |
| Trial-eligibility record (email, last plan, payment reference) | 2 years from first trial | Preventing repeated misuse of the free-trial offer — minimal identifiers only, held under legitimate interest (Art 6(1)(f)) |
After the retention period expires, personal details such as caller phone numbers, transcripts, and summaries are automatically removed. The remaining anonymised data — including call date, duration, and status — cannot be used to identify any individual and is retained for service improvement and aggregate reporting.
Your Right to Earlier Deletion
You can request deletion of your data at any time by using the account deletion feature or contacting privacy@shadowpartner.co.uk. Financial records required by law will be retained for 7 years regardless of deletion requests.
8. Your Rights Under UK GDPR
| Right | What It Means | How to Exercise It |
|---|---|---|
| Access (Art. 15) | Request a copy of all personal data we hold about you | Use 'Download My Data' in account settings or email privacy@shadowpartner.co.uk |
| Rectification (Art. 16) | Correct inaccurate data | Update via account settings or contact us |
| Erasure (Art. 17) | Request deletion of your data | Use 'Delete Account' in settings or contact us |
| Data Portability (Art. 20) | Receive your data in machine-readable format | Use 'Download My Data' in account settings |
| Object (Art. 21) | Object to processing based on legitimate interest | Contact privacy@shadowpartner.co.uk |
| Restriction (Art. 18) | Request we limit how we use your data | Contact privacy@shadowpartner.co.uk |
| Lodge a Complaint | Complain to the ICO if you believe we have mishandled your data | ico.org.uk — the UK's data protection regulator |
9. Cookies
We use only essential cookies necessary for the service to function:
- Authentication cookie — keeps you logged in during your session
- Security cookie (CSRF token) — protects against cross-site request forgery attacks
We do NOT use tracking cookies, advertising cookies, analytics cookies, or any third-party cookies. No cookie consent banner is required as only essential cookies are used.
10. International Data Transfers
Some of our service providers are located outside the UK. Where data is transferred internationally, we ensure it is protected by one or more of the following:
- Standard Contractual Clauses (SCCs) approved by the ICO
- The provider's own adequacy certification or compliance framework
- EU-based hosting where applicable (Twilio: Ireland, Hostinger: France, IONOS: Germany)
11. Data Security
- All data transmitted over HTTPS (SSL/TLS encryption)
- Passwords encrypted using bcrypt — never stored in plain text
- OAuth tokens (calendar integrations) encrypted using PGP before storage
- Database access restricted by firewall
- Rate limiting on authentication endpoints
- Webhook replay protection for payment processing
12. Children's Privacy
Our service is not intended for and does not knowingly collect data from children under 18. If you believe we have inadvertently collected data from a child, contact privacy@shadowpartner.co.uk immediately.
13. Changes to This Policy
We will notify you of material changes by email at least 30 days before they take effect. Continued use of the service constitutes acceptance of the updated policy.
14. Contact
Email: privacy@shadowpartner.co.uk
Data Controller: ShadowPartner Ltd (registration pending in England and Wales), trading as ShadowPartner