Last Updated: [Date – March 27, 2025]

1. Introduction

Welcome to Xbots Ltd (“Xbots,” “we,” “us,” or “our”). We operate the website https://xbots.uk (the “Site”) and provide AI chatbot, AI agent, digital twin, and related services (the “Services”).

Xbots Ltd is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, process, share, and protect information about visitors to our Site and users of our Services (“you”).

This policy is compliant with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Xbots Ltd is the data controller for personal data collected through the Site. Our registered office is at 128 City Road, London, UK. Our company registration number is 16347353.

2. Information We Collect

We may collect and process the following types of information about you:

• Personal Identifiable Information (PII):
  • Information you provide directly via forms on our Site (e.g., contact forms, demo requests, newsletter sign-ups): Name, email address, phone number, company name, job title, and any other information you choose to provide in message fields.
  • Information provided when you register for an account or use our Services: Usernames, passwords, billing information, contact details.
• Service Interaction Data:
  • When you or your end-users interact with our AI chatbots, AI agents, or digital twin Services, we may process the content of those interactions (text, queries, commands) as necessary to provide and improve the Service. The specifics of this processing may be governed by separate agreements with our clients where we act as a data processor.
• Usage Data:
  • Information about how you access and use the Site: IP address, browser type and version, operating system, referring URLs, pages visited, time spent on pages, diagnostic data.
• Cookies and Tracking Technologies:
  • Information collected via cookies, web beacons, pixels, and similar technologies. Please see our [Link to Your Cookie Policy] for more details.
• Client Data:
  • If you are a client using our Services, we may process data provided by you or generated through your use of the Services as outlined in our specific service agreements. In many cases involving client data processed by our AI agents, Xbots Ltd acts as a data processor on behalf of the client, who is the data controller.

3. How We Collect Your Information

We collect information in the following ways:

• Directly from you: When you fill out forms, contact us, register for an account, or use interactive features of our Site or Services.
• Automatically: When you navigate the Site or use our Services, we collect Usage Data and information via Cookies and similar technologies.
• From Third Parties: We may receive information from third-party service providers (e.g., analytics providers, payment processors) or publicly available sources, where legally permissible.

4. Legal Basis for Processing Personal Data

We process your personal data based on the following legal grounds under UK GDPR:

• Consent: Where you have given us explicit consent to process your data for a specific purpose (e.g., signing up for a marketing newsletter). You can withdraw consent at any time.
• Contractual Necessity: Where processing is necessary for the performance of a contract with you (e.g., providing the Services you have subscribed to) or to take steps at your request before entering into a contract.
• Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party), provided your fundamental rights do not override those interests. Examples include improving our Site and Services, ensuring security, analysing usage patterns, and direct marketing communications (where permissible).
• Legal Obligation: Where processing is necessary to comply with a legal or regulatory obligation to which we are subject.

5. How We Use Your Information

We use the information we collect for various purposes, including:

• To Provide and Maintain our Site and Services: Operate the website, manage user accounts, deliver requested services.
• To Improve our Site and Services: Analyse usage data to understand how our Site and Services are used, identify trends, troubleshoot issues, develop new features, and potentially train/improve our AI models (typically using anonymised or aggregated data where possible, unless specific consent is obtained or it’s necessary for service provision under contract).
• To Communicate with You: Respond to inquiries, send service updates, provide customer support, send administrative information.
• For Marketing and Promotions: Send newsletters, promotional materials, and other information that may be of interest to you, where you have consented or where permitted by law (you can opt-out at any time).
• For Security and Fraud Prevention: Monitor for security threats, prevent fraud, protect the rights and safety of Xbots, our users, and the public.
• To Comply with Legal Obligations: Fulfill legal requirements, respond to lawful requests from public authorities.
• To Process Payments: Facilitate transactions for paid services.

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following circumstances:

• With Service Providers: We may share information with third-party vendors and service providers who perform services on our behalf (e.g., hosting providers, cloud services like AWS/Azure/GCP, analytics providers, payment processors, CRM systems, email service providers). These providers are contractually obligated to protect your data and use it only for the purposes we specify.
• With Business Partners: With your consent or where necessary for service provision, we may share data with trusted partners.
• For Legal Reasons: We may disclose information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• In Case of Business Transfer: If Xbots Ltd is involved in a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. We will provide notice before your data is transferred and becomes subject to a different privacy policy.
• With Clients (as Data Processor): When providing Services to our clients, we process data (including end-user interaction data) according to their instructions, as outlined in our Data Processing Agreements (DPAs).

7. International Data Transfers

Your information may be transferred to, and maintained on, computers located outside of the UK where data protection laws may differ. If we transfer your personal data outside the UK (e.g., to service providers), we will ensure appropriate safeguards are in place as required by UK GDPR, such as using Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner’s Office (ICO) or relying on adequacy decisions.

8. Data Security

We implement appropriate technical and organisational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include [Briefly mention types of measures, e.g., encryption, access controls, secure networks, staff training]. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure.

9. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and applicable legal requirements.

10. Your Data Protection Rights

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

• Right to Access: You can request copies of your personal data.
• Right to Rectification: You can request correction of inaccurate data or completion of incomplete data.
• Right to Erasure (‘Right to be Forgotten’): You can request erasure of your personal data under certain conditions.
• Right to Restrict Processing: You can request restriction of processing under certain conditions.
• Right to Object to Processing: You can object to processing based on legitimate interests or for direct marketing.
• Right to Data Portability: You can request transfer of data you provided to us to another organisation, or directly to you, in a structured, commonly used, machine-readable format (under certain conditions).
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time.

To exercise any of these rights, please contact us using the details below. We may need to verify your identity before responding to your request. You will generally not have to pay a fee, but we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

11. Cookies

Our Site uses cookies and similar technologies. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

12. Children’s Privacy

Our Site and Services are not intended for use by children under the age of 15. We do not knowingly collect personal data from children under this age. If you become aware that a child has provided us with personal data without parental consent, please contact us.

13. Links to Other Websites

Our Site may contain links to other websites not operated by us. If you click a third-party link, you will be directed to that site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. We encourage you to review this Privacy Policy periodically for any changes. Changes are effective when they are posted on this page.

15. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or have a complaint, please contact us:

• By email:  privacy@xbots.uk

16. Supervisory Authority

You have the right to lodge a complaint with the UK’s supervisory authority for data protection issues, the Information Commissioner’s Office (ICO).

ICO website: https://www.ico.org.uk

Information Commissioner’s Office

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

Helpline number: 0303 123 1113