Privacy Notice
Last updated: 2026-08-14
1. Who We Are
Apex Insights is a trading name of Craig Moore, a sole trader registered in Scotland with HMRC for Self Assessment.
For our postal address, please contact us at [email protected].
Email: [email protected]
ICO registration number: ZC222916
We are the data controller for the personal data described in this notice. We are not required to appoint a Data Protection Officer but the named contact for privacy queries is the proprietor at the email address above.
2. What Data We Collect
| Category | Examples |
|---|---|
| Account data | Email address, name, phone number |
| Organisation data | Company name, address, sector, Companies House number |
| Questionnaire responses | Information about your business data practices, tools, and processes |
| Consultation data | Notes from the consultation, and consultation transcripts where you give explicit consent |
| Communications | Messages sent through our platform; emails to and from [email protected] |
| Payment data | Amount, payment status, transaction IDs (card details are held by our payment processor — we never see or store them) |
| Technical data | IP address, browser type, device information (collected automatically) |
We do not knowingly collect data from children under 18. The service is intended for use by businesses and their staff.
3. How We Use Your Data & Lawful Basis
| Purpose | Lawful Basis (UK GDPR) |
|---|---|
| Creating and managing your account | Contract performance (Art. 6(1)(b)) |
| Sending sign-in links and service notifications | Contract performance (Art. 6(1)(b)) |
| Delivering your assessment and report | Contract performance (Art. 6(1)(b)) |
| Recording consultation transcripts | Consent (Art. 6(1)(a)) — you can decline or withdraw at any time |
| Invoicing and tax records | Legal obligation (Art. 6(1)(c)) — HMRC record-keeping |
| Security, fraud prevention, abuse detection | Legitimate interest (Art. 6(1)(f)) |
| Anonymised analytics and service improvement | Legitimate interest (Art. 6(1)(f)) |
| Responding to enquiries and complaints | Legitimate interest (Art. 6(1)(f)) |
| Marketing emails (where you have opted in) | Consent (Art. 6(1)(a)) — you can unsubscribe at any time |
Automated decision-making. We use AI tools to help draft and structure your report. A human (the proprietor) reviews, edits, and signs off every report before delivery. No decision producing legal or similarly significant effects is made solely by automated means.
4. Data Retention
| Data Type | Retention Period |
|---|---|
| Account data | For as long as your account is active. Anonymised when you close your account or ask us to erase it |
| Questionnaire responses | For as long as needed to deliver and support your engagement. Erased on request |
| Reports (hosted copies on the platform) | At our discretion; we may remove hosted copies at any time. Clients are advised to download and retain their own PDF copy on delivery |
| Consultation transcripts | For as long as needed to deliver and support your engagement. Erased on request |
| Signed engagement agreements and audit trail | 6 years (Limitation Act 1980) |
| Invoice and payment records | 6 years (HMRC legal obligation) |
| Email correspondence | 3 years from last contact |
| Technical and server logs | 90 days |
| Marketing consent records | Until you withdraw, plus 3 years |
5. Third-Party Processors
We share your data with the processors below only to the extent necessary to deliver the service. Each processor is engaged under a written data processing agreement — typically the processor's published Data Processing Addendum, accepted at sign-up — and processes data only on our documented instructions.
| Processor | Purpose | Data shared | Location |
|---|---|---|---|
| Hetzner Online GmbH | Server hosting and storage | All data; daily backups retained in the same EU region | Germany (EU) |
| Cloudflare, Inc. | CDN, DDoS and bot protection, DNS | IP address, request metadata | Global (UK ingress) |
| Resend, Inc. | Transactional email delivery | Email address, message content | Ireland (EU) / United States |
| Anthropic, PBC | AI-assisted report drafting | Questionnaire responses, consultation notes | United States |
| Stripe Payments UK Ltd (from launch) | Card payment processing | Card details (held by Stripe), transaction metadata | United Kingdom / Ireland |
| Microsoft Ireland Operations Ltd | Business email (Microsoft 365) | Email address, message content | European Union (UK data residency) |
| Calendly LLC | Consultation scheduling and meeting link | Email address, name, booked time, your submission reference | United States |
| Companies House (UK government) | Company verification and lookup | Company registration number (returns publicly filed company data) | United Kingdom |
| EasyPostcodes Ltd | UK postcode address lookup | Postcode (no personal identifier) | United Kingdom |
Our AI provider (Anthropic) processes the content we send it solely to generate your report. Anthropic deletes these inputs and outputs within 30 days and does not use them to train its models. Our hosting and deployment tooling runs on our own servers at the hosting provider named above; it is not a separate recipient of your data.
We do not sell your data, do not share it with advertising networks, and do not allow our processors to use your data for their own purposes.
6. International Data Transfers
Some of our processors are located outside the United Kingdom. Where personal data is transferred outside the UK, we rely on one of the following safeguards required by UK GDPR Chapter V:
| Country | Safeguard |
|---|---|
| EU/EEA (Germany, Ireland) | UK adequacy decision — no further safeguard required |
| United States | Standard Contractual Clauses (incorporated via the processor's published Data Processing Agreement) and the UK International Data Transfer Addendum (IDTA) where applicable |
On request, we will share details of the safeguards in place for any specific transfer.
7. Your Rights
Under UK GDPR (Data Protection Act 2018), you have the right to:
- Access your personal data (Subject Access Request)
- Rectify inaccurate or incomplete data
- Erase your data (“right to be forgotten”), where no legal obligation requires retention
- Restrict processing in certain circumstances
- Data portability — receive your data in a machine-readable format
- Object to processing based on legitimate interest
- Withdraw consent at any time, where processing is based on consent
- Object to direct marketing at any time
- Not be subject to a decision based solely on automated processing that has legal or similarly significant effects (we do not make such decisions)
To exercise any of these rights, email [email protected]. We will respond within one month, as required by UK GDPR Article 12. Where a request is particularly complex or numerous, we may extend this period by up to a further two months and will explain the reason for the extension. We may need to verify your identity before responding.
You can close your account at any time from your account settings. When you do, we immediately anonymise the personal identifiers on your account. Records connected to a completed engagement, such as your report, questionnaire responses, and any consultation transcript, are then kept only for as long as we need them to provide and support the service, as described in section 4, and securely deleted when no longer needed or when you ask us to erase them.
You can also ask us to erase your data sooner by emailing [email protected]. We will honour the request except where the law requires us to keep specific records (for example, invoice records for HMRC), and we will tell you what we cannot delete and why.
8. Data Security
We protect your data using technical and organisational measures including:
- HTTPS (TLS 1.2+) encryption for all data in transit
- Data hosted in an ISO 27001-certified EU datacentre (Germany) with restricted physical and network access
- HTTP-only, secure, SameSite cookies for authentication
- Magic-link sign-in (no passwords stored)
- Multi-factor authentication on administrative accounts
- Rate limiting and intrusion detection
- Restricted administrative access via Cloudflare Zero Trust
- Regular dependency and security reviews
- Automated daily server backups, retained for a rolling window in the same EU region
9. Data Breaches
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Information Commissioner's Office within 72 hours of becoming aware of it, in line with UK GDPR Article 33. Where the breach is likely to result in a high risk to you, we will notify you without undue delay (Article 34).
10. Cookies
We only use strictly necessary cookies for authentication and security. We do not use analytics or tracking cookies. For full details see our Cookie Policy.
11. Complaints
If you are unhappy with how we handle your data, please contact us first at [email protected]. We aim to acknowledge complaints within 3 business days and resolve them within 14 business days where reasonably possible.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent supervisory authority.
12. Changes to This Notice
We may update this privacy notice from time to time. Where a change is material, we will notify you by email at least 30 days before the change takes effect. The current version is always available at this URL, with an updated “Last updated” date.