Digenio AI — Privacy Policy
Last updated: 12 October 2026 · Version 1.0
This Privacy Policy explains how Digenio Tech Ltd collects and uses personal data when you visit digenio.ai, contact us, use the Digenio AI platform (the Service) as a customer or user, or join our partner programme.
1. Who we are
Digenio Tech Ltd is a company registered in England and Wales (company number 13567695), with its registered office at 12, 50 Burr Road, London, England, SW18 4SS (Digenio, we, us). For the processing described in this policy, we are the controller.
- Contact for all privacy matters: hello@digenio.ai
- UK Information Commissioner’s Office (ICO) registration number: Pending — the ICO data protection fee will be paid before launch (number to follow)
- EU representative (Article 27 EU GDPR): Avv. Angelina Zamuner, Via Ca’ Memo 84, 30020 Noventa di Piave (VE), Italy — info@studiozamuner.it
2. What this policy does not cover
Our customers install our tracking code on their own websites and collect form submissions (leads) through the Service. For that data, the customer is the controller and Digenio is a processor acting on the customer’s instructions under our Data Processing Agreement. If you visited a website that uses Digenio, or submitted a form on it, please read that website’s privacy policy and contact its owner to exercise your rights (see section 11).
3. The personal data we use, why, and for how long
| Who / what | Data | Purpose | Lawful basis (UK/EU GDPR) | Retention |
|---|---|---|---|---|
| Visitors to digenio.ai | Pages viewed, clicks, device and browser data, referrer, campaign parameters, online identifiers, IP address (by our analytics and advertising providers) | Measure and improve our website; measure and target our advertising | Consent (via the cookie banner) | See section 8 (cookies) |
| People who contact us | Name, email, company, message | Answer your enquiry | Legitimate interests; steps before a contract | 2 years after last contact |
| Customers and users of the Service | Name, email, company, password (stored hashed) or Google account ID, name and email (if you sign in with Google), user role, settings | Create and manage your account and provide the Service | Contract | Life of the account + 90 days |
| Acceptance records | User, company, document and version accepted, date and time, IP address, browser information | Prove acceptance of our Terms and other agreements | Legitimate interests (evidence of the contract, legal claims) | Life of the account + 6 years |
| Billing and tax | Company name, billing country and address, VAT number and its validation result, currency, invoices, payment status, card brand and last 4 digits (full card details are held by Stripe, not us), location evidence for tax (e.g. IP and card country) | Take payments, issue invoices, apply the correct VAT | Contract; legal obligation (tax and accounting) | 6 years (UK); 10 years for EU VAT (OSS) records |
| Security and usage logs | Logins, actions in the Service, IP address, device | Keep the Service secure, prevent fraud and abuse, support | Legitimate interests | 12 months |
| AI Agent (Lux) | Chat content; your AI provider API key (encrypted) | Provide the AI Agent, which runs on your own AI provider account | Contract | Chat: life of the account + 90 days. API keys: deleted when the subscription ends |
| Onboarding / ICP assistant | Answers to the onboarding questionnaire (business goals, target market, business model) | Generate a draft Ideal Customer Profile with AI | Contract | Life of the account + 90 days |
| Support | Emails and messages with our team | Help you and improve the Service | Contract; legitimate interests | 2 years after the case is closed |
| Marketing emails | Name, email, company, email preferences and engagement (opens, clicks) | Send product updates and newsletters | Legitimate interests for business customers (with an unsubscribe link in every email); consent where the law requires it | Until you unsubscribe, then kept on a suppression list so we do not email you again |
| Partner programme | Name, company, contact details, bank details for payouts (account holder, IBAN or sort code and account number, bank name), referrals and cashback records, partner agreement acceptance (IP, date, document version) | Run the partner programme and pay cashback | Contract; legal obligation (accounting) | Duration of the partnership + 6 years |
After these periods, data is deleted or anonymised. Backups are overwritten on their normal cycle.
4. Automated decisions
We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you. Lead scoring in the Service is carried out on behalf of our customers about their own leads (see section 2), and its results are decision support only.
5. Who we share personal data with
| Recipient | Why | Location |
|---|---|---|
| Fasthosts / IONOS (hosting) | Hosting of the Service, website and databases | United Kingdom |
| Stripe | Payments, subscriptions, tax calculation and invoicing | United States / European Union |
| Zoho (email) | Transactional emails and contact form messages | European Union |
| Sign in with Google (if you choose it); website analytics and advertising (with your consent) | United States | |
| Meta | Advertising measurement (with your consent) | United States / Ireland |
| OpenAI | AI features of the Service (onboarding/ICP assistant) | United States |
| Zoho (EU) | Sending marketing emails | European Union (Zoho EU) |
| Banks | Partner cashback payouts by bank transfer | United Kingdom / European Union |
| Professional advisers | Accountants, lawyers and auditors | United Kingdom / Italy |
We may also share data with authorities when required by law, or with a buyer if our business is sold (under confidentiality). We do not sell personal data.
If you connect your own AI provider key to the AI Agent, your chats are processed by that provider under your own agreement with them; we are not responsible for that provider’s processing.
6. International transfers
Our servers are in the United Kingdom. Transfers from the EU to the UK are covered by the European Commission’s adequacy decision for the UK. Where providers process data in the United States or elsewhere, we rely on an adequacy decision or regulations (including the EU–US Data Privacy Framework and its UK extension, where the recipient is certified), or on the EU Standard Contractual Clauses or the UK International Data Transfer Addendum. You can ask us for details at hello@digenio.ai.
7. How we protect your data
We use appropriate technical and organisational measures, including encryption in transit, encryption of stored API keys, access controls, payment card data handled only by Stripe, and regular backups. No system is completely secure, and we will notify you and the relevant authorities of a personal data breach where the law requires.
8. Cookies and similar technologies on digenio.ai
We use cookies and similar technologies (such as identifiers stored in your browser). Except for strictly necessary ones, we only use them if you consent through our cookie banner. You can change your choice at any time via the “Cookie settings” link at the bottom of every page.
| Category | Used for | Provider | Consent needed |
|---|---|---|---|
| Strictly necessary | Login session, security, load balancing, remembering your cookie choice | Digenio | No |
| Analytics | Understanding how visitors use our website | Google Analytics; Digenio AI (our own analytics, pseudonymous identifier) | Yes |
| Advertising | Measuring and targeting our ads | Google Ads; Meta Pixel | Yes |
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
PHPSESSID | Digenio (app only: area.digenio.ai) | Keeps you signed in (essential session) | Session |
g_state | Google (on digenio.ai) | Remembers whether you dismissed the Google sign-in prompt | Set by Google (several months) |
No analytics or advertising cookies are currently used on digenio.ai. If that changes, a consent banner will be shown before any non-essential cookie is set, and this table will be updated.
9. Your rights (UK and EU)
You have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected;
- have your data erased in certain cases;
- restrict or object to our processing in certain cases — and to object at any time to direct marketing, which we will then stop;
- data portability for data you gave us, where processing is based on contract or consent;
- withdraw consent at any time, without affecting earlier processing.
To exercise a right, email hello@digenio.ai. We will reply within one month. You can also complain to the UK Information Commissioner’s Office (ico.org.uk) or to the data protection authority in your EU country (for example, the Garante per la protezione dei dati personali in Italy). We would appreciate the chance to resolve your concern first.
10. Additional information for US residents
Where US state privacy laws (such as the California Consumer Privacy Act) apply, you may have the right to know, access, correct and delete your personal information, and to opt out of the “sale” or “sharing” of personal information for cross-context behavioural advertising. We do not sell personal information. Our advertising cookies may be considered “sharing”; you can opt out through “Cookie settings”, and we honour Global Privacy Control signals. We will not discriminate against you for exercising your rights. Contact hello@digenio.ai; we will respond within 45 days.
11. If you visited a website that uses Digenio
Our customers use Digenio to understand visits to their websites and to manage form submissions. Our tracking code does not set tracking cookies and does not store your IP address; it uses a random pseudonymous identifier. The website owner decides how this data is used and is responsible for informing you. Please contact the website owner to exercise your rights. If you contact us instead, we will pass your request on to them.
12. Children
Our website and Service are for businesses and are not directed at children. We do not knowingly collect personal data from anyone under 18.
13. Changes to this policy
We may update this policy. We will notify customers of material changes by email or in the Service before they take effect. Previous versions remain available at digenio.ai/legal/privacy.
14. Contact
Digenio Tech Ltd, 12, 50 Burr Road, London, England, SW18 4SS — hello@digenio.ai
EU representative: Avv. Angelina Zamuner, Via Ca’ Memo 84, 30020 Noventa di Piave (VE), Italy — info@studiozamuner.it