This privacy notice explains how Plusway Ltd (“we”, “us”, “our”) collects, uses, stores and shares personal data when you:
We are committed to handling personal data lawfully, fairly and transparently in accordance with the UK GDPR, the Data Protection Act 2018, and, where applicable, the Privacy and Electronic Communications Regulations 2003 (PECR).
Plusway Ltd
Company number: 17152788
Registered office: Suite 5, 5th Floor, City Reach, Greenwich View Place, London E14 9NN
Email: noreply@plusway.co.uk
Telephone: 123456
For the purposes of UK data protection law, we are usually the data controller for personal data relating to:
Where we provide inbound AI call handling, CRM hosting, automation, or related services on behalf of a business customer, we may act as a data processor for personal data processed on that customer’s behalf. In those cases, the relevant customer is usually the data controller and is responsible for its own privacy information to its callers, contacts and end users.
Depending on how you interact with us, we may collect and use the following categories of personal data:
We do not intentionally seek to collect special category data (for example, health data or information about religion or ethnicity) unless this is necessary for the service being provided. However, callers may choose to disclose sensitive information during calls. Where this occurs, such information may be recorded or transcribed as part of the service.
We collect personal data:
Under UK GDPR, we must have a lawful basis for processing personal data. The lawful basis depends on the purpose.
a. To respond to enquiries, demo requests and other pre-contract communications
Data used: contact and enquiry data
Lawful basis: legitimate interests and, where applicable, steps at your request before entering into a contract
b. To provide our services to customers
Data used: customer account data, call data, technical data, support records
Lawful basis: performance of a contract
c. To host, configure and support CRM and automation environments, including GHL
Data used: customer account data, hosted CRM/contact data, usage and support data
Lawful basis: performance of a contract; in some cases we act as processor on our customer’s instructions
d. To operate inbound AI call handling features
Data used: caller details, call recordings, transcripts, voicemail content, AI-generated outputs, routing and support notes
Lawful basis: performance of a contract, and/or legitimate interests in delivering, securing, maintaining and improving our services
e. To monitor, maintain, secure and improve our website, systems and services
Data used: logs, diagnostics, technical usage data
Lawful basis: legitimate interests
f. To manage billing, accounts, tax and financial records
Data used: billing and transaction information
Lawful basis: performance of a contract and legal obligation
g. To send service-related communications
Data used: contact details, account data
Lawful basis: performance of a contract and legitimate interests
h. To send marketing communications
Data used: name, contact details, marketing preferences
Lawful basis: legitimate interests or consent, depending on the message type, recipient status and the rules under PECR
i. To comply with legal and regulatory obligations and to establish, exercise or defend legal claims
Data used: any data relevant to the issue
Lawful basis: legal obligation and/or legitimate interests
Where we rely on legitimate interests, those interests generally include operating our business, delivering and improving our services, keeping our systems secure, responding to requests, preventing misuse, and maintaining records.
Because we provide inbound AI call services, we may process personal data contained in:
This processing may be used to:
Where we provide these services on behalf of a customer, we generally process this information on that customer’s behalf. That customer is responsible for determining the lawful basis for its own use of caller data and for providing any caller-facing notices or consent language that may be required.
If calls are recorded or transcribed, we recommend customers clearly inform callers of this at the appropriate point in the call journey.
We use cookies and similar technologies on our website for functions such as:
Some cookies are strictly necessary and do not require consent. Others, such as analytics or marketing cookies, may require your consent before they are used.
You can control cookies through your browser settings, although disabling some cookies may affect how the website functions.
We may send marketing communications about our products and services where permitted by law.
These may include email, SMS or other electronic messages. The rules for electronic marketing are affected by PECR, and the requirements differ depending on whether the recipient is an individual, sole trader, partnership, or corporate subscriber. In some cases, we will rely on consent; in others, we may rely on legitimate interests where permitted, but we will always provide an unsubscribe or opt-out option.
You can opt out of marketing at any time by:
We may share personal data with the following categories of recipients where necessary:
We do not sell personal data.
Some of our service providers may process personal data outside the UK. Where personal data is transferred internationally, we will take appropriate steps to ensure it is protected in accordance with UK data protection law.
These steps may include transferring data to countries that benefit from UK adequacy regulations, or using appropriate contractual safeguards such as the UK International Data Transfer Agreement or the UK Addendum to standard contractual clauses, together with supplementary measures where appropriate.
We keep personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, tax, accounting, contractual and reporting requirements.
Typical retention periods may include:
If we do not set a fixed period, we determine retention based on the nature of the data, the purpose of processing, legal requirements, and whether we need the information to establish or defend legal claims.
Depending on the circumstances, you may have the right to:
You can exercise your rights by contacting us at noreply@plusway.co.uk.
We usually respond within one month. We do not normally charge a fee, although we may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive.
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
These measures may include access controls, authentication, encryption where appropriate, logging, backups, role-based permissions, and supplier due diligence.
Our website or services may contain links to third-party websites, platforms or integrations. If you follow those links or use those services, their privacy notices and terms will apply. We are not responsible for the content, privacy practices or security of third-party services that we do not control.
Our website and services are intended for businesses and are not directed at children. We do not knowingly collect personal data from children through our website as a target audience. If you believe a child has provided personal data to us inappropriately, please contact us so that we can review and, where appropriate, delete the information.
We may update this privacy notice from time to time to reflect changes to our business, services, legal obligations or the technologies we use. When we do, we will update the “Last updated” date above. Where required, we will provide additional notice.
Plusway Ltd
Email: noreply@plusway.co.uk
Address: Suite 5, 5th Floor, City Reach, Greenwich View Place, London E14 9NN
Telephone: 123456