Privacy & UK GDPR Compliance Policy

Last updated: September 2026

Clause 1: Data Architecture & Roles 1a. The Client as Data Controller: The client acts as the Data Controller regarding all customer contact records provided for reactivation. 1b. Our Role as Data Processor: We act strictly as a Data Processor under UK GDPR Article 28, processing contact numbers and lead records solely under the documented instructions of the client.

Clause 2: Lawful Basis for Direct SMS Communications 2a. Regulatory Scope: Campaigns deployed via our infrastructure operate under the direct guidelines of the Information Commissioner’s Office (ICO) and the Privacy and Electronic Communications Regulations (PECR). 2b. Soft Opt-In & Legitimate Interests: Direct messaging targeting dormant or previous commercial enquiries is executed under the PECR Soft Opt-In Exemption (Regulation 22) or established Legitimate Interests where documented balancing assessments are maintained. All outbound messaging remains directly relevant to the original nature of the commercial quote or customer enquiry.

Clause 3: Right to Object & Automated Opt-Out Suppression 3a. Free and Unambiguous Opt-Out: Every outbound SMS sequence provides a transparent, zero-cost mechanism for the recipient to object and opt out of further communications. 3b. Instant Suppression Triggers: Upon receipt of recognised opt-out keywords (such as STOP, UNSUBSCRIBE, or END), the platform immediately blacklists the contact number automatically, preventing any further dispatch.

Clause 4: Data Security, Encryption & Retention 4a. Technical Safeguards: All client databases, phone lists, and messaging logs remain encrypted during transit and at rest. 4b. Limited Retention Period: Contact records are retained solely for the active duration of the agreed reactivation campaign and confirmation period, after which customer lists are scrubbed, deleted, or securely returned to the client.

Clause 5: Compliance Desk & Data Enquiries

5a. Direct Inquiries: For questions regarding data processing addendums, regulatory checks, or suppression auditing, clients and contacts may reach our compliance team directly via the contact options on our primary website.