Privacy Policy
Version 2.0 · Last updated: 27 October 2026 · Albion Wealth Services, Ltd
This policy explains how Albion Wealth Services, Ltd processes personal data when you use Albion Assistant or interact with an assistant acting on behalf of one of our users. We comply with the General Data Protection Regulation (EU GDPR / UK GDPR) and other applicable law.
1. Who is responsible
Albion Wealth Services, Ltd, 66 Paul Street, London EC2A 4NA, United Kingdom (privacy contact: contact@albionwealthservices.com), is:
- The controller of the data relating to your account, billing, security and use of the service.
- The processor (on the user’s behalf) of the content and third-party data that the assistant processes at the user’s request: their emails, calendar, contacts, files, messages and calls. For that content, the user (or their company) is the controller, and our relationship is governed by the Data Processing Agreement (DPA).
Representative in the European Union (Article 27 GDPR): as Albion Wealth Services, Ltd has no establishment in the EU, it has appointed Albion Wealth Services Europe, P. I. Casería del Rey, 5, 29532 Mollina (Málaga), Spain (contact@albionwealthservices.com), as its representative. People in the EU and supervisory authorities can contact the representative, as well as us, about any matter relating to the processing of personal data.
2. What data we process
Account and billing data
First name and surname (required), email address, phone number (and its internal WhatsApp identifier), language, time zone, company and billing details, plan, token balance and transactions, payment and invoice history, and the status of your payment method (card details are handled by Revolut; we do not store them).
Content the assistant processes for you
- WhatsApp messages, SMS and web chat messages with the assistant, and their history (which serves as the conversation’s memory).
- Emails (subject, senders, body, attachments) from the accounts you connect; events, attendees and meeting links from your calendars; contacts; tasks, reminders and notes; files and folders you upload or authorise.
- Voice calls with the assistant or the receptionist: audio, transcript and summary, phone number and duration.
- Third-party data appearing in the above: senders, recipients, guests, people who call or write to your assistant, and people to whom you delegate tasks.
Sign-up and identity verification
One-time codes to confirm your email address and mobile number (sent by email, SMS or phone call; the mobile code is stored as a hash), the date and result of each verification, and the sign-up method (Google or email). If at any point we ask you for an additional check of your identity or address, such as a card check with no charge, we keep only the result (passed or not) and the information the payment provider returns about that check; never the full card number.
Sign-up information
Country, type of device (mobile, tablet or computer) and the referring page at the time of sign-up, for aggregate service statistics and fraud prevention.
Safety screening of messages
When a message sent to the assistant is flagged by automated screening as possibly unlawful, threatening or dangerous (section 4), we keep the message, the number that sent it, the account concerned, the category, the severity and the reason, and the date. These records may include data relating to alleged criminal offences.
Cancellations and complaints
If you withdraw from the contract or make a complaint, we keep the request, its date, the reason if you give one, and our reply.
Technical data
Activity and security logs (assistant actions, errors, IP addresses, device type), strictly necessary cookies (Cookie Policy) and usage metrics by provider.
Integration credentials
Access tokens and app passwords for the services you connect are stored encrypted and used only to carry out your requests.
We do not deliberately ask for special categories of data (health, beliefs, etc.), but they may appear in your emails or messages. They are processed only to carry out your instructions and with the same security measures.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Creating your account, providing the service and carrying out your requests | Performance of the contract (Art. 6(1)(b)) |
| Connecting external accounts (Google, Microsoft, email) and accessing their data | Your consent (Art. 6(1)(a)), which you can withdraw at any time |
| Payments, invoicing, accounting and tax obligations | Contract and legal obligation (Art. 6(1)(b) and 6(1)(c)) |
| Security, prevention of fraud and abuse, enforcement of usage limits, audit of actions | Legitimate interests (Art. 6(1)(f)) |
| Verifying your email address, your mobile number and, where appropriate, your identity or address | Performance of the contract and legitimate interest in preventing fake accounts and fraud (Art. 6(1)(b) and 6(1)(f)) |
| Automatically screening messages to detect unlawful use, threats or dangers, having them reviewed by authorised staff and, where appropriate, reporting them to the authorities | Legitimate interest in preventing unlawful use of the platform and protecting third parties (Art. 6(1)(f)); legal obligation where one exists (Art. 6(1)(c)); protection of vital interests where there is a risk to life (Art. 6(1)(d)). Data about alleged offences is processed in accordance with Article 10 GDPR and, in the United Kingdom, the Data Protection Act 2018 (Schedule 1, preventing or detecting unlawful acts) |
| Disclosing your name and phone number to the people the assistant writes to or calls on your behalf from a shared line | Performance of the contract and the legitimate interest of recipients in knowing who is contacting them, and of Albion in preventing anonymous communications (Art. 6(1)(b) and 6(1)(f)) |
| Handling cancellations and complaints | Legal obligation (Art. 6(1)(c)) |
| Support and service notices (low balance, incidents, changes to the terms) | Contract and legitimate interests |
| Improving and maintaining the service using aggregate metrics and feedback you send | Legitimate interests |
| Dealing, on your behalf, with third parties who contact you or whom you contact | The legal basis of the user as controller (usually their legitimate interests or the third party’s consent); we act as processor |
We do not sell personal data, we do not use it for advertising or to build commercial profiles, and we do not use it to train artificial intelligence models.
4. Artificial intelligence and automated decisions
To interpret your requests and draft replies, we send our language model providers (currently Anthropic) the minimum content needed for each request. The providers process that data on our behalf and, under their commercial API terms, do not use it to train their models. The assistant produces suggestions and carries out actions that you start or confirm; it does not take decisions with legal or similarly significant effects on people based solely on automated processing. People who interact with the assistant must be told that it is an automated system, and the assistant always introduces itself as an AI assistant (Regulation (EU) 2024/1689, Article 50).
AI provider cache. To reduce cost and response time, the provider may temporarily keep (usually for a few minutes) the fixed part of the assistant’s instructions and of a conversation’s context, solely to reuse it in the following requests. It is not used for any other purpose.
Safety screening. Every message the assistant receives (from you or from a third party writing to your assistant) is analysed automatically by an AI model to detect whether it requests or announces a crime, or contains threats, harassment or extortion, sexual content involving minors, plans for violence or a serious risk to someone’s life or safety. The analysis does not delay or change the reply. If the message is flagged, authorised Albion staff are alerted and review it. No action is taken on your account based on the automated result alone. We may refuse to carry out the instruction, suspend the account and pass the information to the authorities where the law requires or allows it, or to protect a person’s life or safety.
5. Google user data and Limited Use
If you connect your Google account, we request only the permissions we need and that you authorise on Google’s consent screen:
userinfo.emailand profile: to identify you and sign you in.calendar.events(Google Calendar, through our provider Nylas): to view, create, change and cancel events in your primary calendar and to generate Google Meet links.contacts.readonly(Google Contacts): to view and sync your address book, read-only, so the assistant can recognise your contacts.drive.file(Google Drive): to access only the files and folders you create or open with Albion.
We do not ask Google for Gmail permissions. If you want the assistant to read your Gmail, you connect it by IMAP with an app password that you generate and can revoke at any time; that credential is stored encrypted.
Google data is used only to provide the features you request in the app. We do not use it for advertising (including personalised or interest-based advertising), we do not sell it, and we do not transfer it except (a) to providers needed to deliver the service to you (infrastructure and AI models, see sub-processors), (b) to comply with the law, (c) for security or abuse prevention, or (d) with your consent. We do not allow humans to read your Google data, except with your express consent to resolve an issue, for security purposes, to comply with the law, or where it is aggregated and anonymised for internal operations. We do not use this data to develop, improve or train generalised AI models.
Albion Assistant’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
You can revoke access at myaccount.google.com/permissions or from the panel (Connections). When you disconnect, we stop accessing your data and delete the associated tokens.
6. WhatsApp, SMS and voice
WhatsApp messages are sent and received through Meta’s WhatsApp Business Platform and our messaging providers (Twilio and, for certain numbers, Telnyx). SMS and calls go through telephone carriers and telephony and voice providers (Twilio, Telnyx, Retell AI and its speech synthesis provider). Those providers process the metadata and content needed to deliver the message or call under their own terms. Data we receive from Meta is used only to provide the service described. Call transcripts and summaries are kept as set out in section 9.
Your own phone numbers and verification of the holder
If you ask for a number of your own (through the panel or by talking to Albion), the telephone carrier may be legally required to verify the holder. In that case we ask you, through a secure single-use link that expires after 7 days, for your full name, address and the documents the carrier requires (for example, an identity document or passport and proof of address; for a company, its registration or tax details). The legal basis is performance of the service you request and compliance with the carrier’s legal obligation. Albion does not store those documents: the file is forwarded directly to the carrier (Twilio or Telnyx), which keeps and processes it as the party responsible for its regulatory verification under its own terms, and no copy is kept in our systems. When you connect the number to WhatsApp, the verification SMS that Meta sends to that number reaches our systems only so that we can show you the code; we do not keep the text of the message. For Spanish numbers, the DNI, NIE or CIF number and the address are also sent directly to Telnyx and we do not keep them; the WhatsApp registration is verified by an automated call from Meta to the number, from which our systems only extract the code, without recording the call or keeping its transcript. We keep only the details of the request (country, chosen number, status, dates and a progress history, without the content of the documents), which you can see in your panel (My numbers) and which we notify to you by WhatsApp and email at each step.
7. Who we share data with
Only with providers that deliver services we need (hosting, database, messaging, voice, calendars, AI, payments, accounting), listed with their purpose and location at /subprocessors, and with police, judicial or administrative authorities where the law requires or allows it (for example, to report unlawful use detected by safety screening or where there is a risk to life). When the assistant writes to or calls a third party on your behalf from a shared line, that third party receives your first name, surname and contact phone number. If Albion merges or transfers its business, data may be transferred to the successor with the same safeguards and prior notice. We do not pass data to third parties for their own commercial purposes.
8. International transfers
Our database is hosted in Ireland and the assistant’s engine in Germany. Some providers (for example, for AI, voice and messaging) may process data in the United States or other countries. Where that happens, we rely on the applicable adequacy decisions (including the EU–US Data Privacy Framework and its UK Extension) or on the EU standard contractual clauses and the UK Addendum / IDTA, with supplementary measures where appropriate.
9. How long we keep data
| Data | Period |
|---|---|
| Account, settings and conversation content | While your account is active. After closure, deleted from live systems within 30 days and from backups within 90 days. |
| Integration credentials and tokens | Until you disconnect the integration or close your account (they are deleted when you disconnect). |
| Call transcripts and summaries | While they are shown in your panel or until you delete them; the voice provider keeps the audio for the minimum time necessary under its configuration. |
| Identity and address documents for verifying a number of your own | We do not keep them: they are sent directly to the telephone carrier. The request details (without documents) are kept while you have the number and for up to 6 years for invoicing obligations. |
| Invoices, payments and accounting records | Up to 6 years (tax and company law obligations). |
| Security logs and audit of actions | Up to 12 months, unless an incident justifies longer. |
| Verification codes and records (email, mobile, identity) | Codes expire after between 10 minutes and 1 hour. The verification record is kept while the account is active and for up to 12 months afterwards. |
| Messages flagged by safety screening | Up to 12 months; longer only if needed for an investigation, a report or legal proceedings. |
| Cancellations and complaints | Up to 6 years (limitation period for claims). |
| Data we must keep by law or to defend claims | For as long as the law requires or the applicable limitation period, restricted and not used for any other purpose. |
10. Security
- Encryption in transit (TLS) and encryption at rest of integration credentials (AES-256-GCM).
- Separation between customers (each customer can access only their own information) using row-level security policies in the database.
- Restricted internal access, secrets kept out of the code, logging and audit of the assistant’s actions, and classification of high-risk actions that require your confirmation.
- We will notify the authority and the people affected of security breaches within the legal deadlines (72 hours to the authority where applicable).
No measure is infallible; please keep your devices and credentials secure.
11. Your rights
You have the right to access, rectify and erase your data, to restrict processing, to object, to data portability and to withdraw your consent at any time (without affecting anything already done). You can disconnect integrations and change settings from the panel. To exercise your rights or ask for your account to be closed, write to contact@albionwealthservices.com; we will reply within one month. Complaints: if you think we have not handled your data properly, you can complain to us directly at the same address; we will acknowledge your complaint within 30 days, investigate it without undue delay, keep you informed and tell you the outcome. You can also complain to a supervisory authority: in the United Kingdom, the Information Commissioner’s Office (ICO); in Spain, the Agencia Española de Protección de Datos (AEPD); or the authority in your EU country of residence.
12. If you are a third party talking to an Albion assistant
If you have received a call or message from an Albion assistant, or have communicated with one (for example, to book an appointment or leave a message), the assistant is acting on behalf of one of our users, who decides what your data is used for. We process it as a processor. To exercise your rights over that data, please contact that person or company first; you can also write to us at contact@albionwealthservices.com and we will pass on your request. You are hereby informed that you are interacting with an automated system. If the message or call comes from a shared Albion line, we give you the name and contact phone number of the person on whose behalf it is sent, so that you can contact them. If you have received an abusive or unlawful message or call through Albion, please write to us at the same address.
13. Children
The service is not intended for anyone under 18 and we do not knowingly collect data from children. If you believe a child has given us data, write to us and we will delete it.
14. Cookies
We use only strictly necessary and preference cookies. Details are in the Cookie Policy.
15. Changes to this policy
We will publish any changes here and show the date of the version. We will notify you of material changes through the panel or by email.
16. Contact
Albion Wealth Services, Ltd · 66 Paul Street, London EC2A 4NA, United Kingdom · contact@albionwealthservices.com