scotsphere AI Privacy Policy: UK GDPR Compliance & Your Data Rights

1. Overview

To provide our services and operate our business effectively, scotsphere AI (Antony Slack Ltd) may need to collect and process certain information about you. This may include:

• Information automatically collected from your browser when you visit our website (e.g. your IP address and browser type).
• Usage data relating to your interaction with our website or services (e.g. pages visited, session duration).

This Privacy Policy outlines what information we collect, how it is used, and how it is protected.

2. Our Commitment to Data Privacy

We are committed to maintaining the confidentiality, integrity, and security of your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the EU GDPR (where applicable), and the Data Protection Act 2018.

We apply the principle of data minimisation, meaning we only collect the minimum personal data necessary to provide our services. All personal data is processed lawfully, fairly, and transparently, and we implement technical and organisational measures to safeguard it at all times.

How scotsphere AI Collects and Processes Your Data

Data Controller: Antony Slack Ltd (trading as scotsphere AI)
Registered Address: Longformacus Road, Edinburgh, EH16 6SD, UK
Email: info@scotsphere.ai

4. Definition of 'Personal Data'

'Personal data' refers to any information relating to an identified or identifiable natural person. This may include, but is not limited to, your name, email address, and IP address.

We will only process personal data where we have a lawful basis for doing so, such as your consent, our legitimate interests, contractual necessity, or legal obligation.

5. Who We Share Data With

We restrict access to personal data on a strict "need to know" basis. Personal data may be shared only with:

• Employees and authorised contractors of Antony Slack Ltd, for the sole purpose of providing our services.
• Trusted third-party service providers, including: website hosting providers and IT infrastructure partners; providers of analytics, CRM, and cloud services.

Where third-party providers are based outside the UK or European Economic Area (EEA), we ensure appropriate safeguards are in place, such as UK International Data Transfer Agreements (IDTAs) or EU Standard Contractual Clauses (SCCs).

We have signed Data Processing Agreements (DPAs) with all relevant third parties to ensure ongoing GDPR compliance.

6. How Your Data Is Protected

We employ the following data security measures:

• Access Controls: Access to data is limited to authorised personnel with role-based restrictions and strong password policies.
• Encryption: Data is encrypted at rest and in transit. SSL is used for all web traffic.
• VPN Usage: Our team accesses systems through secure Virtual Private Networks (VPNs).
• Provider Due Diligence: We work only with providers who meet high data protection standards and have appropriate DPAs in place.

7. Your Data Rights

Under the UK GDPR, you have the following rights regarding your personal data:

• Right of Access – to request a copy of the personal data we hold about you.
• Right to Rectification – to request correction of inaccurate or incomplete data.
• Right to Erasure – to request deletion of your personal data ('right to be forgotten').
• Right to Restrict Processing – to request limited use of your data under certain conditions.
• Right to Object – to object to data processing based on our legitimate interests.
• Right to Data Portability – to request transfer of your data to another service provider.
• Right to Withdraw Consent – at any time, where consent is the lawful basis for processing.
• Right to Lodge a Complaint – with the Information Commissioner's Office (ICO) at ico.org.uk.

To exercise any of these rights, please contact us at info@scotsphere.ai.

8. Types of Data Collected

a) Technical Data (e.g. IP Address)

Our web server logs your IP address and basic device/browser information. This is standard practice for detecting malicious activity and monitoring site performance. This data is not used to personally identify you and does not require consent under the UK GDPR when collected for legitimate security purposes.

b) Cookies and Similar Technologies

We use cookies, pixel tags, and similar technologies to understand site usage and improve functionality.

Types of cookies used:

• Essential cookies (required for functionality)
• Analytics cookies (to measure usage)
• Preference cookies (to remember user settings)

Users can manage cookie preferences through our cookie banner or their browser settings. By continuing to use our site, you consent to our use of cookies as detailed in this policy.

9. Website Analytics

We use Google Analytics, configured to anonymise IP addresses and avoid storing personally identifiable information. This data helps us understand user behaviour and improve our website, without identifying individuals.

10. Policy Updates

This policy may be updated periodically to reflect legal, regulatory, or operational changes. Where appropriate, significant changes will be communicated via email or on our website.

11. Contact Us

To exercise your rights or raise questions about this Privacy Policy or data protection practices, contact:
Data Controller: Antony Slack Ltd
Email: info@scotsphere.ai

Report a Repair and Alexa

Who is responsible for your information?

North Lanarkshire Council is the data controller for repair reports submitted through Report a Repair. This means the Council decides why and how the information is used.

Antony Slack Ltd, trading as scotsphere AI, operates Report a Repair for the Council. scotsphere AI acts as a data processor and processes the information only on the Council's instructions.

Questions or requests about your information can be sent to:

Email: info@scotsphere.ai
Telephone: 0131 381 6570
Address: Antony Slack Ltd, trading as scotsphere AI, 29 Longformacus Road, Edinburgh, EH16 6SD, UK

scotsphere AI will pass requests concerning Council repair records to North Lanarkshire Council when appropriate.

What information is used?

When you use Report a Repair, Amazon processes your voice to recognise what you say. Amazon then sends the service structured information. scotsphere AI does not receive the raw Alexa audio recording.

The information can include:

• The room and repair type you select
• Your description of the problem
• Alexa request, session, user/account and device identifiers
• The time and language setting of the request
• Relevant device capabilities

The service also adds the configured property reference, address and postcode. This associates the report with the correct property.

How is the information used?

The information is used to:

• Operate the Alexa conversation
• Submit and manage the repair
• Provide a repair reference and submission status
• Prevent or investigate duplicate and failed submissions
• Maintain an operational record
• Protect the service from misuse
• Investigate and resolve technical problems

After you confirm the report, scotsphere AI sends the information to the Council's repair service. A repair record and reference are then created and stored in the Council's cloud-hosted systems.

Information is shared only with North Lanarkshire Council and authorised providers of voice recognition, secure hosting, repair management and supporting technology.

Report a Repair does not sell your information or use it for advertising.

Information you should not include

Only describe the repair and where the problem is located.

Do not provide information about your health or anyone else's health. Health information is not needed to report a repair.

Do not include:

• Financial or payment information
• Passwords or security codes
• Key locations
• Alarm details
• Other property-access information

If access arrangements are required, the Council will collect them separately through an approved process.

We do not ask for or use health information. If health information is included accidentally, it will not be used for another purpose. It will be removed where reasonably possible under the Council's instructions.

Amazon and Alexa

Amazon processes Alexa voice recordings, voice-history information and related Alexa data under Amazon's own privacy terms and your Alexa privacy settings.

scotsphere AI does not control Amazon's processing or retention of this information. You can review and manage Alexa information through your Alexa privacy settings.

Report a Repair is not sponsored, endorsed or jointly provided by Amazon.

Lawful basis

North Lanarkshire Council processes repair information because this is necessary for the performance of its public tasks as a local authority.

scotsphere AI processes the information on the Council's behalf and under the Council's instructions.

How long information is kept

Confirmed repair records are retained for three years.

The following information held by the Report a Repair service is retained for seven days:

• Incomplete session information
• Failed-submission information
• Application logs
• Operational and security logs

Amazon applies its own retention arrangements to information held in your Alexa account. You can manage this information through your Alexa privacy settings.

Processing in the United States

Some structured information used by Report a Repair is currently processed in Oregon, USA, by an authorised hosting provider.

The transfer is protected by the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. A transfer assessment has been completed.

The service also applies security, access-control, data-minimisation and short-retention measures to protect the information.

The service is being moved to hosting in the United Kingdom or European Economic Area. This notice will be updated after the move has been completed and the remaining information held in Oregon has been deleted in accordance with the applicable retention arrangements.

Your data-protection rights

Depending on the circumstances, you may have the right to:

• Ask for a copy of your personal information
• Ask for inaccurate information to be corrected
• Ask for processing to be restricted
• Object to certain uses of your information
• Ask for information to be deleted where the law allows

Further information about these rights is provided elsewhere in this privacy policy.

You can exercise your rights using the scotsphere AI contact details above. Requests relating to Council repair records will be passed to North Lanarkshire Council.

You also have the right to complain to the Information Commissioner's Office.

Information about making a complaint is available at: https://ico.org.uk/make-a-complaint/