Privacy policy

Who we are

The data controller for this policy is HMG AI LTD, company number 16147848. The registered office is Suite RA01, 195-197 Wood Street, London, E17 3NU, United Kingdom. The company is not VAT registered.

We trade as OptiOrg, Gayn, and NexQ. “We”, “us”, and “our” mean HMG AI LTD. OptiOrg is run by Aidan Hall, the director.

Privacy requests: leads@optiorg.ai:leads@optiorg.ai. Phone: +443300243335:+44 330 024 3335.

What this policy covers

This policy covers:

• optiorg.ai, and any OptiOrg application that links to this policy, including a web app and a mobile app if we publish one
• Gayn, the AI receptionist at gayn.co.uk, including calls, texts, transcripts, and bookings
• NexQ websites at nexq.co.uk, together with the cookie and enquiry notice already published at nexq.co.uk/privacy
• the systems we run for a customer: the app, the receptionist, and the sites we host

Where nexq.co.uk/privacy describes cookies and enquiry forms on that marketing site, that description still applies to nexq.co.uk. This policy is the one for this website, for Google account data connected to OptiOrg, and for Gayn call handling.

ClubDesk, our class-booking app for clubs, has its own privacy policy at /clubdesk/privacy and its own terms at /clubdesk/terms. The club is the controller of its families’ data, including children’s class records. ClubDesk’s Google connection is Calendar and the connecting account’s email. The Gmail scopes in section 5 belong to the separate OptiOrg mailbox tools.

Controller and processor

We are the controller for our own business: accounts on the app, our enquiries, our invoices, and our own marketing to businesses.

We are the processor when we handle personal data on a customer’s instructions. That includes callers to a Gayn number, people who fill in a form on a site we built for a customer, and the contacts a customer stores in the app. The customer decides why that data is collected and must have a lawful basis for it. We process it to provide the service. A data processing addendum is available on request from leads@optiorg.ai.

A call to a dental practice, a clinic, or a law firm can include information the caller chooses to say about health or a legal matter. We process that only so the receptionist can take the message, book, or pass it on. We do not use it to market to the caller.

The OptiOrg app

The app is how the work is run. Access is by an account we issue. You must be 18 or over to hold an account. For an account we collect the name, email, role, timezone, and currency on the profile, and a record of invitations and sign-in.

Depending on what the account uses, the app stores:

• CRM records: company, contact name, work email, phone, job title, notes, tasks, deals, quotes, invoices, and files
• messages the account sends or receives: email, SMS, and WhatsApp, including the number, the text, delivery status, and any media attached to a WhatsApp message
• call logs: number, direction, time, duration, outcome, and notes
• calendar events once Google Calendar is connected: title, time, location, meeting link, and attendees
• project material for a website build: pages, assets, domains, and client feedback
• support tickets, audit history, and form submissions, which can include the IP address and browser type of the person who submitted the form, used to deal with spam

If a user saves an Anthropic API key in settings, we store it for that account and use it only when they run a drafting feature. If they connect GitHub, we store the token and GitHub login they authorise and use them on the repositories for that project.

Google account data

This section is the OptiOrg mailbox connection. ClubDesk does not use it. Connecting Google here is optional. The OptiOrg app asks for these Google scopes, and only these:

• Google Calendar (https://www.googleapis.com/auth/calendar) so meetings can be read and written on the calendar the user connects
• Gmail read (gmail.readonly) so replies can be matched to the right contact
• Gmail modify (gmail.modify) so labels and read state can stay in step with the record in the app
• Gmail send (gmail.send) so mail can be sent from that mailbox
• OpenID, email, and profile, so we know which Google account is connected

We use that data to file conversations against the right contact, send the messages the user asks the app to send, and show or create the meetings they book. We do not use Gmail or Calendar data for advertising. We do not sell it. We do not use it to train public models. We do not transfer it to a third party except the processors in section 11, and only so the service can run.

People can read Google data in the app when they are signed in to the account that connected it. Someone at HMG AI LTD reads it only with the customer’s permission, to support that account, to keep the service secure, or where the law requires it.

OptiOrg’s use and transfer of information received from Google APIs to any other app will adhere to the //developers.google.com/terms/api-services-user-data-policy:Google API Services User Data Policy, including the Limited Use requirements.

You can disconnect Google by emailing leads@optiorg.ai from the account address. If the app shows a disconnect control, that does the same thing. We then stop calling Google for that account and delete the stored tokens within 30 days. Messages and events already saved onto a contact record stay with that record until the record is deleted or the retention period in section 13 ends, because they are the business record the account asked us to keep.

Gayn calls, texts, and bookings

Gayn is an AI receptionist for UK service businesses. It answers inbound calls, takes the job details, books where the plan includes booking, and texts the business a summary and transcript. It identifies itself as an AI on the call. It does not claim to be a person.

To do that we process:

• the live call audio, so the receptionist can hear the caller and speak back
• a transcript, the caller’s name, number, postcode, and the reason for the call, where the caller gives them
• the audio recording itself, where the setup for that customer stores recordings
• SMS to the business, and confirmation texts to the caller when the service sends them
• calendar bookings on the Book and Engage plans
• the business knowledge the customer approves before go-live: services, prices, service area, common questions, and the name and voice of the receptionist

The business customer is responsible for telling callers, where the law requires it, that an AI will answer and that the call may be transcribed or recorded. Gayn is not an emergency service.

The speech is handled by our telephony provider (Twilio) and by the voice and language providers that run the receptionist. Those providers act on our instructions for that call. We will name a voice provider on this page when a customer’s setup uses one fixed vendor.

Websites and enquiries

If you email us or submit a form on optiorg.ai, gayn.co.uk, or nexq.co.uk, we collect the details you type: name, email, phone if you give it, business name, and the message. We use them to reply and, if you go ahead, to do the work.

On a website we build for a customer, the form fields are the customer’s. Submissions are delivered to the customer and may also sit in the app. We host those sites on Cloudflare.

A waitlist email for OptiOrg, if you join one, is stored with the date and the page you joined from, and is used only to tell you when access is available or to reply to you.

Business contacts and marketing

We keep business contact records for companies we may work with. A record can include name, role, work email, phone, company, LinkedIn URL, and notes about a conversation. Some of those details come from the person, some from the public Companies House register, and some are checked or filled in by Apollo.io.

We email businesses about work they asked for, and we may email a corporate address about our services where the law allows it. Every marketing email has a way to opt out. We keep a suppression list so an opt-out is honoured. We do not add a personal email address, or a sole trader, to a marketing sequence unless we have a lawful basis to do so.

If an enquiry arrives from a Google ad, the contact record may store the click id and campaign name. We may send an offline conversion back to Google Ads so we can see which ads led to a real enquiry. That upload is the click id and the fact of the conversion, not the content of a call or an email.

Cookies

optiorg.ai does not use analytics or advertising cookies. It does not run Google Analytics or Microsoft Clarity.

gayn.co.uk and nexq.co.uk use a cookie banner. Strictly necessary cookies (security, and storing the cookie choice) are always on. Google Analytics 4, Google Ads measurement, and Microsoft Clarity run only if the visitor accepts them. The cookie names and lifetimes for NexQ are listed at //nexq.co.uk/privacy:nexq.co.uk/privacy. Gayn’s banner offers the same choice: accept analytics, or necessary cookies only.

Why we use personal data

Under UK GDPR we rely on:

• Contract — to provide the app, Gayn, or a NexQ site you have asked for, and to keep invoices
• Legitimate interests — to answer an enquiry before a contract exists, to keep our own business records, to secure the service, and to contact corporate subscribers about relevant work, balanced against their rights and always with an opt-out
• Consent — analytics cookies, and any marketing that needs consent. You can withdraw consent at any time
• Legal obligation — tax and accounting records

Caller and end-customer data inside Gayn or a client website is processed on the business customer’s instructions. Their basis is theirs to establish. Ours, as processor, is the contract with that business.

Who we share it with

We do not sell personal data. We share it with the processors below, with a business customer when the data is theirs, and with a professional adviser or authority when the law requires it.

Supabase. Application database for accounts, CRM records, projects, and stored Google tokens. The main database is in the EU (Frankfurt). The contracts database is in the EU (Ireland).

Cloudflare. Hosting, DNS, and protection for our sites and for websites we host for customers.

Twilio. Phone calls, SMS, and WhatsApp for Gayn and for messages sent from the app. Twilio sees the numbers, the audio or message content needed to deliver them, and delivery status.

Google. Gmail and Google Calendar when an account connects them. Google Analytics 4 and Google Ads only on Gayn and NexQ, and only if the visitor accepts analytics cookies. Offline conversion uploads use a click id, not the content of a call.

Microsoft Clarity. Session recordings and heatmaps on gayn.co.uk and nexq.co.uk, only if the visitor accepts analytics cookies.

Resend and Postmark. Transactional email, such as enquiry notifications. Postmark is part of ActiveCampaign. Message content and addresses needed to send the email are processed by them.

Apollo.io. Checking and filling in business contact details (work email, role, company, phone) for B2B records.

Anthropic. Drafting help inside the app when that feature is used. The prompt can include the business details the user included in the draft. We send only what that feature needs.

GoCardless. Direct debit and card payments for NexQ. GoCardless collects the bank or card details. We do not store the full account number.

GitHub. Only if a user connects GitHub. We store the token, login, and avatar they authorise, and use them on the repositories for that project.

Documenso. Contract signing. The signer’s name, email, and the signed document are stored so we can keep the agreement.

Voice and language providers that speak or transcribe a Gayn call receive the audio and the business knowledge needed for that call. They are processors for that purpose.

Where data is held

The OptiOrg application database is hosted by Supabase in the EU. Call audio and messages pass through Twilio, which operates internationally. Google, Microsoft, Resend, Postmark, Apollo, Anthropic, Cloudflare, and a voice provider may process data outside the UK.

Where a transfer is outside the UK and there is no adequacy regulation, we use the provider’s UK International Data Transfer Addendum or standard contractual clauses.

How long we keep it

• Enquiry correspondence with no contract: 12 months, then deleted or reduced to the minimum
• Invoices, contracts, and accounting records: 6 years after the end of the financial year they belong to
• App CRM records: for as long as the account is open, then 12 months, unless a shorter deletion is requested and the law lets us delete them
• Google tokens: deleted within 30 days of disconnect or account deletion
• Gayn transcripts: while the subscription is active and for 12 months after it ends
• Gayn audio, where a recording is stored: 90 days, unless the customer asks us to delete it sooner or the law requires longer
• Marketing suppression records: kept so we do not email that address again
• Analytics, where accepted: about 14 months for Google Analytics 4 and 13 months for Microsoft Clarity, under those providers’ settings
• Server security logs: up to 90 days

Security

Sites are served over HTTPS. Access to the application database is limited by account and role, with row-level security on the application tables. Google tokens and API keys are available to the signed-in account and to administrators who operate the service. No method of storage is perfect. If a breach creates a risk to people, we will tell those people and the ICO where the law requires it.

Your rights, and how to delete an account

If we are the controller, you can ask us to:

• confirm whether we hold personal data about you, and for a copy
• correct it
• delete it
• restrict it, or object to processing based on legitimate interests
• receive data you provided, in a portable format, where the basis is contract or consent
• withdraw consent, including cookie consent and any marketing consent

Delete an account. Email leads@optiorg.ai?subject=Delete%20my%20OptiOrg%20account:leads@optiorg.ai from the account email address with the subject “Delete my OptiOrg account”. We confirm the request and delete or anonymise the account within 30 days. We keep invoices and other records the law tells us to keep, and we keep a suppression entry if you have opted out of marketing. There is no fee for a deletion request.

If we hold data only as processor for one of our business customers, we will pass the request to that customer or help them answer it. Callers to a Gayn number should contact the business they called, and can also email us so we can point the request at the right account.

We reply to rights requests within one month.

Children

The OptiOrg app, Gayn as a product, and NexQ are for businesses. You must be 18 or over to hold an account. We do not knowingly create an account for a child, and we do not build marketing profiles of children. ClubDesk does store children’s details that a parent or a club enters for a class. That processing is described in the ClubDesk privacy policy.

A member of the public who calls a Gayn number, including a young person calling a clinic or a household, is handled only so the business can take that call. That content is the business customer’s data.

Changes

We update this policy when the product or the law changes. The date at the top is the latest version. For a material change to how the app uses Google data or call recordings, we will email the account address before the change applies. The previous public page on optiorg.ai said the policy was still being finalised. This page replaces that notice.

Contact and the ICO

HMG AI LTDSuite RA01, 195-197 Wood Street, London, E17 3NU, United Kingdomleads@optiorg.ai:leads@optiorg.ai+443300243335:+44 330 024 3335

You can complain to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or at //ico.org.uk:ico.org.uk. We would like the chance to put a problem right first.

Also read the privacy policy and the terms and conditions. Questions go to leads@optiorg.ai:leads@optiorg.ai.