Privacy Policy

This Privacy Policy explains how Flair Technologies Ltd ("we", "us", "our") collects, uses, stores, and protects personal data when you use Lupo ("Lupo" or the "Service").

Lupo is an AI inbound sales intake and booking service for service businesses. Lupo may help participating businesses answer calls, respond to enquiries, qualify customer requests, schedule appointments, and send transactional booking-related communications.

We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and applicable privacy and communications laws.

1. Data We Collect

We collect only the data reasonably necessary to provide, operate, secure, and improve Lupo.

This may include:

• Account and business information, such as name, business name, email address, phone number, role, login information, and billing or account details.
• Customer enquiry information, such as customer name, phone number, email address, requested service, appointment preferences, booking details, and notes provided during a phone call, web form, or website chat handoff.
• Communication data, such as call transcripts, call summaries, messages, support requests, webhook submissions, and booking-related communications.
• Calendar and integration data, where a business connects third-party services such as calendar, email, messaging, CRM, or voice providers.
• Usage and technical data, such as app activity, diagnostics, device or browser information, logs, IP address, performance metrics, and security events.
• SMS and mobile messaging data, such as mobile phone number, messaging consent status, opt-out status, message delivery status, and transactional booking-message history.

We do not intentionally collect unnecessary personal data.

2. How We Use Data

We use personal data to:

• provide and operate Lupo;
• answer calls and enquiries on behalf of participating businesses;
• qualify customer requests;
• create, update, or cancel bookings;
• send transactional customer-care communications, including booking confirmations, booking updates, cancellations, requested callback status, and support-related messages;
• notify business owners or authorised staff about leads, bookings, or escalations;
• provide customer support;
• secure, monitor, debug, and improve the Service;
• comply with legal, regulatory, accounting, and security obligations.

We do not sell or rent personal data.

3. SMS and Mobile Messaging

Lupo may collect mobile phone numbers and messaging consent when a customer:

• calls a participating business;
• submits a website enquiry form;
• requests a callback through website chat;
• books or updates an appointment;
• provides or confirms a mobile number for booking-related communication.

Mobile numbers are used only for transactional customer-care messages, such as appointment confirmations, booking updates, cancellations, requested callback status, and support-related communications.

Text messaging originator opt-in data and consent will not be shared with any third parties except service providers necessary to deliver the messaging service.

Customers may opt out of SMS messages by replying STOP. Customers may request help by replying HELP. Message and data rates may apply. Message frequency varies based on booking and enquiry activity.

4. Legal Bases for Processing

We process personal data under one or more of the following lawful bases:

• performance of a contract;
• legitimate interests, such as providing and improving the Service, preventing fraud, maintaining security, and supporting participating businesses;
• consent, where required for certain communications or integrations;
• compliance with legal obligations.

Where we rely on consent, you may withdraw that consent at any time.

5. Third-Party Processors and Integrations

We use trusted third-party service providers to operate Lupo. These may include cloud hosting providers, database providers, authentication providers, voice and telephony providers, SMS providers, email providers, analytics and logging providers, calendar providers, and payment or billing providers.

These providers process data only as necessary to provide services to us and are not permitted to use personal data for their own marketing.

Where required, we use written agreements with processors and appropriate safeguards for international data transfers.

6. AI and Automation

Some features of Lupo use automated processing and AI systems to understand enquiries, generate summaries, assist with qualification, and support booking workflows.

AI outputs may be imperfect. Participating businesses are responsible for reviewing and using Lupo appropriately in their own operations.

We design Lupo to minimise unnecessary personal data exposure and to protect access to customer information.

7. Data Retention

We retain personal data only for as long as reasonably necessary to provide the Service, support customers, comply with legal obligations, resolve disputes, maintain security, and enforce agreements.

Retention periods may vary depending on the type of data, the participating business's configuration, legal requirements, and operational needs.

You may request deletion of your data by contacting privacy@lupolabs.ai, subject to legal, contractual, and operational limitations.

8. Security

We use technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

These measures may include encryption, access controls, authentication, audit logging, least-privilege access, and operational security reviews.

No system is perfectly secure, and we cannot guarantee absolute security.

9. Your Rights

Depending on your location and relationship with Lupo, you may have rights to:

• access your personal data;
• request correction;
• request deletion;
• object to or restrict processing;
• request data portability;
• withdraw consent;
• complain to a data protection authority.

To exercise your rights, contact privacy@lupolabs.ai.

10. Children's Privacy

Lupo is not intended for individuals under 18. We do not knowingly collect personal data from children.

11. Third-Party Links

Lupo may link to third-party websites, services, or integrations. We are not responsible for their privacy practices. Please review their policies separately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The Effective Date above shows when it was last updated. Material changes may be communicated within the Service, by email, or by other reasonable means.

13. Contact Us

For privacy questions or data requests:

Email: privacy@lupolabs.ai

Address:
Flair Technologies Ltd
45 Fitzroy St
Fitzrovia
London W1T 6EB
United Kingdom

Enterprise customers: See our Data Processing Addendum where applicable.