Privacy Policy

1. About this Privacy Policy

This Privacy Policy explains how SXNTH LTD, trading as SXNTH.AI® ("SXNTH.AI", "we", "us" or "our"), collects and uses personal data, who we share it with, how we protect it, how long we keep it, and the choices and rights available to you.

It applies where SXNTH.AI acts as a controller of personal data in connection with our website, apps and portals, enquiries, events, accounts, recruitment, business development, direct marketing, client relationships and other services that link to this policy.

This policy is written primarily for our current UK operations. If privacy laws in another country apply to a particular activity, we will apply the relevant local requirements and may provide an additional or jurisdiction-specific notice. We do not treat a general reference to international operations as a claim that every privacy law applies to every user or activity.

2. Who we are and our role

SXNTH LTD is a company registered in the United Kingdom with company number 16768167. Our registered office is 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom. SXNTH LTD is registered with the UK Information Commissioner’s Office under registration number ZC123407.

For our website, business contacts, marketing, account administration and our own business operations, SXNTH.AI will normally act as the controller of your personal data.

When a client asks us to process personal data strictly on its behalf, SXNTH.AI may act as a processor and the client will normally be the controller. In that situation, the client’s privacy notice and our contract or Data Processing Addendum will govern that processing. If you send us a rights request relating to data we process only for a client, we may need to pass the request to that client.

3. Personal data we may collect

The information we collect depends on how you interact with SXNTH.AI. It may include:

Identity and contact information, such as your name, business email address, telephone number and contact preferences.

Professional and business information, such as employer, job title, business sector, role, company details and professional interests.

Account and authentication information used to create, secure and manage an account or connected service.

Communications, enquiries and support information, including messages, meeting notes, feedback and correspondence with us.

Website, device and usage information, such as IP address, browser information, device information, pages visited, timestamps and security or diagnostic data.

Cookie and preference information, including consent choices and settings managed through our cookie controls.

Client and service information that you or your organisation provide when using our services, including documents, files, workflow information and integration data.

AI feature information, which may include prompts, files, instructions, outputs, feedback and related technical metadata where you choose to use an AI-enabled feature.

Transaction and billing information, such as billing contacts, payment status and transaction records. Payment card information may be handled directly by our payment provider rather than stored by SXNTH.AI.

Marketing and prospect information, including the source of the contact, relevant business interests, campaign history, responses, unsubscribe status and suppression records.

Recruitment information if you apply to work with us, such as your CV, work history, skills, application information and interview records.

We do not ask you to provide special category data or criminal offence data unless it is genuinely necessary for a defined purpose. If we need to process this type of information, we will identify an appropriate additional legal condition and apply proportionate safeguards.

4. Where personal data comes from

We may receive personal data from:

You directly, for example when you complete a form, contact us, create an account, attend an event, book a meeting, apply for a role or use an SXNTH.AI service.

Your employer, organisation or another client where they are authorised to provide the information to us.

Your use of our website, apps, devices, integrations or services.

Publicly available professional and business sources, including company websites, professional profiles and public registers.

Specialist B2B data and prospecting providers.

Service providers and integrations that you or your organisation choose to connect to SXNTH.AI.

Where we obtain your personal data from another source, we will provide the information required by applicable data protection law. Where we use that information to communicate with you, we aim to make the relevant privacy information available at or before our first communication, unless an applicable exemption applies or you already have the information.

5. Why we use personal data and our lawful bases

We only process personal data where we have a lawful basis. Depending on the activity, we may rely on one or more of the following:

Purpose | Examples | Typical lawful basis

Provide and manage services | Accounts, client delivery, support, bookings, service communications | Contract; legitimate interests

Operate and secure our systems | Authentication, access control, abuse prevention, logging, incident response | Legitimate interests; legal obligation where applicable

Manage business relationships | Enquiries, proposals, meetings, account management, procurement | Contract; steps before contract; legitimate interests

B2B marketing and business development | Relevant outreach, newsletters, event invitations, follow-up | Legitimate interests where permitted; consent where required

Cookies and non-essential tracking | Analytics, preferences and non-essential website technologies | Consent where required

Payments and records | Billing, invoices, financial administration | Contract; legal obligation

Improve our services | Quality, reliability, usability, product and service improvement | Legitimate interests; consent where required

Recruitment | Applications, interviews, selection, onboarding | Steps before contract; legitimate interests; legal obligation

Legal and regulatory matters | Rights requests, complaints, disputes, legal claims, regulator engagement | Legal obligation; legitimate interests

Where we rely on legitimate interests, we consider the purpose, whether the processing is necessary, your reasonable expectations, the likely impact on you and the safeguards available. You can contact privacy@sxnth.ai if you want more information about a legitimate interests assessment relevant to your data.

6. B2B marketing, business contacts and third-party data sources

SXNTH.AI uses targeted B2B outreach to identify and communicate with organisations and professional contacts where we believe our services may be relevant to their work. We aim to keep this activity proportionate, relevant and transparent.

For UK business contacts at corporate subscribers such as limited companies and limited liability partnerships, the PECR consent rule for electronic mail does not generally apply in the same way as it does to individual subscribers. UK GDPR still applies whenever we process personal data about an identifiable business contact. Where appropriate, we normally rely on legitimate interests for relevant B2B marketing to corporate business contacts.

Sole traders and certain partnerships receive different protection under PECR. We do not rely on the corporate-subscriber approach for those contacts where consent or another specific PECR route is required.

For B2B prospecting, we may obtain professional contact information from public business sources and specialist B2B data providers. This may include your name, job title, employer, business email address, business telephone number and related professional information.

If we contact you using information obtained indirectly, this Privacy Policy explains our identity, purposes, lawful basis, relevant data categories, sources and your rights. You may also contact us if you want more detail about the source information we hold for you. For questions about SXNTH.AI’s B2B outreach, including how we obtained professional contact information, email support@outreach.sxnth.ai.

You have an absolute right to object to the use of your personal data for direct marketing. Every marketing email should provide a simple way to opt out. You can also object by replying to the message or emailing privacy@sxnth.ai. Once you object, we will stop using your personal data for direct marketing.

We may keep the minimum information needed on a suppression or do-not-contact list so that your preference continues to be respected and you are not accidentally added back into a future campaign.

Where a B2B data provider notifies us of a valid removal or opt-out request relating to data we previously obtained through that provider, we review the request and take the required action across relevant systems, subject to any independent legal basis that permits or requires us to retain particular information.

7. Cookies, analytics and communication tracking

Our website and apps may use cookies and similar technologies for security, essential functionality, preferences, analytics and, where enabled, other purposes explained in our Cookie Policy. We use consent controls for non-essential technologies where consent is required.

Email and communication technologies can also create privacy obligations. Our current UK cold B2B outreach policy is to keep open tracking disabled by default unless SXNTH.AI has established an appropriate legal basis and satisfied any consent requirement that applies to the specific technology. We may still process ordinary delivery, bounce, reply and security information needed to operate communications and protect our systems.

For more information about website cookies and controls, please see our Cookie Policy.

8. AI, machine learning and automated processing

Some SXNTH.AI services use AI or machine learning to help analyse information, generate content, support workflows, make recommendations or improve how work is carried out. Human judgement and appropriate oversight remain part of our operating approach.

If you use an AI-enabled feature, information such as prompts, files, instructions, outputs and feedback may be processed to provide that feature, maintain security, troubleshoot problems and improve service quality. We may use specialist AI service providers where appropriate and subject to relevant contractual, privacy and security controls.

SXNTH.AI does not use personal data submitted through client workspaces to train general-purpose AI models unless this has been clearly disclosed in advance and there is an appropriate contractual and lawful basis for doing so. We may use properly anonymised or aggregated information for analytics, quality measurement and service improvement where that information is no longer personal data.

Automated tools may support recommendations, matching, prioritisation or other decision-support activities. Unless a feature-specific notice says otherwise, these outputs are intended to support human decision-making. If SXNTH.AI uses solely automated processing that produces legal or similarly significant effects, we will provide the additional information and safeguards required by applicable law.

9. Who we share personal data with

We may share personal data only where necessary and proportionate with:

Cloud hosting, storage, software, communications, security, analytics, authentication, scheduling, payment and other technology service providers.

AI and machine-learning service providers used to deliver approved AI-enabled functionality.

CRM, marketing and B2B data providers used for business development and communications.

Clients, partners or professional advisers where this is necessary to provide a service, manage a relationship, obtain advice or protect legal rights.

Authorities, regulators, courts or law-enforcement bodies where disclosure is required or permitted by law.

A potential buyer, investor, lender or successor organisation in connection with a genuine financing, restructuring, acquisition, sale or similar corporate transaction, subject to appropriate confidentiality and data-protection controls.

Where another organisation processes personal data on our behalf, we use appropriate contractual and due-diligence controls. Where an organisation acts as an independent controller, it is responsible for its own processing and privacy information.

SXNTH.AI does not sell personal data as a standalone product. If a law applicable to a future service uses broader definitions of "sale" or "sharing", we will provide the disclosures and choices required by that law.

10. International data transfers

Some service providers or recipients may process personal data outside the United Kingdom. Where this creates a restricted transfer under UK data protection law, we use an approved transfer route appropriate to the circumstances.

This may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the European Commission Standard Contractual Clauses, or another lawful safeguard. Where required, we assess the transfer and the protections available in the destination country and apply additional measures where appropriate.

As SXNTH.AI expands internationally, we will review local transfer, localisation and privacy requirements before launching data-processing activities in new jurisdictions.

11. How long we keep personal data

We keep personal data only for as long as it is reasonably needed for the purpose for which it was collected, to meet legal or regulatory requirements, to establish or defend legal claims, or to maintain an appropriate audit or security record.

Our retention decisions take account of the type and sensitivity of the data, the purpose of the processing, the length of the relationship, contractual requirements, legal obligations, security needs and whether the information can be anonymised.

In particular:

Client and account records may be kept for the duration of the relationship and for an appropriate period afterwards where needed for legal, contractual, accounting, security or audit purposes.

Marketing and prospect information is reviewed for relevance and is deleted or anonymised when it is no longer needed, subject to suppression requirements.

Suppression records may be retained for as long as needed to make sure we continue to respect an objection or unsubscribe request.

Security and technical logs are retained for a proportionate period based on operational, security and audit needs.

Recruitment records are retained in line with the purpose of the recruitment process and any applicable legal requirements.

Where a contract or service-specific notice sets a more specific retention period, that period will apply to the relevant processing.

12. How we protect personal data

We use proportionate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Depending on the system and risk, these measures may include access controls, encryption, authentication, least-privilege access, logging and monitoring, vulnerability management, secure development practices, supplier due diligence, backups, incident response and staff confidentiality obligations.

No organisation can guarantee absolute security. We therefore review risks, controls and incidents as part of our ongoing governance process. Security concerns can be reported to security@sxnth.ai.

13. Your data protection rights

Depending on the law and circumstances that apply, you may have rights to:

Ask for access to personal data we hold about you.

Ask us to correct inaccurate or incomplete information.

Ask us to erase personal data in certain circumstances.

Ask us to restrict processing in certain circumstances.

Object to processing based on legitimate interests.

Object at any time to processing of your personal data for direct marketing. This right is absolute.

Withdraw consent where processing is based on consent. Withdrawal does not affect processing that was lawful before withdrawal.

Receive or transfer certain personal data where the right to data portability applies.

Receive appropriate safeguards and information where qualifying automated decision-making applies.

Make a complaint about how we handle your personal data.

To exercise a privacy right, contact privacy@sxnth.ai. We may need to verify your identity and may ask for information needed to locate the relevant data. Rights are subject to the conditions and exemptions set out in applicable law.

14. Data protection complaints

If you are concerned about how SXNTH.AI has handled your personal data, you can raise a data protection complaint by emailing privacy@sxnth.ai. Please tell us what happened, what information or activity concerns you and, where possible, the outcome you are seeking.

We will acknowledge a data protection complaint within the period required by UK law, currently within 30 days, investigate it appropriately and communicate the outcome. We may ask for further information where this is reasonably necessary to investigate the complaint.

You also have the right to raise a concern or complaint with the UK Information Commissioner’s Office. More information is available at https://ico.org.uk/make-a-complaint/.

15. Children and young people

Our general website, business services and B2B communications are intended for organisations and professional users and are not directed at children. We do not knowingly collect personal data from children under 16 through our general services. If a specific SXNTH.AI service is designed to involve younger users, we will provide an appropriate service-specific privacy notice and safeguards before that processing begins.

16. Changes to this policy

We may update this Privacy Policy when our services, technology, suppliers, legal obligations or operating model change. We will publish the updated version with a revised effective date. Where a change is material and the law requires additional notice or consent, we will take the appropriate steps before the new processing begins.

17. Contact us

Privacy and data protection: privacy@sxnth.ai

Compliance and Data Processing Addendum enquiries: compliance@sxnth.ai

Security concerns: security@sxnth.ai

Registered office: SXNTH LTD trading as SXNTH.AI®, 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom

Company number: 16768167

ICO registration number: ZC123407