It would be helpful to start by explaining some key terms used in this policy:
We may collect and use the following personal information about you:
This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.
We collect most of this personal information directly from you—in person, by telephone, text or email and via our website. However, we may also collect information:
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
|---|---|
| To provide products and services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you or Powdr Ltd | For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you |
| Conducting checks to identify our customers and verify their identity. Screening for financial and other sanctions or embargoes. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business. | To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, e.g. policies covering security and internet use | For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations. |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations. |
| Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products. |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you. |
| Marketing our services and those of selected third parties where we have consent to existing and former customers | For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers |
| External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations. |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
We have determined, acting reasonably and considering the circumstances, that we are able to rely on legitimate interests as the lawful basis on which to process your personal information in certain circumstances (we have stated this above and set out our legitimate interests). We have reached this decision by carrying out a balancing exercise to make sure our legitimate interest does not override your privacy rights as an individual.
We consider that it is reasonable for us to process your information for the purposes of our legitimate interests outlined above as: (a) we process your information only so far as is necessary for such purpose; and (b) it can be reasonably expected for us to process your information in this way.
This tool allows Authorised Users to upload a file (such as a spreadsheet) which is automatically converted into a Powdr financial model. In relation to personal data:
This tool is a Claude-powered AI assistant embedded within Powdr’s AWS environment. It is used by Powdr staff and Authorised Users of Enterprise Subscriptions to support financial model analysis, variance analysis and reporting. As standard, the AI tool will only process company related data and metrics however if a document is uploaded that contains personal data by a user, personal data may inadvertently by analysed by the AI tool.
In relation to the handling of such personal data:
Neither the AI Upload Conversion Tool nor the AI Insights Tool is used to make automated decisions about you that produce legal effects or similarly significantly affect you. AI outputs are always subject to human review by Powdr staff before any action is taken where it is used in support of a client. Your right not to be subject to solely automated decision-making (see ‘Your Rights’ below) is therefore not engaged by our use of these tools.
If you do not wish for your company data to be processed using AI Features, please contact your Powdr account manager or our Data Protection Officer at the address below. Please note that opting out of AI processing may affect the scope and pricing of services available to you under your subscription.
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and Why We Use Your Personal Information’). However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside Powdr Ltd for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by: contacting us at Nicola@powdr.co.uk or using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We routinely share personal information with:
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party unless we have gained your explicit permission to do so.
Clients of Powdr have entered into or shall enter into a data sharing and processing agreement (the “data processing and sharing agreement”) to govern the processing and sharing of personal data in accordance with all applicable law relating to privacy and the protection of personal data.
Where a Client holds an Enterprise Subscription, the data processing and sharing agreement will additionally address the processing of personal data through AI Features, consistent with the terms set out in Powdr’s Terms and Conditions and this Privacy Policy.
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who We Share Your Personal Information With’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring Your Personal Information Out of the EEA’.
All data processed through AI Features is held and processed within Powdr’s AWS infrastructure, on servers based in the United Kingdom.
We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
Personal and company details provided during sign up will be held on our systems for a minimum of 3 years. If you would like your information to be removed from our systems after this point you can email us to request this.
Finance details entered as part of the model build will be held on our systems for a minimum of 3 years post any termination of a contract. If you would like your information to be removed from our systems you can email us to request this.
Other information such as customer feedback or survey information will be stored for 3 years then original documentation will be removed. Feedback may still be used after this point but will be made anonymous unless we have your permission to use your details.
Files uploaded via the AI Upload Conversion Tool that contain personal data are deleted immediately upon completion of the conversion process and are not retained. The converted Powdr model is retained in accordance with the standard retention period above.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
You have the following rights, which you can exercise free of charge:
| Right | Description |
|---|---|
| Access | The right to be provided with a copy of your personal information (the right of access) |
| Rectification | The right to require us to correct any mistakes in your personal information |
| To be forgotten | The right to require us to delete your personal information – in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal information – in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations |
| To object | The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests. |
| Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. See ‘Automated Decision-Making’ above for how this applies to our AI Features. |
| Withdraw consent | You can withdraw your consent although this does not impact the processing up to the point of withdrawal. |
For further information on each of those rights, including the circumstances in which they apply, please contact us – see below ‘How to Contact Us’.
If you would like to exercise any of those rights, please:
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.
Access to AI Features is restricted to Powdr staff and Authorised Users of Enterprise Subscriptions. All AI processing takes place within our ISO 27001 certified AWS environment. No personal data processed through AI Features leaves our controlled infrastructure.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at: First Contact Team, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was first published in August 2024 and was last updated in April 2026 to reflect the introduction of AI Features.
We may change this privacy notice from time to time where the need arises. If this impacts the way we contact you or use your data, we will inform you by email.
Please contact us if you have any questions about this privacy policy or the information we hold about you.
