Privacy Policy
1. Who we are
1.1 This privacy policy explains how Skye Line Trades Ltd ("Skye Line Trades", "we", "us" or "our") collects and uses personal data.
1.2 We are a company incorporated in England and Wales with company number 17358493. Our registered office is at Suite 3b, Kings House, 1 King Street, Leeds LS1 2HH. Our website is skyelinetrades.com (the "Website").
1.3 We provide an AI receptionist service (the "Service") that answers inbound telephone calls on behalf of our business customers (tradespeople), takes messages and bookings, and passes them on.
1.4 If you have any questions about this policy or wish to exercise your rights, contact us at support@skyelinetrades.com.
1.5 We have assessed that we are not currently required to appoint a Data Protection Officer, and we keep that assessment under review. Privacy matters are handled by the company's director, contactable at the address above.
2. The two capacities in which we act
We handle personal data in two distinct capacities, and the difference matters.
2.1 As controller. For personal data about our own business customers, prospective customers, and visitors to the Website — for example the account, contact, billing and enquiry data of the tradespeople who subscribe to or enquire about the Service — we are the controller. This means we decide how and why that data is used, and this policy governs how we do so.
2.2 As processor. For personal data about the callers and end-clients whose calls are handled by the Service — for example a member of the public who telephones a tradesperson's number — we act as a processor on behalf of our customer. The tradesperson customer is the controller of that caller data and decides the purposes for which it is used. Our handling of it is governed by the data processing agreement between us and that customer (the "DPA"), and by the customer's own privacy notice to their callers.
2.3 This policy focuses mainly on the data for which we are the controller. Where we act as a processor, we handle caller data only on the customer's documented instructions, as set out in the DPA.
3. The personal data we collect
3.1 As controller, we collect and use:
(a) Account and contact data — name, business name, email address, telephone number, and the login details of the customers and individuals who register for or enquire about the Service;
(b) Billing and payment data — billing details and payment records. Card and bank details are handled directly by our payment processor and are not stored by us;
(c) Prospective customer data — the business contact details of tradespeople we contact about the Service, as described in Clause 5;
(d) Website data — information you submit through the Website contact form, and the technical data necessary to operate and secure the Website, namely your IP address, browser and device information, and server logs. Technical data is retained for up to 12 months (see also Clause 11); and
(e) Support and correspondence data — the content of emails and support requests you send to us.
3.2 As processor, on behalf of our customers we handle:
(a) Call data — the audio of inbound calls, the transcripts generated from those calls, and the messages, booking details and caller contact information captured during a call. This may include the caller's name, telephone number, address, and details of the job or enquiry.
3.3 We do not seek to collect special category data (such as data about health, racial or ethnic origin, religious beliefs or sexual orientation) or criminal-offence data through the Service. Because callers speak freely, a caller may occasionally mention such information during a call. Where that happens it is handled as ordinary call data and deleted within the retention periods in Clause 7.
4. Why we use personal data, and our lawful bases (controller data)
As controller, we use personal data for the following purposes, relying on the lawful bases indicated:
| Purpose | Lawful basis |
|---|---|
| To provide, administer and support the Service and manage your account and subscription | Performance of a contract with you |
| To take payment and manage billing | Performance of a contract; compliance with a legal obligation (tax and accounting records) |
| To respond to your Website enquiries and support requests | Our legitimate interests in responding to and assisting prospective and existing customers |
| To send you service-related communications about your account or the Service | Performance of a contract; our legitimate interests in operating the Service |
| To contact tradespeople about the Service (see Clause 5) | Our legitimate interests in marketing our services to relevant businesses |
| To comply with our legal and regulatory obligations | Compliance with a legal obligation |
| To establish, exercise or defend legal claims and protect the security of our systems | Our legitimate interests in protecting our business; compliance with a legal obligation |
Where we rely on legitimate interests, we have assessed that those interests are not overridden by your interests or fundamental rights and freedoms.
5. Prospective customers and marketing
5.1 We contact tradespeople and trades businesses to tell them about the Service. Where those contact details relate to an identifiable individual — for example a sole trader — they are personal data and this policy applies to them.
5.2 Where we get the data. We obtain business contact details from publicly available sources, including online business directories, mapping and listing services, and business websites. We do not buy marketing lists of consumer data. If you ask us, we will tell you the specific source your details came from.
5.3 What we hold. Business name, contact name where published, business telephone number, business email address where published, trade, and business location, together with a record of our contact with you.
5.4 Lawful basis. We rely on our legitimate interests in promoting a service relevant to your business. We do not make marketing calls to numbers registered with the Telephone Preference Service (TPS) or Corporate Telephone Preference Service (CTPS) unless you have told us directly that we may call you. You can object to this processing at any time (see Clause 12).
5.5 Screening. Before calling, we screen numbers against the Telephone Preference Service (TPS) and Corporate Telephone Preference Service (CTPS), and against our own do-not-contact records.
5.6 Opting out. You can ask us to stop contacting you at any time, by telling the caller, by replying to any message, or by emailing support@skyelinetrades.com. We will stop, and we will keep a minimal record of your details on a suppression list so that we do not contact you again. That is the only reason we retain them.
5.7 Retention. Prospect data is deleted when it is no longer relevant to our outreach, and in any event within 24 months of the last contact, apart from suppression records under Clause 5.6.
6. Purposes for which caller data is used (processor data)
6.1 When we handle caller data as a processor, we do so only for the following purposes, on the customer's instructions:
(a) operating the Service — answering the call, capturing the message or booking, and passing it on to the tradesperson customer;
(b) keeping records for quality, dispute-resolution and support purposes;
(c) sharing call summaries and transcripts back with the tradesperson customer whose calls they are; and
(d) producing call and usage records for billing and account management. This uses call counts and durations, not the content of calls or caller contact details.
6.2 We do not use call audio, transcripts or any caller data to train, develop or improve artificial-intelligence or machine-learning models. AI training is expressly excluded as a purpose.
7. How long we keep personal data
7.1 We keep personal data only for as long as necessary for the purposes described in this policy, and then delete or anonymise it. In particular:
(a) call audio recordings are retained for 1 month and then deleted;
(b) transcripts are retained for 6 months and then deleted;
(c) account, billing and correspondence data is retained for the duration of your subscription and then for as long as needed to meet our legal, tax and accounting obligations (typically up to 6 years) and to defend potential legal claims;
(d) prospective customer data is retained as set out in Clause 5.7; and
(e) where deletion from backup media is not immediately possible, we isolate the data, protect it from further processing, and delete it in accordance with our backup cycle.
7.2 Retention of caller data handled on behalf of customers mirrors the periods in Clause 7.1(a) and (b) and is set out in the DPA.
8. Who we share personal data with
8.1 We share personal data with third-party service providers who help us operate the Service, including providers of voice orchestration and call handling, speech-to-text transcription, conversational AI, text-to-speech, payment processing, support-inbox hosting, and website hosting. These providers act on our instructions and are bound by contractual data-protection obligations.
8.2 We will tell you which providers we use, what each does and where it processes data, on request from support@skyelinetrades.com. The same list is set out in Schedule 1 to the DPA, which forms part of the contract for customers who subscribe to the Service. That list separates the providers who handle call audio, transcripts and caller information from those who support our business but never see caller data.
8.3 We may also disclose personal data where required by law or to a regulator, to our professional advisers, and in connection with the sale or reorganisation of our business.
8.4 We do not sell personal data.
9. International transfers
9.1 Some of our sub-processors are located outside the UK, including in the United States.
9.2 Where we transfer personal data outside the UK, we put in place the appropriate safeguards required by UK data protection law. These will be one or more of:
(a) UK adequacy regulations, where these apply to the destination country;
(b) the UK International Data Transfer Agreement (IDTA); or
(c) the EU Standard Contractual Clauses together with the UK International Data Transfer Addendum,
in each case supported by a transfer risk assessment and, where appropriate, additional technical and organisational measures.
9.3 You may contact us at support@skyelinetrades.com for more information about the safeguards we use.
10. Security
10.1 We take appropriate technical and organisational measures to protect personal data, including encryption in transit and at rest, access controls and authentication (including multi-factor authentication where the platform supports it), restricting access to those who need it, and applying automated retention and deletion settings.
10.2 No system can be guaranteed completely secure, but we review our measures regularly and require equivalent standards from the providers we use.
11. Cookies
11.1 We use only strictly necessary (essential) cookies and similar technologies required to operate the Website and keep it secure. We do not use analytics, advertising or other non-essential cookies. The server logs and technical data described in Clause 3.1(d) are not cookies; they are generated automatically when you visit the Website and are used for security and operational purposes.
11.2 Because we use only strictly essential cookies, no consent is required under the Privacy and Electronic Communications (EC Directive) Regulations 2003, and we do not display a cookie consent banner.
12. Your rights
12.1 Under UK data protection law, in respect of personal data for which we are the controller, you have the right to:
(a) be informed about how your data is used;
(b) access a copy of your data;
(c) have inaccurate data corrected;
(d) have your data erased in certain circumstances;
(e) restrict processing in certain circumstances;
(f) object to processing based on our legitimate interests, and to object to direct marketing at any time, which we will always act on;
(g) data portability in certain circumstances;
(h) not be subject to a decision based solely on automated processing that produces legal or similarly significant effects on you; and
(i) complain to us directly about how we have handled your personal data, under section 164A of the Data Protection Act 2018 (see Clause 14).
12.2 In respect of personal data for which we are the controller, we do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. The AI components of the Service transcribe calls, capture messages and produce summaries; they do not make automated decisions about callers or end-clients.
12.3 To exercise any of these rights, contact us at support@skyelinetrades.com. We will respond within the time limits required by law, usually one month. There is normally no charge. If we decide not to act on your request, we will tell you why, and we will tell you about your right to complain to us under Clause 14 and to the ICO.
12.4 If you are a caller or end-client and your data was handled through the Service on a tradesperson's behalf, that tradesperson is the controller of your data. Please direct your request to them. We will assist them in responding, as set out in the DPA.
13. Children
The Service and the Website are directed at businesses and are not intended for children. We do not knowingly collect personal data from children.
Where caller data is handled through the Service on behalf of a customer, and a caller is a child, that customer is the controller of that data and is responsible for ensuring appropriate safeguards.
14. Complaints and the ICO
14.1 We are registered with the Information Commissioner's Office (ICO) and pay the data protection fee. Our registration number is ZA__________.
14.2 Your right to complain to us. Under section 164A of the Data Protection Act 2018 you have the right to complain to us directly if you believe we have handled your personal data in breach of data protection law. You can complain:
(a) using the contact form at skyelinetrades.com/contact, marking your message as a data protection complaint;
(b) by email to support@skyelinetrades.com; or
(c) by post to Skye Line Trades Ltd at the address in Clause 16.
We will accept a complaint however it reaches us, and you do not have to use any particular route.
14.3 What we will do. We will acknowledge your complaint within 30 days of receiving it. We will take appropriate steps to investigate it, including making any necessary enquiries, without undue delay. We will keep you informed of progress and tell you the outcome and how we reached it.
14.4 Our records. We keep a record of the complaints we receive, when we received and acknowledged them, the steps we took, and the outcome.
14.5 Complaining to the ICO. If you are unhappy with our response, or with how we handled your complaint, you can complain to the ICO. You can do this at any time, but the ICO will usually expect you to have raised the matter with us first.
- website: ico.org.uk
- helpline: 0303 123 1113
- post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
15. Changes to this policy
We may update this policy from time to time. We will publish the current version on the Website and update the "Last updated" date above. Where changes are material, we will notify existing customers by email.
16. Contact us
For any privacy question, or to exercise your rights, contact us at support@skyelinetrades.com, or write to us at Skye Line Trades Ltd, Suite 3b, Kings House, 1 King Street, Leeds LS1 2HH.