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Privacy policy

Last updated 30 September 2026
  1. 1. Who we are
  2. 2. The data we collect
  3. 3. How we collect it
  4. 4. How we use it
  5. 5. Who we share it with
  6. 6. International transfers
  7. 7. Data security
  8. 8. Data retention
  9. 9. Your legal rights
  10. 10. Customer data on our platform
  11. 11. Glossary

01Important information and who we are

Purpose of this privacy policy

Supamodel respects your privacy and is committed to protecting your personal data. This policy explains how we collect and process personal data when you visit this website, contact us, book a call or become a customer, and tells you about your privacy rights and how the law protects you.

This website is not intended for children and we do not knowingly collect data relating to children.

This policy covers personal data for which we are the controller. It does not cover the business data our customers load into the Supamodel platform, where we act as a processor on our customer's instructions. That is explained in section 10.

Controller

Supamodel Technology Ltd (“Supamodel”, “we”, “us” or “our”) is the controller and is responsible for your personal data.

Contact details

If you have any questions about this policy or how we handle your personal data, including any request to exercise your legal rights, please contact us:

Legal entity
Supamodel Technology Ltd, a company registered in England and Wales with company number 17041702
Email
hello [at] supamodel.io
Postal address
8 Spur Road, Cosham, Hampshire, PO6 3EB, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to this policy and your duty to tell us about changes

We keep this policy under regular review. This version was last updated on 30 September 2026.

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

02The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer the following kinds of personal data about you:

  • Identity Data — first name, last name, job title and the company you work for.
  • Contact Data — business email address, telephone number and billing address.
  • Financial Data — bank account details used to pay or be paid by us.
  • Transaction Data — details of payments to and from you and the services you have bought from us.
  • Technical Data — IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data — information about how you use our website and services.
  • Marketing and Communications Data — your preferences in receiving marketing from us and your communication preferences.

We also use Aggregated Data such as statistical data. Aggregated Data may be derived from your personal data but is not considered personal data in law, as it does not directly or indirectly reveal your identity.

Special Categories of Personal Data

We do not collect any Special Categories of Personal Data about you through this website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide it when requested, we may not be able to perform that contract. In this case we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

03How is your personal data collected?

Direct interactions

You may give us your Identity, Contact and Financial Data by corresponding with us by email, phone or otherwise. This includes personal data you provide when you:

  • book a call or request a demo;
  • enquire about or buy our services;
  • ask us to send you marketing or product updates;
  • give us feedback or contact us.

Automated technologies or interactions

As you interact with our website, our hosting provider automatically records Technical Data in server logs for security and troubleshooting.

This website does not currently use analytics, advertising or tracking cookies. Our typeface is served by Google Fonts, which means your browser requests it from Google's servers and Google receives your IP address and browser details when you load a page. Google's handling of this data is described in the Google Privacy Policy and the Google Fonts privacy FAQ.

If we introduce analytics or other cookies in future, we will update this policy and ask for your consent where the law requires it. For general information about cookies, visit aboutcookies.org.

Third parties or publicly available sources

We may receive Identity and Contact Data about you from publicly available sources such as Companies House and professional networking sites like LinkedIn, and from people who introduce you to us.

04How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use it in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you or your organisation;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending direct marketing communications to you by email or text message where the law requires it. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

Purpose / activityType of dataLawful basis
Responding to enquiries and arranging calls or demos Identity, Contact Legitimate interests (to respond to people interested in our services); steps taken at your request before entering into a contract
Onboarding you or your organisation as a customer Identity, Contact Performance of a contract
Delivering our services, managing payments, fees and charges, and collecting money owed to us Identity, Contact, Financial, Transaction, Marketing and Communications Performance of a contract; legitimate interests (to recover debts due to us)
Managing our relationship with you, including telling you about changes to our terms or this policy Identity, Contact, Marketing and Communications Performance of a contract; legal obligation; legitimate interests (to keep our records updated)
Administering and protecting our business and this website, including troubleshooting, testing, system maintenance, support and hosting Identity, Contact, Technical Legitimate interests (running our business, provision of IT services, network security, fraud prevention); legal obligation
Sending you relevant product updates and information about our services Identity, Contact, Usage, Marketing and Communications Legitimate interests (to develop our services and grow our business); consent where required by law

Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We do not sell your personal data.

You can ask us to stop sending you marketing messages at any time by following the opt-out link in any marketing message or by contacting us. Opting out of marketing does not apply to personal data provided to us as a result of a service purchase or other transaction.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If you would like an explanation of how the processing for a new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

05Disclosures of your personal data

We share personal data with the service providers below, who process it on our behalf to help us run our business:

RecipientActivityLocationPrivacy terms
Google Web fonts; email, calendar, call booking and document management (Google Workspace) US / EU policies.google.com/privacy
Amazon Web Services (AWS) Website hosting and server logs; cloud infrastructure and data storage UK / EU aws.amazon.com/privacy
Xero Invoicing, bookkeeping and financial reporting US (data storage) / NZ (head office) xero.com/uk/legal/privacy

We may also share personal data with professional advisers, including lawyers, bankers, auditors and insurers, and with HM Revenue & Customs, regulators and other authorities where the law requires it.

If we sell, transfer or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way as set out in this policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order or the instructions of a government authority.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes, and only permit them to process it for specified purposes and in accordance with our instructions.

06International transfers

Some of our service providers are based outside the UK, so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by making sure at least one of the following safeguards is in place:

  • we transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
  • we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK, such as the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

07Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

08Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period, we consider:

  • the amount, nature and sensitivity of the personal data;
  • the potential risk of harm from unauthorised use or disclosure;
  • the purposes for which we process it and whether we can achieve those purposes through other means;
  • the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

09Your legal rights

Under data protection law you have rights in relation to your personal data. You have the right to:

  • Request access to your personal data (a “data subject access request”). This lets you receive a copy of the personal data we hold about you and check that we are lawfully processing it.
  • Request correction of the personal data we hold about you, so that any incomplete or inaccurate data is corrected. We may need to verify the accuracy of the new data you provide.
  • Request erasure of your personal data where there is no good reason for us to continue processing it, where you have successfully exercised your right to object, where we may have processed it unlawfully, or where we are required to erase it to comply with local law. We may not always be able to comply with a request for erasure for specific legal reasons, which we will tell you about at the time.
  • Object to processing where we are relying on a legitimate interest and something about your particular situation makes you want to object, or where we are processing your personal data for direct marketing. In some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing — asking us to suspend processing while we establish the data's accuracy, where our use is unlawful but you do not want it erased, where you need us to hold it to establish, exercise or defend legal claims, or while we verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal data to you or a third party, in a structured, commonly used, machine-readable format. This applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent. This will not affect the lawfulness of any processing carried out before you withdraw it. If you withdraw consent, we may not be able to provide certain services to you, and we will tell you if that is the case.

More information is available from the ICO's guide to individual rights. To exercise any of these rights, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or refuse to comply with it in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you to ask for further information about your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated.

10Customer data on the Supamodel platform

When an organisation uses Supamodel, we connect to its systems and process its business data — which may include personal data about that organisation's own customers, staff or suppliers — to build and run its data platform. For that data, our customer is the controller and we act as its processor.

We process customer data only on our customer's documented instructions and under the data processing terms in our agreement with them. It is not used for our own purposes, and it is never used to train AI models, ours or anyone else's. Where we use AI model providers to answer questions, we use them on zero-retention terms.

If your personal data is held by one of our customers and you want to exercise your rights over it, please contact that organisation directly. If you contact us instead, we will pass your request on to them.

11Glossary

Lawful basis

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you, both positive and negative, and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted to by law. You can obtain further information about how we assess our legitimate interests against any potential impact on you by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Service providers acting as processors, based in the UK, EU, USA and New Zealand, who provide IT, hosting, communication and accounting services, as listed in section 5.

Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the UK, who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers, based in the UK, who require reporting of processing activities in certain circumstances.

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