Privacy Policy

Graphyte Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website, (the ‘Web Site’), or uses our Products, for or via an Operator, and only collect and use your personal data as described in this Privacy Policy. Any personal data we collect will only be used as permitted by law.

Please read this Privacy Policy carefully and ensure that you understand it.

1. Information About Us

The Web Site and Products are owned and operated by Graphyte Ltd, a Limited company registered in England under company number 11273540.

Address: The Ministry, 79-81 Borough Road, London SE1 1DN

Data Protection Officer: Rob Davis.

Email address:

2. What Does This Policy Cover?

This Privacy Policy covers the following uses of data:

  • Your use of our Web Site. The Web Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
  • Operators who license our Products to enhance your experience using their services such as via offering personalised interfaces, serving relevant content for you on their web sites and mobile apps, in ads tailored to your preferences or in personalised communications such as emails or push notifications. In order to provide these Products to the Operators we require certain personal data in order to build a model of user preferences and activity so that we can personalise content to the user.
  • Employees of licensed Operators who use our Graphyte Admin platform to configure our Products.

3. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a)         The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.

b)         The right to access the personal data we hold about you. Part 9 will tell you how to do this.

c)         The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more.

d)         The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 10 to find out more.

e)         The right to restrict (i.e. prevent) the processing of your personal data.

f)           The right to object to us using your personal data for a particular purpose or purposes.

g)         The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h)         The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i)           Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 10.

5. What Personal Data Do You Collect and How?

Subject to the following, we do not collect any personal data from you.

Web Site

Our Site collects certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution.

Analytics – we use cookies to analyse user activity to improve the customer experience on the Web Site. For example, we might look at which pages are generating the most traffic, or which links are being clicked the least, in order to understand which content performs best on a given page or section of the site. We can use this information to make improvements on the functionality of the Web Site. 

Communications – We offer the Intercom chat bot functionality to our site visitors through pop-up chat and sometimes via email for longer or continued conversations. We use Intercom as a conversational marketing tool to have better interactions with our prospective customers.

If you send us an email, use our contact form or live chat and supply your email address , we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, We are the data controller responsible for such personal data.

The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of the Web Site. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes.

Our Products

Our Products are designed to allow an Operator who licenses them to be able to personalise their product offering based on explicit or implicit knowledge of user preferences and behaviours. We receive user activity data from the Operator including customer transactions and/or behavioural activity while using the Operator’s services. We collect this data either from clickstream events on the Operator’s website or mobile apps (similar to data shared by them with other analytics providers such as Google Analytics) or via secure direct feeds from the Operator’s backend platforms into our own environment. Data is only personal to the extent that it is tagged with an identifier such as an internal database ID that can be used persistently to link user behaviour and activity together so that we can build machine learning models that allow us to recommend tailored content to the user.

One use of our Products is to allow an Operator to provide tailored ads for their services while a user browses a third-party publisher using a platform such as Google Ads. Our service is used to provide relevant content to the user such as products and events that they might be interested in. In order to provide this service we drop a cookie on the user’s browser that correlates the user’s identity between the Operator’s web site and the ad serving platform. The identifier within the cookie is encrypted. If a user wishes to opt out of ads they may do this directly with the ad serving platform.

Our Graphyte Admin system ( requires a validated user account for a licensed Operator in order to operate the platform. In order to create a user account and to allow the platform to function fully (such as logging who has made changes to configuration) we require a user’s name and email address. This account will only be maintained for the duration of the user’s employment with the Operator.

6. How Do You Use My Personal Data?

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7, below.

As stated above, we do not generally collect any personal data directly from you, but if you contact us and we obtain your personal details from your email, we may use them to respond to your email. 

We will not share any of your personal data with any third parties for any purposes other than storage on an email, web hosting server or web analytics platform server.

Any personal data we collect in our capacity as Data Processor on behalf of an Operator in the provision of our Products is collected and used in accordance with the Operator’s privacy policy and terms and conditions. We will only use and keep this data for the term of the contractor between us and the Operator.

7. How and Where Do You Store My Data?

We will only store your personal data within the UK and the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, the GDPR, and/or to equivalent standards by law.

8. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

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 that we have used it, as specified in this Privacy Policy (i.e. to communicate with you).

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.

9. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

Any subject access requests for information held in our capacity as Data Processor on behalf of an Operator who licenses our Products should be made primarily to the Operator.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 40 calendar days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

10. How Can I Opt Out of Tracking Cookies?

Each Operator that uses our licenses our software will have a Privacy/Cookie policy which will discuss their use of tracking cookies to support the functioning of their sites.

As stated above, in order to support targeting in ads for our Operators we will drop a cookie containing an encrypted user identifier. Most browsers allow you to refuse to accept or to delete cookies. You can prevent cookies from being stored on your computer by modifying the settings in your web browser. Learn more about how to change cookies settings. You can also block Google from accessing and storing cookies on your computer by using a browser plugin.

Ads that rely on our technology for personalised data will allow you to remove consent for tracking and personalised data. In this case you will receive a generic version of the ad rather than more relevant content to you.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details 

for the attention of Robert Davis:

Email address:

Postal Address: Graphyte, The Ministry, 79-81 Borough Road, London SE1 1DN

12. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.Any changes will be immediately posted on the Web Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of the Web Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 8th February 2021.