# Privacy Policy

> Discentra Ltd's Privacy Notice. Last updated 17 March 2026. Explains what personal information we collect, how we process it, our legal bases under GDPR and UK GDPR, sub-processors, retention, your rights, and how to contact us.

## Last updated: 17 March 2026

This Privacy Notice for Discentra Ltd ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

- Visit our website at https://discentra.ai or any website of ours that links to this Privacy Notice
- Use our AI voice coaching platform for financial institutions. Discentra detects behavioural triggers in traders and delivers real-time coaching calls to improve performance and reduce churn. We do not provide financial advice.
- Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at deinde@discentra.ai.

## Summary of key points

This summary provides key points from our Privacy Notice. You can find more detail in the full sections below.

**What personal information do we process?** When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us, the choices you make, and the products and features you use.

**Do we process any sensitive personal information?** No. We do not process sensitive personal information.

**Do we collect any information from third parties?** No. We do not collect any information from third parties.

**How do we process your information?** We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

**In what situations and with which parties do we share personal information?** We may share information in specific situations and with specific third parties (sub-processors listed below).

**How do we keep your information safe?** We have organisational and technical processes and procedures in place to protect your personal information. No transmission over the internet can be guaranteed 100% secure.

**What are your rights?** Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information.

**How do you exercise your rights?** Submit a data subject access request, or contact us at deinde@discentra.ai.

## Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. Do we use cookies and other tracking technologies?
6. Is your information transferred internationally?
7. How long do we keep your information?
8. How do we keep your information safe?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Controls for Do-Not-Track features
12. Do United States residents have specific privacy rights?
13. Do other regions have specific privacy rights?
14. Do we make updates to this notice?
15. How can you contact us about this notice?
16. How can you review, update, or delete the data we collect from you?

## 1. What information do we collect?

### Personal information you disclose to us

**In short:** We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include the following:

- Names
- Email addresses
- Job titles

**Sensitive Information.** We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

### Information automatically collected

**In short:** Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting.

The information we collect includes:

- **Log and Usage Data.** Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services.
- **Device Data.** Information about your computer, phone, tablet, or other device you use to access the Services. This may include IP address, device and application identification numbers, location, browser type, hardware model, ISP and/or mobile carrier, operating system, and system configuration.
- **Location Data.** Information about your device's location, which can be either precise or imprecise. You can opt out by disabling your Location setting on your device.

## 2. How do we process your information?

**In short:** We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

- To respond to user inquiries and offer support to users.
- To send administrative information to you, such as details about our products and services, changes to our terms and policies.
- To send you marketing and promotional communications, in accordance with your marketing preferences. You can opt out at any time.
- To identify usage trends so we can improve our Services.
- To save or protect an individual's vital interest, such as to prevent harm.

## 3. What legal bases do we rely on to process your information?

**In short:** We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on. We may rely on:

- **Consent.** We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
- **Performance of a Contract.** We may process your personal information when necessary to fulfil our contractual obligations.
- **Legitimate Interests.** We may process your information when reasonably necessary to achieve our legitimate business interests, where those interests do not outweigh your rights and freedoms. For example, to send users information about offers, or to analyse how our Services are used so we can improve them.
- **Legal Obligations.** We may process your information for compliance with our legal obligations, such as cooperating with a law enforcement body or regulatory agency.
- **Vital Interests.** We may process your information where necessary to protect your vital interests or those of a third party.

In legal terms, we are generally the 'data controller' under European data protection laws of the personal information described in this Privacy Notice, since we determine the means and/or purposes of the data processing we perform. This Privacy Notice does not apply to the personal information we process as a 'data processor' on behalf of our customers. In those cases, the customer is the 'data controller'.

If you are located in Canada, this section applies to you. We may process your information with express or implied consent. You can withdraw consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without consent (for example, fraud detection, legal subpoenas, publicly available information specified by regulations, witness statements relating to insurance claims, identifying injured persons, or de-identified information for approved research, subject to ethics oversight).

## 4. When and with whom do we share your personal information?

**In short:** We may share information in specific situations and/or with the following third parties.

**Vendors, Consultants, and Other Third-Party Service Providers.** We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties.

The third parties we may share personal information with are:

- **Advertising, Direct Marketing, and Lead Generation:** HubSpot CRM
- **Functionality and Infrastructure Optimisation:** Cal.com
- **Web and Mobile Analytics:** PostHog
- **Website Hosting:** Vercel

We also may need to share your personal information in the following situations:

- **Business Transfers.** We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.

## 5. Do we use cookies and other tracking technologies?

**In short:** We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising. To the extent these technologies are deemed to be a 'sale' or 'sharing' (which includes targeted advertising, as defined under applicable laws) under US state laws, you can opt out by submitting a request as described in section 12 below.

Specific information about how we use such technologies is set out in our Cookie Notice: https://discentra.ai/cookies.

## 6. Is your information transferred internationally?

**In short:** We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. Regardless of your location, your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information, including facilities in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, those countries may not have data protection laws as comprehensive as those in your country. We will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

**European Commission's Standard Contractual Clauses.** We have implemented measures to protect your personal information, including using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations.

## 7. How long do we keep your information?

**In short:** We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as necessary for the purposes set out, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 90 days.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if not possible (for example, because it has been stored in backup archives), we will securely store it and isolate it from any further processing until deletion is possible.

## 8. How do we keep your information safe?

**In short:** We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission or storage technology can be guaranteed 100% secure. Transmission of personal information to and from our Services is at your own risk.

## 9. Do we collect information from minors?

**In short:** We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 (or the equivalent age in your jurisdiction) or that you are the parent or guardian of such a minor and consent to such minor's use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under age 18, please contact us at deinde@discentra.ai.

## 10. What are your privacy rights?

**In short:** Depending on your state of residence in the US or in some regions (such as the EEA, UK, Switzerland, and Canada), you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to:

1. Request access and obtain a copy of your personal information.
2. Request rectification or erasure.
3. Restrict the processing of your personal information.
4. Where applicable, data portability.
5. Not be subject to automated decision-making.

In certain circumstances, you may also have the right to object to the processing of your personal information.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK Information Commissioner's Office.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

**Withdrawing your consent.** If we are relying on your consent, you have the right to withdraw at any time by contacting us using the details below.

**Opting out of marketing.** Unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in our emails, or by contacting us. You will be removed from the marketing lists.

**Cookies and similar technologies.** Most web browsers accept cookies by default. You can set your browser to remove or reject cookies. See our Cookie Notice: https://discentra.ai/cookies.

If you have questions or comments about your privacy rights, you may email us at deinde@discentra.ai.

## 11. Controls for Do-Not-Track features

Most web browsers include a Do-Not-Track ('DNT') feature you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. We do not currently respond to DNT browser signals. If a standard is adopted that we must follow in the future, we will inform you in a revised version of this Privacy Notice.

## 12. Do United States residents have specific privacy rights?

**In short:** If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you, correct inaccuracies, get a copy of, or delete your personal information.

### Categories of personal information we collect

| Category | Collected |
|---|---|
| A. Identifiers (name, postal address, IP address, email, account name) | Yes |
| B. Personal information as defined in the California Customer Records statute (name, contact information, employment history, financial information) | Yes |
| C. Protected classification characteristics (gender, age, race, marital status) | No |
| D. Commercial information (transaction information, payment information) | No |
| E. Biometric information (fingerprints, voiceprints) | No |
| F. Internet or other similar network activity | Yes |
| G. Geolocation data (device location) | Yes |
| H. Audio, electronic, sensory, or similar information | No |
| I. Professional or employment-related information | Yes |
| J. Education Information | No |
| K. Inferences drawn from collected personal information | No |
| L. Sensitive personal Information | No |

We will use and retain the collected personal information as needed to provide the Services or for:

- Category A: 1 year
- Category B: 1 year
- Category F: 6 months
- Category G: 6 months
- Category I: 1 year

### Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories for a business or commercial purpose: A, B, F, G, I.

### Your rights

You have rights under certain US state data protection laws. These rights are not absolute, and in certain cases we may decline your request as permitted by law. Rights include:

- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies
- Right to request deletion
- Right to obtain a copy of personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of processing for targeted advertising, sale, or profiling

Depending on the state where you live, you may also have:

- Right to access categories of personal data being processed (Minnesota)
- Right to obtain a list of categories of third parties to which we have disclosed data (California, Delaware, Maryland)
- Right to obtain a list of specific third parties (Minnesota, Oregon)
- Right to obtain a list of third parties to which we have sold data (Connecticut)
- Right to review, understand, question, and where applicable correct profiling (Connecticut, Minnesota)
- Right to limit use and disclosure of sensitive personal data (California)
- Right to opt out of collection of sensitive data and personal data collected via voice or facial recognition (Florida)

### How to exercise your rights

To exercise these rights, contact us by submitting a data subject access request, by emailing deinde@discentra.ai, or by referring to the contact details below.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof of valid authorisation.

### Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.

### Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing deinde@discentra.ai. We will inform you in writing of any action taken or not taken in response to the appeal. If your appeal is denied, you may submit a complaint to your state attorney general.

### California 'Shine The Light' law

California Civil Code Section 1798.83 permits California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. To submit such a request, contact us using the details below.

## 13. Do other regions have specific privacy rights?

**In short:** You may have additional rights based on the country you reside in.

### Australia

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 (Privacy Act). This Privacy Notice satisfies the notice requirements defined in the Privacy Act.

If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services.

You have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint to the Office of the Australian Information Commissioner.

## 14. Do we make updates to this notice?

**In short:** Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice or by directly sending you a notification.

## 15. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at deinde@discentra.ai or contact us by post at:

**Discentra Ltd**
9 Gurner Avenue
Salford
Manchester M5 3WP
England, United Kingdom

If you are a resident in the United Kingdom, we are the 'data controller' of your personal information. We have appointed Deinde Alubankudi to be our representative in the UK. Contact directly by email at deinde@discentra.ai, by visiting https://discentra.ai/get-in-touch, or by post to the address above.

## 16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request, or email deinde@discentra.ai.

## Related links

- [Terms of Service](https://discentra.ai/terms)
- [Cookie Policy](https://discentra.ai/cookies)
- [Get in Touch](https://discentra.ai/get-in-touch)

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