Privacy Policy

Scope of this Policy and Direct Agreements

Ares runs structured, AI-led conversations with the employees of the organisations we work with. We typically enter into a separate written agreement with each client or partner organisation (a "Direct Agreement") that governs what Personal Data we may collect from that organisation's employees, how we may use it, what we track, and how long we retain it.

This Policy applies as follows:

• Visitors to our public websites and direct contacts. Ares is the data controller of your Personal Data and this Policy applies in full.
• Conversation participants covered by a Direct Agreement. Where a Direct Agreement is in place, your employer (or the organisation that engaged Ares) is the data controller and Ares processes your Personal Data as a data processor on its behalf. The Direct Agreement governs that processing, and you should refer to your employer's privacy notice for details.
• Engagements without a Direct Agreement. Where no Direct Agreement covers a conversation or engagement, this Policy governs and Ares acts as the data controller.

To the extent of any conflict between this Policy and an applicable Direct Agreement, the Direct Agreement prevails.

1. Personal Data We Collect

In this Policy, "Personal Data" means any information relating to an identified or identifiable natural person. We may collect and process Personal Data about you in the ways outlined below. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our services if that information is necessary to provide you with them or if we are legally required to collect it.

Information provided by you

• When you participate in an Ares conversation. If you take part in a conversation conducted through our Platform, we will process the content of your responses. Conversations are voice-based: your audio is recorded and transcribed, and your responses are processed using third-party voice infrastructure and AI services in order to conduct the conversation and produce insights for the organisation that engaged us.
• When you access our Platform. If you engage with our Platform, for example to schedule or join a conversation or to review outputs, you may provide us with Personal Data such as your name, contact details, and the company you work for.
• When you contact us. If you contact us using a contact form, via email, or by other means, you may provide us with Personal Data, such as your name and contact details, the company you work for, and the content, date and time of our communications.

Information collected via automated means

• Cookies and similar technologies. We use cookies and similar technologies (collectively "cookies") to ensure that our Platform functions properly, to improve our products and services and to assist with marketing campaigns. Cookies are small text files containing a string of alphanumeric characters. We and third-party partners collect information using cookies, pixel tags, or similar technologies. We and third-party service providers may use the following cookies:
  • Functional cookies. Some cookies are strictly necessary to make our Platform available to you. For example, to provide login functionality, to join a conversation, or to allow you to fill out forms. We cannot provide you with the Platform without this type of cookie.
  • Analytics cookies. We use cookies for website analytics purposes in order to operate, maintain and improve our Platform. We work with third parties such as PostHog for these purposes.
• The information collected via such cookies may include information such as your IP address, time spent on the Platform, actions taken on the Platform, device information, searches, interactions, hardware information, and other related information.

Information collected from other sources

• Information provided by your employer or our clients. If the organisation you work for engages Ares, we may receive Personal Data about you from that organisation, such as your name, work email address, and role or department, in order to schedule and conduct conversations.

2. How We Use Personal Data

We will only process your Personal Data based on a valid legal ground. The table below describes the legal ground by purpose. It applies where Ares acts as the data controller; where a Direct Agreement applies, the purposes of processing are determined by the client on whose behalf we act.

3. How We Share Your Personal Data

We may share your Personal Data with third parties in the following circumstances:

• Service providers, vendors and analytics partners. We work with third party service providers to operate our Platform, including for IT-hosting and infrastructure, data processing and caching, voice conversation infrastructure, AI and speech processing, and other services. These third parties may have access to or process your Personal Data as part of providing those services to us. In addition, we use analytics service providers such as PostHog to collect and process certain analytics data.
• Our clients and partners. Where conversations are conducted on behalf of a client or partner organisation, conversation outputs and insights are shared with that organisation as described in the applicable Direct Agreement.
• Legal. We may disclose your Personal Data to third parties if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose your Personal Data that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Platform and any facilities or equipment used to make our Platform available, or (v) protect our property or other legal rights, including to enforce our agreements, or the rights, property, or safety of others.
• Merger. We may disclose or otherwise transfer Personal Data to an acquirer, investor, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, financing or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• Consent. We may also disclose your Personal Data with your permission.

4. Data Retention

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we need to retain certain information as required by law, including to comply with tax requirements, or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations. Where conversations are conducted under a Direct Agreement, the retention of conversation recordings and transcripts is governed by that agreement.

5. Your Rights in Relation to Your Personal Data

Depending on where you reside, you may also have the following legal rights:

• Access and Portability. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have provided to us, and request information about its processing.
• Rectification and Deletion. You may ask us to update and correct inaccuracies in your Personal Data, or to have the information anonymised or deleted, as appropriate.
• Restriction and Objection. You may ask us to restrict the processing of your Personal Data, or object to such processing.
• Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
• Complaint. You may lodge a complaint with the UK Information Commissioner's Office, who you can contact using the details found at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.

You may exercise these rights by contacting us using the contact details at the end of this Policy. Please note that there are exceptions and limitations to each of these rights. Where we process your Personal Data as a data processor under a Direct Agreement, we may refer your request to your employer (the data controller) and will assist them in responding to it.

6. Third Parties

Our Platform may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

7. Security

We make reasonable efforts to protect your Personal Data by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information, to the extent permitted by applicable law.

8. Children's Privacy

We do not knowingly collect, maintain, or use Personal Data from children under 18 years of age, and no part of our Platform is directed to children. If you learn that a child has provided us with Personal Data in violation of this Policy, then you may alert us by contacting us using the contact details at the end of this Policy.

9. Cross-Border Data Transfers

We use service providers that may store or process your Personal Data outside of the United Kingdom, including in the United States and the European Economic Area. Where this happens, your Personal Data may be transferred to, and stored and processed in, those regions.

We will comply with applicable data protection laws when transferring your Personal Data outside of the UK. In particular we will rely on (i) UK adequacy regulations, (ii) contractual protections for the transfer of your Personal Data, or (iii) another valid data transfer mechanism. You may contact us as specified below for more information about the safeguards we use to transfer Personal Data outside the UK.

10. Changes to this Policy

We may update this Policy from time to time to reflect changes in our privacy practices. If we modify this Policy, we will indicate the date of the latest revision at the top of this Policy.

11. Our contact information

Should you have any queries regarding this Policy, about Ares' processing of your Personal Data or if you wish to exercise your rights with respect to your Personal Data, you can contact Instruct AI LTD (trading as Ares Intelligence) by email: [email protected] or by writing to us at: 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE.