Last updated: 15 October 2026
1. Who we are
Prosper AI Systems ("we", "us", "our") is a UK AI-automation agency providing the Quote Rescue Engine. We are the data controller for the personal data described in this policy.
- Legal entity: John Hogarth, a sole trader trading as Prosper AI Systems
- Registered/business address: Venture Towers, Portsmouth, PO1 5DL, United Kingdom
- Email: [email protected]
- ICO registration: We are in the process of registering with the ICO.
We have not appointed a Data Protection Officer as we are not required to; questions should go to the email above.
2. The personal data we collect
| Category | Examples | Source |
|---|---|---|
| Identity & contact | First name, email address, phone number (optional) | You, via our forms |
| Consent & preference records | Whether you opted in to marketing emails, date/time, form used, IP address | Our forms / CRM |
| Customer & account data | Name, email, business name, login credentials (hashed), app usage | You, via our app |
| Transaction data | Products bought, amounts, dates, billing name/address. We do not see or store full card details. | Stripe / GoHighLevel checkout |
| Communications | Emails and messages you send us; email opens and clicks | You / our email platform |
| Technical & usage data | IP address, device/browser type, pages viewed, cookie identifiers | Your device, via cookies and similar technologies |
We do not intentionally collect special category data. Our services are intended for businesses and are not directed at children under 18.
3. How and why we use your data
| Purpose | Lawful basis (UK GDPR Art. 6) |
|---|---|
| Sending you the free Growth Pack you requested | Contract / steps at your request (Art. 6(1)(b)) |
| Sending marketing and nurture emails | Consent (Art. 6(1)(a)) and PECR reg. 22 |
| Marketing SMS and phone follow-up (only if you gave a phone number and ticked the SMS/phone box) | Consent (Art. 6(1)(a)) and PECR regs. 21–22 |
| Processing payments and delivering what you bought | Contract (Art. 6(1)(b)) |
| Providing and securing your Quote Rescue Engine account | Contract (Art. 6(1)(b)); legitimate interests in security |
| Keeping accounting and tax records | Legal obligation (Art. 6(1)(c)) |
| Replying to enquiries and service messages | Legitimate interests / contract |
| Non-essential cookies and analytics | Consent (PECR reg. 6) |
| Improving our website and services, preventing fraud | Legitimate interests (Art. 6(1)(f)) |
4. The free Growth Pack opt-in
When you request the Growth Pack we ask for your first name, email address and, optionally, your phone number. We use these to deliver the Growth Pack. If you tick the marketing consent box, which is never pre-ticked, we will also send you a short email nurture sequence and occasional emails about our services. Ticking the box is not a condition of receiving the Growth Pack. We keep a record of when and how you consented.
If you give us your optional phone number, the form has a separate, unticked box for SMS and phone follow-up. The wording is: "I'd like Prosper AI Systems to contact me by SMS and phone about my Growth Pack and related services. I can opt out at any time by replying STOP or by emailing us." We will only text or call you for marketing if you tick that box. We do not make marketing calls to numbers registered with the Telephone Preference Service (TPS) unless you have specifically agreed to receive our calls. You can opt out of SMS by replying STOP, and out of calls by telling us during a call or by emailing [email protected].
5. Email nurture and withdrawing consent
You can withdraw your consent at any time, free of charge, by clicking "unsubscribe" in any marketing email, by replying STOP to any text, or by emailing [email protected]. We will then add you to a suppression list so we do not contact you again. Withdrawing consent does not affect any processing that took place before you withdrew it. We may still send essential service or transactional messages, for example receipts or account notices.
6. Who we share data with (processors)
We use trusted service providers that process data on our behalf under written contracts:
| Provider | Purpose | Location / safeguard |
|---|---|---|
| GoHighLevel (HighLevel Inc.) with LeadConnector (GoHighLevel's messaging service), which uses carriers such as Twilio | CRM, forms, funnel pages, email, SMS and calls, checkout | USA – UK Extension to the EU-US Data Privacy Framework (UK-US data bridge) where the provider is certified, otherwise the UK International Data Transfer Addendum to the EU Standard Contractual Clauses |
| Stripe (Stripe Payments Europe Ltd / Stripe, Inc.) | Payment processing through our GoHighLevel checkout. Stripe is also an independent controller for fraud prevention and regulatory purposes. | UK/EU/USA – UK-US Data Bridge / SCCs |
| Supabase (Supabase Inc.) | App accounts, authentication and database for the Quote Rescue Engine | London, UK (AWS eu-west-2); IDTA/SCCs for any US support access |
| Netlify (Netlify, Inc.) | Website and app hosting; server logs (IP address, request data) | USA – UK-US Data Bridge / SCCs |
| GoHighLevel built-in page analytics | Website usage statistics (with consent). If we add other analytics tools we will update this policy and they will only run with your consent. | USA – UK Extension to the EU-US Data Privacy Framework (UK-US data bridge) where the provider is certified, otherwise the UK International Data Transfer Addendum to the EU Standard Contractual Clauses |
| Professional advisers (accountants, legal) | Accounting and compliance | UK |
We may also disclose data where the law requires it, or as part of a sale or restructuring of our business. We never sell your personal data.
7. International transfers
Some providers above store or access data outside the UK. Where they do, we rely on UK adequacy regulations (including the UK-US Data Bridge for certified organisations) or the ICO's International Data Transfer Agreement/Addendum to the EU Standard Contractual Clauses.
8. Cookies and analytics
When you first visit our pages a cookie banner asks for your choice. You can Accept all, Reject non-essential, or open Settings and choose by category:
| Category | Purpose | Consent needed? |
|---|---|---|
| Strictly necessary | Make pages, forms, checkout and app log-in work, and remember your cookie choice | No (always on) |
| Analytics | Help us understand how visitors use our site | Yes, off by default |
| Marketing | Measure ad campaigns and show relevant ads | Yes, off by default |
Analytics and marketing scripts are blocked until you opt in. Rejecting is as easy as accepting. Your choice is saved in your browser's local storage (key prosper_cookie_consent) for up to 12 months, after which we ask again. You can change your mind at any time with the "Cookie settings" link in our page footer, or by clearing your browser storage.
9. How long we keep your data
| Data | Retention |
|---|---|
| Growth Pack leads who do not become customers | 24 months after your last interaction with us, then deleted |
| Marketing suppression list (after unsubscribe) | Email address kept only as long as needed to honour your opt-out |
| Consent records | For as long as we rely on the consent, plus 2 years |
| Customer and transaction records | 6 years after the end of the financial year (HMRC requirements) |
| App account data (Supabase) | For the life of the account; deleted within 90 days of account closure, unless we must keep it for legal reasons |
| Hosting/server logs | About 30 days |
| Analytics data | 14 months |
10. Your rights
Under UK data protection law you have the right to: - access a copy of your personal data; - rectification of inaccurate data; - erasure ("right to be forgotten"); - restrict processing; - object to processing based on legitimate interests, and an absolute right to object to direct marketing; - data portability; - withdraw consent at any time; - not be subject to solely automated decisions with legal or similarly significant effects (we do not make such decisions).
To exercise any right, email [email protected]. We will respond within one month, and usually there is no fee. We may need to verify your identity.
11. Security
We use access controls, encryption in transit (HTTPS), reputable processors and least-privilege access to protect your data. No online system is completely secure, but we will notify you and the ICO of a qualifying breach where required.
12. Complaints
If you have a concern, please contact us first at [email protected]. You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority: - Website: ico.org.uk/make-a-complaint - Helpline: 0303 123 1113 - Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
13. Changes to this policy
We may update this policy from time to time. The latest version will always be on this page, with the "last updated" date above.
14. Contact us
Prosper AI Systems, Venture Towers, Portsmouth, PO1 5DL, United Kingdom Email: [email protected]