Privacy Policy.

Section 01

Who we are

Ember is a growth consultancy and AI-powered lead recovery service for exotic and prestige car dealerships, operating under the trading name Ember at ember-agent.com. Ember is owned and operated by Paul Armstrong, based in the United Kingdom.

For personal data collected through this website and in the course of our business operations, Ember acts as the data controller. For personal data that our dealer clients upload to us in order to operate the Ember Agent lead reactivation service on their behalf, Ember acts as a data processor, and the dealer is the data controller.

Contact: info@ember-agent.com

Section 02

What this policy covers

This policy covers two distinct categories of data subject:

• Visitors and prospects — individuals who visit our website or submit their contact details through our forms.
• End-user leads — individuals whose contact details are provided to us by our dealer clients for the purpose of SMS lead reactivation. See Section 6 for how we handle this data.

Section 03

Information we collect

Information you provide directly

When you submit our contact form, we collect your first name, last name, job title, company name, email address, and any message you choose to include.

Technical and usage information

When you visit our website we may collect standard technical information including your IP address, browser type and version, device type, pages visited, time and date of visit, and the referring URL.

What we do not collect

We do not collect payment card information directly. We do not knowingly collect sensitive personal data such as health information, government identification numbers, or biometric data.

Section 04

How we use your information

We use the information we collect to:

• Respond to your enquiries and manage our business relationship with you;
• Provide the Ember Agent and consultancy services you have engaged us for;
• Send operational communications relating to our services;
• Understand how our website is used and improve it over time;
• Comply with our legal obligations and protect our legitimate business interests;
• With your explicit consent, send you marketing communications. You may withdraw consent at any time by contacting info@ember-agent.com.

Section 05

Legal basis for processing (UK and EU)

If you are located in the United Kingdom or the European Economic Area, we rely on the following legal bases:

• Performance of a contract — to provide the services you have engaged us for.
• Legitimate interests — to operate, improve and secure our services and communicate with existing clients.
• Consent — for marketing communications and optional analytics cookies.
• Legal obligation — to comply with applicable tax, accounting and regulatory requirements.

Section 06

Dealer data and end-user leads

When a dealer engages Ember Agent, they provide us with a list of their own past customer enquiries. In this context, the dealer is the data controller and Ember acts as a data processor, processing that data solely on the dealer's instructions for the purpose of SMS lead reactivation.

We use the lead contact data provided by the dealer exclusively to send SMS reactivation messages on the dealer's behalf, using the dealer's own registered Twilio phone number. We do not use this data for any other purpose, we do not sell it, and we do not share it with third parties other than as required to operate the messaging service.

Every SMS sent through Ember Agent includes a clear opt-out instruction. Replying STOP will immediately remove you from further contact. Lead data provided by dealers is retained only for the duration of the active service agreement and deleted within 30 days of termination.

Section 07

How we share information

We do not sell personal information. We share personal information only in the following limited circumstances:

• Service providers — trusted third-party providers including cloud hosting, SMS delivery (Twilio), analytics (Google Analytics), and AI model processing (Anthropic).
• Legal requirements — where required by law, court order, or regulatory authority.
• Business transfers — in connection with a merger, acquisition, or sale of assets.
• With your consent — in any other circumstances where you have directed us to share your information.

Section 08

International transfers

Ember is based in the United Kingdom. Some of our service providers — including Twilio, Anthropic, and Google — are based in the United States. Where we transfer personal data of UK or EEA residents to countries not deemed adequate, we rely on appropriate safeguards including the UK International Data Transfer Agreement (IDTA) and EU Standard Contractual Clauses (SCCs).

Section 09

Data retention

• Enquiry and contact data — retained for as long as the business relationship exists, or for a reasonable period thereafter.
• Client and billing records — retained for a minimum of six years to comply with UK accounting and tax obligations.
• Dealer lead data — retained only for the duration of the active engagement, then deleted within 30 days of termination.
• Website analytics data — retained in aggregated or anonymised form per our analytics provider's terms.

Section 10

Security

We take reasonable administrative and technical measures to protect personal information, including encrypted transmission via TLS, access controls, and use of reputable third-party platforms with their own security certifications.

No method of transmission over the internet is completely secure. If you believe your data may have been compromised, please contact us immediately at info@ember-agent.com.

Section 11

Your privacy rights

UK and EU residents (UK GDPR / EU GDPR)

You have the right to access the personal data we hold about you, request correction of inaccurate data, request deletion, request restriction of processing, object to processing based on legitimate interests, request portability of your data, and withdraw consent where we rely on it.

California residents (CCPA / CPRA)

If you are a California resident, you have the right to know what personal information we collect and how it is used, request deletion, request correction, and opt out of the sale of personal information. We do not sell personal information.

How to exercise your rights

Email info@ember-agent.com. We will respond within 30 days. UK residents may also lodge a complaint with the Information Commissioner's Office at ico.org.uk.

Section 12

Cookies

Our website uses essential cookies required for basic functionality, and optional analytics cookies to understand how visitors use the site. Where required by law, we request your consent before setting non-essential cookies. See our Cookie Policy for full details.

Section 13

Children's privacy

Our services are intended for business use and are not directed at children under the age of 13. We do not knowingly collect personal information from children.

Section 14

Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the date at the top of this page. Your continued use of our website after any update constitutes acceptance of the revised policy.

Section 15

Contact us

Email: info@ember-agent.com · Website: ember-agent.com · Jurisdiction: United Kingdom

For UK residents: Information Commissioner's Office — ico.org.uk