Privacy Policy

Privacy Policy

axleo Systems Ltd Last updated: 26 March 2026

1. Who we are

axleo Systems Ltd ("axleo", "we", "us", "our") provides an AI-powered call analysis platform for UK motor dealerships. We process call recordings to generate transcriptions, compliance checks, coaching insights, and analytics for our customers.

For the purposes of UK data protection law, axleo Systems Ltd is the data processor when handling call recordings and related data on behalf of dealerships (who are the data controllers). For data we collect directly from visitors to our website or from prospective customers, we act as the data controller.

Contact for privacy matters: privacy@axleo.co.uk

2. What this policy covers

This policy explains how we collect, use, store, and protect personal data in connection with:

  • Our website at axleosystems.com and related domains
  • The axleo platform and dashboard
  • Call recordings, transcriptions, and AI-generated analysis
  • Communications with prospective and existing customers

3. Personal data we collect

3.1 Website visitors

When you visit our website, we may collect:

  • Technical data such as IP address, browser type, device information, and pages visited
  • Contact details you provide when requesting a demo (name, email, company name, job title)

3.2 Platform users (dealership staff)

When dealership staff use the axleo platform, we process:

  • Account information: name, email address, role, dealership association
  • Usage data: login activity, features accessed, actions taken within the dashboard

3.3 Call data (processed on behalf of dealerships)

When dealerships connect their phone systems to axleo, we process:

  • Call recordings (audio files)
  • Call metadata: date, time, duration, caller and agent identifiers
  • AI-generated transcriptions of call content
  • AI-generated analysis: compliance scores, coaching feedback, sentiment indicators, action items
  • Customer names and details mentioned during calls

For call data, the dealership is the data controller. They are responsible for ensuring they have a lawful basis for recording calls and sharing recordings with axleo for processing. This typically requires informing callers that calls are recorded and may be analysed using AI.

4. How we use personal data

4.1 Lawful bases

We process personal data under the following lawful bases as defined by UK GDPR:

  • Contractual necessity (Article 6(1)(b)): To provide the axleo platform and services as agreed with our customers.
  • Legitimate interests (Article 6(1)(f)): To improve our services, ensure security, prevent fraud, and communicate with prospective customers. We balance these interests against individual rights and freedoms.
  • Consent (Article 6(1)(a)): Where we send marketing communications to individuals who have opted in.
  • Legal obligation (Article 6(1)(c)): Where we are required to retain data or respond to lawful requests from authorities.

4.2 Purposes

We use personal data to:

  • Provide call transcription, analysis, compliance monitoring, and coaching insights
  • Generate dashboards, reports, and analytics for dealership managers
  • Maintain and improve the accuracy and performance of our AI models
  • Communicate with customers about their account and our services
  • Respond to demo requests and enquiries
  • Ensure platform security and prevent misuse
  • Comply with legal and regulatory obligations

5. AI processing and automated decision-making

axleo uses artificial intelligence to analyse call recordings. This involves:

  • Automatic transcription: Converting speech to text using AI models
  • Compliance checking: Identifying whether required disclosures (such as Initial Disclosure Documents under FCA rules) were made, and whether GDPR recording consent was obtained
  • Coaching analysis: Scoring call quality and generating feedback for sales staff
  • Sentiment and intent analysis: Identifying buying signals, objections, and follow-up opportunities

Your rights regarding AI processing

Under Article 22 of UK GDPR, individuals have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. axleo's AI analysis is used as a decision-support tool for dealership managers — it does not make autonomous decisions about individuals. Human review and judgment are always involved in any consequential action taken as a result of axleo's analysis.

If you believe axleo's AI processing has affected you, you can contact us at privacy@axleo.co.uk to request information about the logic involved and to seek human review.

6. Data sharing and sub-processors

We share personal data only where necessary to provide our services. We do not sell personal data to third parties.

6.1 Sub-processors

We use the following categories of third-party service providers who may process personal data on our behalf:

Provider

Purpose

Data location

Supabase

Database hosting and authentication

UK/EU

Google (Vertex AI / Gemini)

AI-powered call analysis and transcription

Data processed in accordance with Google's data processing terms; no call data used to train Google's general models

OpenAI

AI-powered call analysis and natural language processing

Data processed in accordance with OpenAI's data processing agreement; API usage — data is not used to train OpenAI's models

We maintain data processing agreements with all sub-processors and require them to protect personal data to standards consistent with UK GDPR.

6.2 Other disclosures

We may disclose personal data:

  • Where required by law, regulation, or court order
  • To protect the rights, safety, or property of axleo, our customers, or others
  • In connection with a merger, acquisition, or sale of assets (with prior notice)

7. International data transfers

All call recordings, transcriptions, and analytics data are stored in UK-based data centres. Where any processing occurs outside the UK (for example, AI model inference), we ensure appropriate safeguards are in place, including:

  • UK International Data Transfer Agreements (IDTAs)
  • Adequacy decisions where applicable
  • Standard contractual clauses approved by the ICO

8. Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:

Data type

Retention period

Call recordings and transcriptions

As agreed with the dealership in our service agreement (typically 12-24 months), or until deletion is requested

AI-generated analysis and scores

Same as call recordings

Platform account data

Duration of the service agreement plus 12 months

Website enquiry data

24 months from last contact

Technical/analytics data

12 months

Dealerships can request deletion of specific call data at any time through the platform or by contacting us.

9. Data security

We implement appropriate technical and organisational measures to protect personal data, including:

  • AES-256 encryption for all data at rest
  • TLS 1.3 encryption for all data in transit
  • Role-based access controls scoped by dealership and user role
  • Full audit logging of all data access events
  • Regular security assessments and vulnerability testing
  • Access restricted to authorised personnel on a need-to-know basis

10. Your rights

Under UK GDPR, you have the following rights regarding your personal data:

  • Right of access — Request a copy of the personal data we hold about you
  • Right to rectification — Request correction of inaccurate personal data
  • Right to erasure — Request deletion of your personal data where there is no compelling reason for continued processing
  • Right to restrict processing — Request that we limit how we use your personal data
  • Right to data portability — Request your personal data in a structured, machine-readable format
  • Right to object — Object to processing based on legitimate interests or for direct marketing
  • Rights related to automated decision-making — Request human review of decisions made using automated processing

For dealership customers and their callers

If you are a customer of one of our dealership clients and wish to exercise your data protection rights in relation to call recordings or analysis, please contact the dealership directly in the first instance, as they are the data controller. We will assist dealerships in responding to such requests.

How to exercise your rights

Contact us at privacy@axleo.co.uk. We will respond within one calendar month as required by law. We may ask for proof of identity before processing your request.

11. Cookies

Our website uses essential cookies required for the site to function. We may also use analytics cookies to understand how visitors use our site. You can manage cookie preferences through your browser settings.

12. Children's data

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children.

13. Changes to this policy

We may update this policy from time to time. Material changes will be communicated via our website. The "last updated" date at the top of this page indicates when the policy was most recently revised.

14. Complaints

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

  • Website: ico.org.uk
  • Telephone: 0303 123 1113
  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would appreciate the opportunity to address your concerns directly before you contact the ICO. Please reach out to us at privacy@axleo.co.uk.

15. Contact us

axleo Systems Ltd - Email: privacy@axleo.co.uk - Website: axleosystems.com