1. Who we are
dijitul Ltd is a company incorporated in England and Wales, company number
12532695, registered office The Bungalow, 11 St John Street, Mansfield, Nottinghamshire, NG18 1QJ.
We are registered with the Information Commissioner's Office as a data controller, in accordance with the
Data Protection Act 2018. Our ICO registration number is
ZB855355.
We are not required to appoint a Data Protection Officer under UK GDPR Article 37. Responsibility for data protection rests with a named individual within the company, who can be reached at olly@dijitul.uk.
2. Two different roles — please read this one
This notice covers two quite different things, and conflating them is the source of most confusion about AI services:
- Account data — we are the controller. Information about you as a customer: your name, your work email address, billing details, and how you use the dashboard. We decide why and how this is processed, and this notice explains it.
- Prompt content — we are a processor. Anything you or your users send through the API, including any personal data contained in a prompt. We process it only on your instructions. Your own privacy notice governs it, and our obligations to you are set out in the Data Processing Addendum, not here.
3. What personal data we collect about account holders
| Category | Examples | Source |
|---|---|---|
| Identity and contact | Name, work email address, organisation name, job title | You, at registration |
| Account and credentials | Hashed password, multi-factor settings, API key hashes and display prefixes | You, and generated by us |
| Billing | Billing address, VAT number, invoice history, card token | You, and our payment processor |
| Usage metadata | Timestamps, model requested, residency tier, regions, status codes, latency, token counts | Generated automatically |
| Technical | IP address, user agent, dashboard session data, audit-trail entries | Generated automatically |
| Correspondence | Support emails and their contents | You |
We do not knowingly collect special category data about account holders, and you should not send it to us in a support email.
4. Why we process it, and on what lawful basis
| Purpose | Lawful basis (UK GDPR Art. 6) |
|---|---|
| Providing the Service and administering your account | Performance of a contract |
| Metering usage and invoicing | Performance of a contract |
| Keeping the Service secure; detecting abuse and credential compromise | Legitimate interests — operating a secure service |
| Diagnosing faults and improving reliability | Legitimate interests — maintaining service quality |
| Retaining financial records | Legal obligation |
| Product announcements and service notices | Legitimate interests, or consent where marketing |
Where we rely on legitimate interests, we have carried out a balancing assessment and you may ask for a summary of it by writing to olly@dijitul.uk.
5. Prompt content — what actually happens to it
Prompt and completion bodies are not written to disk in normal operation. What we retain about a request is metadata: when it happened, which key made it, which model and residency tier were used, the status, the latency and the token counts.
If you have enabled PII detection, we record the types and counts of identifiers found — for example, “one email address, one NHS number”. We do not record the values. The configuration for this is described on the privacy modes page.
If you explicitly enable debug capture on a key, request and response bodies for that key are stored for a bounded window of at most 24 hours and are then purged automatically. This is off by default and switching it on is recorded in the audit trail.
Inference itself is performed on Amazon Bedrock, which is zero-data-retention by default: AWS does not store your prompts or completions, and the model provider has no access to them. Neither we nor any sub-processor uses your prompt content to train models.
6. Who we share personal data with
- Amazon Web Services — our sub-processor for model inference. Prompt content is transmitted to AWS for the purpose of generating a response and is not retained by them.
- Stripe — payment processing. We do not receive or store full card numbers.
- DigitalOcean — hosting for the gateway, its database and its logs. The server is in their London region, so account data and usage metadata are stored in the United Kingdom.
- SMTP2GO — delivery of transactional email such as usage alerts, billing notices and replies to enquiries. Routed via their EU infrastructure.
- Google — website analytics, and only if you accepted analytics cookies on this site. If you declined, or never answered, no data about your visit reaches Google. This applies to the website alone and never to gateway traffic. See section 10.
- Professional advisers, and law enforcement or regulators where we are legally required to disclose.
We do not sell personal data, and we do not share it for third-party advertising.
7. International transfers
Account data is held in the United Kingdom, and so is inference: every request is invoked In-Region on AWS Europe (London). We do not operate an EEA or global tier. The data residency page sets out the mechanism and its limits in full.
Where a transfer outside the UK does occur, it is covered by appropriate safeguards. In respect of AWS, the AWS Data Processing Addendum, the EU Standard Contractual Clauses and the ICO's International Data Transfer Addendum are incorporated automatically into the AWS Customer Agreement.
Of the sub-processors listed above, hosting and email delivery keep data in the United Kingdom and the EEA respectively. The one transfer outside that footprint is Google Analytics, which is optional, off by default, and only ever concerns your visit to this website — never anything sent through the gateway.
8. How long we keep it
- Account records — for the life of the account, then six years. That period matches the limitation period for a contractual claim and our financial record-keeping obligations, after which they are deleted.
- Request metadata — 90 days, then deleted.
- Aggregated daily usage — retained for as long as needed for billing and financial record-keeping.
- Debug capture bodies — at most 24 hours from capture.
- Invoices and financial records — six years, in line with UK statutory requirements.
- Audit trail — six years. It records administrative actions such as settings changes, key issuance and account suspensions, which is the evidence needed to answer a question about an account long after the event.
9. Your rights
Under UK GDPR you have the right to:
- be informed about how your data is used — this notice;
- request a copy of the personal data we hold about you;
- have inaccurate data corrected;
- request erasure, where no overriding basis for retention applies;
- restrict or object to processing carried out on the basis of legitimate interests;
- data portability for data you provided under a contract; and
- withdraw consent at any time, where consent is the basis relied on.
To exercise a right, email olly@dijitul.uk. We will respond within one month. If your request concerns prompt content rather than your account, it must be directed to the organisation that operates the account, because they are the controller for that data — we will assist them, but we cannot act on it directly.
10. Cookies
The marketing and documentation pages set no cookies and load no third-party assets unless you have accepted analytics. Everything else on them is served from our own domain.
The dashboard sets a strictly necessary session cookie and a CSRF token cookie. These are required for the application to function and are exempt from the consent requirement under the Privacy and Electronic Communications Regulations.
Analytics
We use Google Analytics 4 to understand how the site is used. It is off by default. The Google tag is not requested, no analytics cookies are set, and no data reaches Google, unless and until you accept using the banner. Declining costs you nothing — every part of the site works either way.
If you accept: Google Analytics sets cookies on your device and receives your IP address, which is processed by Google LLC in the United States. We enable IP anonymisation, so the address is truncated before storage. Your choice is remembered for 180 days, after which we ask again. You can change your mind at any time by clearing this site's data in your browser.
We also honour the Global Privacy Control browser signal. If your browser sends it, we do not show the banner and analytics never load.
Note: this is the one place where data about your visit to this website may leave the United Kingdom. It does not affect the gateway itself — customer prompts and completions are governed by your account's residency tier and are never sent to Google or any other analytics provider.
11. Security
API keys are stored as SHA-256 hashes and are displayed only once. Traffic is protected with TLS 1.2 or above. Administrative access requires multi-factor authentication and is limited to named staff. Our technical measures are described in more detail on the security page.
12. Children
The Service is a business tool and is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us and we will delete it.
13. Changes to this notice
We will update this notice when our processing changes. Material changes will be notified by email to account holders. The version identifier at the top of this page indicates the current version.
14. Contact and complaints
Contact us at olly@dijitul.uk or by post at The Bungalow, 11 St John Street, Mansfield, Nottinghamshire, NG18 1QJ.
If you are unhappy with how we have handled your personal data you may complain to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, or at ico.org.uk. We would prefer that you raised it with us first so that we have a chance to put it right.
Questions about this document should go to olly@dijitul.uk. Nothing on this page is legal advice, and it does not create any obligation on dijitul Ltd until a settled version has been executed.