Freja is a trading name of BRETT INTELLIGENCE LIMITED, a company registered in England and Wales under company number 17381109, with its registered office at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ.
This policy explains how BRETT INTELLIGENCE LIMITED (brett, we, us or our) uses personal data in connection with our website, including Freja’s early-access waitlist, and AI-powered review and organisational intelligence platform.
1. Who we are
BRETT INTELLIGENCE LIMITED is registered in England and Wales under company number 17381109. Our registered office is 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ.
For personal data we use for our own business purposes, brett is the controller. When we process personal data in content supplied by a customer, we normally act as that customer's processor and our Data Processing Agreement applies.
Privacy enquiries may be sent to [email protected].
2. Information we collect
We may collect:
- account and business contact information, such as names, work email addresses, job titles and login details;
- subscription, billing and transaction information;
- documents, prompts, policies, comments and other content submitted to the Platform (Customer Content);
- outputs, reports, review decisions and audit information generated through use of the Platform;
- technical and usage information, such as IP address, device and browser information, login activity, pages or features used and diagnostic data;
- communications, support requests and feedback;
- for Freja’s waitlist, your email address, questionnaire answers about business size, marketing challenges, approach and spending, and records of signup, confirmation, referrals and email/analytics choices; and
- to generate Freja business cards, the name, business, role, email, optional phone number and website, logo and design choices you provide; if you opt in to marketing emails, we retain your name, business, role, email and website with a record of your permission;
- information received through integrations selected by a customer or from public business sources.
Customers decide what Customer Content to submit and are responsible for ensuring that they may lawfully provide it to us.
We generate business cards and contact downloads on request and return them to your browser. We do not keep a copy of the card, its QR code, uploaded logo, selected design or phone number. Anyone who receives or scans your QR code can read and save its embedded contact details. Cards remain available in the current page until you leave or reload it. Website branding import reads public website information without generative AI; public branding may be cached briefly to avoid repeated requests.
If you separately opt in to Freja marketing emails, we keep your name, business, role, email and website to send and personalise emails about early access, product news and offers. Your initial email includes a private link that fills in your email address on the early-access form. Your phone number is used only to generate your card; this email permission does not cover telephone calls or text-message marketing. You can make a card without opting in. Creating a card does not join the early-access waitlist.
If you do not provide information needed to create an account or supply the Services, we may be unable to provide the relevant service.
3. How we use information
We use personal data to:
- provide, secure, maintain and improve our website, Platform and support;
- create and administer accounts and subscriptions;
- manage Freja’s waitlist and referrals, and use grouped, non-identifying questionnaire summaries for product research and fundraising;
- process Customer Content and generate AI-assisted outputs at a customer's direction;
- communicate with customers, users and prospective customers;
- monitor performance, investigate problems and prevent misuse;
- comply with law and protect our rights; and
- send business marketing where permitted by law.
Our lawful bases are performance of a contract, our legitimate interests in operating and improving a business service, compliance with legal obligations and, where required, consent. Where brett acts as a processor, the customer determines the applicable lawful basis.
For Freja’s waitlist, we rely on your consent for requested waitlist emails and optional analytics, and our legitimate interests for administering signups, referrals and product research. Analytics permission is separate from joining the waitlist.
For the free business-card service, we rely on our legitimate interests in providing the tool you request, generating downloads and preventing misuse. We rely on your separate consent to retain your business contact details for Freja email marketing. Permission for a single invitation is not treated as permission for ongoing marketing.
4. AI processing
The Platform analyses Customer Content and related instructions to produce reviews, suggestions, classifications, summaries and reports. These outputs may be incomplete or inaccurate and are intended to support human decision-making.
brett is not a law firm, does not provide legal or regulated financial advice, and does not guarantee compliance. Customers remain responsible for reviewing outputs, approving communications and complying with applicable law and regulation.
We do not use Customer Content to train or improve models for other customers or for general model development unless the customer expressly agrees otherwise in writing. We may use AI and cloud service providers to process Customer Content solely to provide and secure the service.
We do not use the Platform to make decisions about individuals that produce legal or similarly significant effects on our own behalf.
5. Sharing information
We may share personal data with:
- cloud hosting, AI, authentication, analytics, communications, payment and support providers;
- professional advisers and authorities where required by law;
- a buyer, investor or successor in connection with a corporate transaction; and
- other parties where a customer or user asks us to do so.
Service providers may use personal data only as permitted by their agreements with us. A current list of subprocessors used for Customer Content is available to customers on request.
Our hosting and email-delivery providers process the information needed to operate the card and marketing service. If you choose to save a pass to Apple Wallet or Google Wallet, the chosen provider processes the pass and its embedded contact details under its own applicable terms and privacy information. Removing data held by Freja cannot recall contacts, downloaded files or passes already saved or shared.
6. International transfers
Freja’s main waitlist records are stored in the UK/EU.
Some providers may process personal data outside the United Kingdom. Where required, we use an applicable adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another lawful safeguard. Contact us for further information about relevant safeguards.
7. Retention and security
We do not retain generated business cards. Temporary request fingerprints used to prevent duplicate submissions are removed after 24 hours. Invitation prefill links expire after seven days; invitation request and delivery records are normally deleted after 30 days. We retain opted-in marketing contact details for up to 24 months from the recorded permission, or until you unsubscribe, whichever comes first. Unsubscribing removes your marketing contact details and cancels pending invitations. Limited consent evidence may be retained for up to three years after withdrawal or expiry, with a non-readable email identifier and withdrawal record retained to respect opt-outs.
For Freja’s waitlist, unconfirmed signups are deleted after 30 days. Confirmed signups are kept until early-access onboarding ends or they are no longer needed, reviewed at least annually. Questionnaire answers are removed on unsubscribe. Limited consent and withdrawal evidence may be kept for up to three years after emails stop, with minimum suppression information retained to respect your choice.
We keep personal data only for as long as reasonably necessary for the purposes described above, including to provide the service, meet legal or accounting requirements, resolve disputes and enforce agreements. Retention depends on the nature of the data, the customer relationship and applicable legal requirements.
We use appropriate technical and organisational measures designed to protect personal data, including access controls, encryption, logging, monitoring and backup arrangements. No service can guarantee absolute security.
8. Your rights
Depending on the circumstances, you may have rights to access, correct, erase or restrict use of your personal data, object to processing, receive portable data and withdraw consent. You may also object to direct marketing at any time.
To exercise a right, contact [email protected]. We may need to verify your identity. If brett processes the relevant data for a customer, we may refer the request to that customer.
You may complain to the Information Commissioner's Office at ico.org.uk, although we encourage you to contact us first.
9. Website analytics and marketing
Our website uses cookies and similar browser storage for necessary functions and, with your permission, to remember preferences, measure website use through Google Analytics and load booking embeds. Optional services are off until you allow them. You can change or withdraw your choices using Cookie preferences in the footer. Our Cookie Policy explains the technologies, providers and lifetimes. We do not load Google Analytics on personalised introduction pages. You can unsubscribe from marketing emails using the link in the email or by contacting us. We may still send service-related communications.
Freja’s waitlist uses an email confirmation link. Referral codes may reflect the name in your email address and are visible to people you share them with. We do not give referrers your email address or questionnaire answers.
10. Changes and contact
We may update this policy from time to time. The current version will be published on our website with its updated date.
For privacy enquiries, contact [email protected]. For general enquiries or support, contact [email protected].