Legal compliance · Policies

Privacy Notice

How Daryo89 Ltd handles personal data — for the UK, the EU and the EEA. Version 3.0.

Version 3.0Last updated 29 September 2026Company DARYO89 LTD (14758584)ICO ZB970149Questions d.lapegna@daryo89.com

Version 3.0 — 29 September 2026. This notice replaces the privacy statements dated 4 June 2026. It applies to everyone whose personal data Daryo89 Ltd handles: visitors to daryo89.com, people who ask us a question, people who use our free AI visibility check, our customers and their users, the businesses we contact, our suppliers and partners. It is written for the UK and for the EU and EEA; section 14 says what differs.

1. Who we are and how to reach us

ControllerDARYO89 LTD, a company registered in England and Wales, number 14758584
Registered office171 Gladiator Road, Upper Cambourne, Cambridge, CB23 6JZ, United Kingdom
ICO registrationZB970149 (the register of fee payers is public at ico.org.uk)
Privacy contactd.lapegna@daryo89.com — write “Privacy” in the subject; or by post to the registered office, marked for the attention of the Director
Who is responsible for data protectionDario Adriano Lapegna, Founder & Director, leads data protection personally and is the contact for every privacy matter. We are not required to appoint a statutory Data Protection Officer and have not designated one (a director who decides how data is used cannot hold that independent role); the Director is accountable for compliance.
Representative in the EUNot required. We are established in the United Kingdom, our processing of data about people in the EU is occasional, does not involve special categories of data on a large scale and is unlikely to result in a risk to their rights (Article 27(2)(a) GDPR). Should we begin to offer services to people in the EU regularly, we will appoint a representative there and name them here.

We are the controller of the personal data described in this notice — we decide why and how it is used. Where we work inside a customer’s own systems (for example when one of our plugins runs on a customer’s website), the customer is the controller and we act as its processor under a written data processing agreement; section 9 explains which is which.

2. What this notice is, and what it is not

This notice explains what personal data we collect, where it comes from, why we use it, on which legal basis, who we share it with, where it goes, how long we keep it, how we protect it, and what your rights are. It is written to meet Articles 13 and 14 of the UK GDPR and of the EU GDPR, the Data Protection Act 2018 as amended by the Data (Use and Access) Act 2025, and the Privacy and Electronic Communications Regulations 2003 (PECR).

It does not cover the content of websites we audit or the customers’ own use of our products towards their users: for those, the website owner’s or the customer’s own privacy notice applies. Cookies are covered in our separate Cookie Policy; in short, our own cookies keep the site working and remember your choices, and Google Analytics cookies are set only if you accept them in the banner.

3. The personal data we handle, and where it comes from

We handle little personal data, and most of it is business contact data. The table lists every category, what it contains and where we obtain it.

WhoWhatWhere it comes from
Visitors to daryo89.comTechnical data: IP address, browser and device type, pages requested, time, referrer; cookie identifiers where set (see the Cookie Policy)Your browser, our web server and our hosting and content-delivery providers
People who contact usName, email address, telephone number, company, the content of your message, and any file you sendYou — by email, telephone, a form on the site, LinkedIn, or in a meeting
People who use the free AI visibility checkThe website address you enter, your email address if you leave it, and the results of the check (which can include names and contact details published on that website)You, and the public website you ask us to check
Customers and the people who work for themContact and account details, licence keys and the site each key is installed on, orders, invoices and payment confirmations (not card numbers — see section 6), support correspondence, usage of our products (scans run, credits used, error logs)You when you buy, register or write to us; our products as they run
Users of the client portalLogin details, the reports and scan results you are shown, your activity in the portalThe customer who gives you access, and your use of the portal
Businesses we approach (business outreach)The company’s registered name, number, type and office; the names of directors and officers; the business website; a business email address and, where published, a business telephone number; whether the company replied, asked us to stop, or bouncedThe public register at Companies House; the company’s own website; public business listings; your reply. We do not buy lists and we do not scrape social networks
Newsletter and update subscribersEmail address, name if given, and whether you opened or clicked an email we sent (recorded by our own mail system on our own server, with no third party)You, when you subscribe; our mail system
Suppliers, partners and their staffBusiness contact details, contract and payment details, correspondenceYou or your organisation
People in the content we produceNames and roles that appear in articles, reports and social posts we write for customersPublic sources and the customer’s brief

Special categories of data (health, ethnicity, religion, sexual orientation, biometrics and the like) and criminal-offence data: we do not ask for them and do not want them. If you send them to us in a message, we hold them only as part of that message and under the conditions in section 5. Our Clinical AI Governance work is about policies, procedures and systems; we do not process patient records, and where a customer must share clinical information for an engagement, that is done under the customer’s own governance and a written agreement.

Children. Our services are for businesses and professionals. We do not knowingly collect data about anyone under 18; if you believe we have, tell us and we will delete it.

Data protection law requires a legal basis for each purpose. We use four: contract (the processing is needed to perform a contract with you or to take steps you ask for before one); legal obligation (the law requires it); legitimate interests (we have a real business reason that does not override your interests, rights and freedoms — we have assessed each one and the assessments are available on request; the Data (Use and Access) Act 2025 recognises direct marketing and the security of our systems as legitimate interests); and consent (you have agreed, and can withdraw at any time).

PurposeDataLegal basis
Answering a question or a request for a proposalContact data, your messageContract (steps before a contract) or, if no contract follows, legitimate interests (responding to you)
Running the free AI visibility check and sending you its resultThe website address, your email, the resultsContract (you ask for the check); the follow-up email about our services: legitimate interests (direct marketing), from which you can opt out in every message
Selling, licensing, delivering and supporting our products and servicesAccount, licence, order, support and usage dataContract
Invoicing, accounting, tax and auditOrder and payment recordsLegal obligation (Companies Act 2006, tax law: six years) and contract
Running our website securely and keeping it availableTechnical data, logsLegitimate interests (security and integrity of our systems — a recognised legitimate interest)
Measuring how the website is usedPages viewed, how you arrived, device and browser type, approximate location from a truncated IP address, an analytics cookie identifierConsent — Google Analytics runs only if you accept analytics cookies in our cookie banner; withdraw at any time from the banner (see the Cookie Policy)
Business-to-business outreach: telling companies about our services (section 7)Public company and officer data, business emailLegitimate interests (direct marketing), with an easy way to object; PECR is respected (section 7)
Sending updates you subscribed toEmail address, nameConsent — withdraw at any time with the link in each email
Producing articles, posts, landing pages and reports for customers, with AI assistanceThe customer’s brief, public information, the content itselfContract with the customer; legitimate interests where a person named in public sources appears in the content
Monitoring licence misuse, fraud and abuse of our productsLicence, site and usage dataLegitimate interests (protecting our business and our customers)
Establishing, exercising or defending legal claimsAny relevant dataLegitimate interests; legal obligation
Complying with a lawful request from a court, regulator or law-enforcement bodyThe data requestedLegal obligation

We do not sell personal data, and we do not use it for purposes incompatible with the one it was collected for. If we ever need to use it for a new purpose, we will tell you first and, where required, ask.

5. Automated decisions and the use of AI

A person is always in the loop. We use AI to speed up our work, not to replace judgement, experience or the personal approach we promise. Our tools score websites, draft text, sort replies and prepare content; a person sets the rules they work to, reviews what they produce, and approves it. No decision with a legal or similarly significant effect on you is taken by automated means alone: whether we take on an engagement, what we send to a customer, how we answer a request or a complaint, and what is published under our name or a customer’s are decided by a person.

We use third-party AI models as processors to analyse public websites, to draft and check content, and to classify replies. When we do, we send only what the task needs — normally a business website’s public content, a company’s public register entry, the customer’s brief, and the text to be checked — and not your correspondence with us, your account details or your payment data. The providers we use are named in section 6. We use them through their business interfaces, under terms that do not allow the data we send to be used to train their models.

Content we produce with AI assistance — articles, posts, landing pages, outreach emails — is prepared within a review window and published or sent under a person’s editorial responsibility, in the name of the organisation it comes from. Where the law of the reader’s country requires it, AI-generated content is labelled as such. Where you interact with an automated assistant of ours, it tells you that it is automated.

6. Who we share personal data with

We share personal data only with organisations that help us provide our services, each under a contract that binds them to use it only on our instructions and to protect it, or where the law requires it. We never share it for their own marketing.

CategoryProviderCountry and safeguardWhat they process
Web hosting and backupsIONOS Cloud Ltd (part of IONOS SE) — our own virtual private serversUnited Kingdom — data centre in London; no transferEverything on daryo89.com and our servers, including logs and backups
Network security and content deliveryCloudflare, Inc.Global network: a request is handled at the Cloudflare location nearest the visitor, so data may be processed outside the UK and EEA — UK Extension to the EU–US Data Privacy Framework, and the UK Addendum to the EU Standard Contractual ClausesTechnical data of visitors; requests to our site; firewall and rate-limit logs
Email, calendars and documentsMicrosoft Ireland Operations Ltd (Microsoft 365) and Google Cloud EMEA Ltd (Google Workspace), bought directly from the providersIreland, with processing in the UK, the EU and the United States — DPF / UK Extension and SCCsOur correspondence with you, including support; the documents we prepare for you
Customer relationship management and email sendingFluentCRM and Fluent Forms, running on our own server; our emails are sent through our Microsoft 365 and Google Workspace accountsUnited Kingdom (our server); Microsoft and Google as aboveContact records, subscriptions, the emails we send you
Payments — cardStripe Payments UK Ltd (Stripe Payments Europe Ltd for EU customers; part of Stripe, Inc.)UK and Ireland; group transfers to the USA under the DPF and SCCsYour card details are entered on Stripe’s pages and never stored by us; we receive the confirmation, the last four digits and the billing name
Payments — PayPalPayPal UK Ltd (PayPal (Europe) S.à r.l. et Cie, S.C.A. for EU customers)UK and Luxembourg; group transfers to the USA under the DPF and SCCsPayment confirmation and billing name
BankingTide Platform Ltd (accounts provided by ClearBank Ltd); Revolut LtdUnited KingdomBank-transfer references and payee details on our statements
AccountingXero (UK) LtdUK, with data hosted on Amazon Web Services in the United States — UK Addendum to the SCCsInvoices, payments and contact details of customers and suppliers
AI modelsAnthropic, PBC; OpenAI, L.L.C. (OpenAI Ireland Ltd for EU accounts); Google LLC / Google Ireland Ltd (Gemini API); Perplexity AI, Inc.USA, some with EU entities — UK Extension to the DPF where the provider is certified, otherwise the UK Addendum to the SCCs; EU transfers under the DPF or SCCsThe public website content, public register data, briefs and text described in section 5
Web search and email verificationBrave Software, Inc. (Brave Search API); MillionVerifier, established in Hungary (email address verification)USA — UK Addendum to the SCCs; Hungary — the EU, treated as adequate under UK law, no further safeguard neededSearch queries about businesses and topics; business email addresses checked before we write to them
Website analyticsGoogle Ireland Ltd (Google Analytics 4)Ireland, with processing in the United States — DPF / UK Extension and SCCs; runs only with your consentThe technical and usage data described in section 3, under a random identifier; IP addresses are truncated and not stored; we do not share it with Google for its own advertising and we do not use advertising features
Public registers and web dataCompanies House (the public register); Google LLC (PageSpeed Insights API, Places listings)UK; USACompany and officer data as published; the website addresses we check
Social publishing on behalf of customersMeta Platforms Ireland Ltd (Facebook Pages); LinkedIn Ireland Unlimited CompanyIreland; group transfers to the USA under the DPFThe content a customer authorises us to publish, and the customer’s page or profile tokens
Accountancy, legal and insuranceOur accountants, solicitors and insurers (professional indemnity with AXA)United KingdomWhat is needed for accounts, advice or a claim
AuthoritiesHMRC, the ICO, courts and law-enforcement bodiesUnited Kingdom / the relevant countryWhat the law requires

We do not share personal data with data brokers, advertising networks or social networks for advertising.

7. Business outreach — the companies we contact

Part of our marketing is done by writing to companies we believe would benefit from our services. This is the part of our processing you are most likely to notice without having dealt with us, so we set it out in full.

  • Whom we write to. Companies on the Companies House register of a corporate type (limited companies, PLCs, LLPs). We do not write to sole traders, partnerships or private individuals, and we do not write to healthcare providers directly.
  • What we use. The company’s public register entry (name, number, type, registered office, the names of its officers), its own website, and a business email address found on that website or in a public business listing. We check the website’s AI visibility before we write, and the message refers to what we found.
  • The legal basis. Legitimate interests — direct marketing to businesses, which the Data (Use and Access) Act 2025 recognises as a legitimate interest — balanced against yours: we write to a business address about business services, once, with at most three follow-ups, and we stop the moment you ask. Under PECR, email to a corporate subscriber does not require prior consent; we still make every message easy to decline.
  • Where the message comes from. Our outreach is sent from the domain daryo89partners.com; our direct correspondence is sent from daryo89.com. Anything else claiming to be us is not.
  • How to stop it. Reply “stop” to any message, use the link in it, or write to d.lapegna@daryo89.com. We keep your address on a suppression list so that we do not write again — that list is the one thing we keep indefinitely, because it exists to honour your objection.
  • Your rights. You may object at any time (section 11), ask what we hold and where we obtained it, and ask us to delete it. This section is the information Article 14 requires when data is obtained from public sources rather than from you; we give it in the first message we send.

8. International transfers

We are based in the United Kingdom and most of our processing happens here. Some of our providers process data in the European Economic Area, and some in the United States. When personal data leaves the UK or the EEA we use a lawful transfer mechanism: for the United States, the UK Extension to the EU–US Data Privacy Framework where the provider is certified under it, and otherwise the UK International Data Transfer Addendum to the EU Standard Contractual Clauses (for the UK) or the EU Standard Contractual Clauses (for the EEA), with a transfer risk assessment as the Data (Use and Access) Act 2025 requires. You can ask us for a copy of the mechanism that applies to a given provider.

9. Our products: when we are a controller and when we are a processor

SituationWho is the controllerWhat applies
You visit daryo89.com, contact us, use the free check, buy from us, or receive our outreachDaryo89 LtdThis notice
You use the client portal or receive a report as a customer’s clientThe customer, for the content of the report and your access; Daryo89 Ltd, for the portal’s operationThis notice for the portal; the customer’s notice for the rest
A customer installs our plugins (Multi Scan & AI Assessment, Marketing Agent, D89 Outreach, Care Recruit, Invoice Lite) on their websiteThe customer, for everything the plugin processes on their site (their visitors, leads, candidates, invoices, the companies they write to); Daryo89 Ltd, for licensing, updates, metering and support data sent to usThe customer’s notice for their site; our data processing agreement with the customer; this notice for what reaches us
A customer uses the daryo89.com scanning service through a plugin (proxied scans)The customer, for the site scanned; Daryo89 Ltd as processor, and as controller for the metering recordThe data processing agreement; this notice for the metering record

What our plugins send to us: the licence key, the site address, the plugin version, counts of scans and credits, error reports without personal content, and the pages a scan requests. They do not send a customer’s user database, their visitors’ data or their leads to us. A data processing agreement on our standard terms is available to every customer on request.

10. How long we keep personal data

We keep personal data no longer than the purpose needs, then delete or anonymise it. The periods below are our standard; a legal hold or a live dispute can extend them.

DataKept forWhy
Enquiries and proposals that do not become a contract24 months from the last contact, then deletedTo answer follow-ups and to know what was discussed
Free AI visibility checks (the address, the result, the email if left)12 months, then deletedSo you can see your result again and compare a later check
Customer accounts, orders and correspondenceThe life of the relationship, then 6 yearsContract and limitation periods; our Terms make the order record the reference for support and licence matters
Licence Keys, the Scan Log and the Reports it recordsThe Licence Term (three years from purchase, as our Terms provide) plus 12 months, then deletedThe Scan Log is the authoritative record for Failed Analysis claims and Token reinstatement under our Terms and SLA
The content of a scanned site sent to AI providersNot kept: processed to produce the Report and discarded; only the Report and the Scan Log entry remainData minimisation; our Terms permit public pages only
Support ticketsThe Licence Term or retainer plus 12 monthsSupport history and disputes
Managed-infrastructure retainer records (access, changes, incidents)The retainer plus 6 yearsAccountability under the SLA; limitation periods
Data we hold as a processor for a customerFor the term of the service; returned or deleted within 30 days of termination (the notice period in our Terms), unless the customer instructs otherwise in writingThe data processing agreement
Orders, invoices, payment and banking records6 years after the end of the financial year they belong toCompanies Act 2006 and HMRC requirements
Business outreach data (companies we have written to)12 months after the last message unless you reply, then deleted; the suppression list: indefinitelyTo avoid writing again; to honour objections
Newsletter and update subscriptionsUntil you unsubscribe; the address then stays on a suppression listTo honour the withdrawal
Google Analytics data14 months (the retention we set in our Google Analytics property), then deleted by GoogleYear-on-year comparison; the shortest setting that allows it
Web-server access logs30 daysTroubleshooting and security
Security, firewall, rate-limit and authentication logs90 days (an incident under investigation: until it is closed)Detecting and investigating misuse; our SLA commitments
Backups30 days on a rolling basis, encrypted; a deletion reaches every backup within that periodRecovery
Contracts and correspondence about legal claims or complaints6 years after the matter closesLimitation periods; the complaints record the law requires
Recruitment (if we ever recruit)Unsuccessful applications: 6 months; employees: the employment plus 6 yearsEquality Act and employment law

11. Your rights

You have the following rights, free of charge, whichever country you are in. Write to d.lapegna@daryo89.com with “Privacy” in the subject; we may need to confirm who you are before acting.

  • To be told what we do with your data — this notice, and specific answers on request.
  • Access: a copy of your personal data and the details of how we use it. We answer within one month; for a complex or numerous request we may take up to two more months and will tell you why. We carry out a reasonable and proportionate search, as the law provides.
  • Rectification: correction of data that is wrong or incomplete.
  • Erasure: deletion where the data is no longer needed, where you withdraw consent, where you object and we have no overriding reason, or where the processing was unlawful. We may have to keep what the law obliges us to keep (invoices, for example) and will tell you what and why.
  • Restriction: a pause on processing while a dispute about accuracy or legitimacy is resolved.
  • Portability: the data you gave us, in a machine-readable format, where we process it by automated means under contract or consent.
  • Objection: to processing based on legitimate interests. Objection to direct marketing is absolute — we stop the moment you object, with no questions asked.
  • Withdrawing consent: at any time, without affecting what was done before.
  • Automated decisions: we make none with a legal or similarly significant effect on you; if that ever changed, you would have the right to human intervention, to express your view and to contest the decision.

We do not charge for these requests unless a request is manifestly unfounded or excessive, and we never discriminate against anyone for exercising a right.

12. Complaints

If you think we have handled your personal data badly, complain to us first: write to d.lapegna@daryo89.com with “Data protection complaint” in the subject, or use the complaint form on this page. We acknowledge every data protection complaint within 30 days, we investigate it, we tell you the outcome and what we have done, and we keep a record of complaints, as section 164A of the Data Protection Act 2018 (introduced by the Data (Use and Access) Act 2025) requires.

Privacy Enquiry/complain

You may also complain to the regulator at any time: in the UK, the Information Commissioner’s Office — ico.org.uk/make-a-complaint, 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. In the EU or EEA, the supervisory authority of the country where you live or work (the list is at edpb.europa.eu).

13. How we protect personal data

Our founder learned data discipline in clinical practice before applying it to digital infrastructure, and our security is built to the standards our health and care customers are held to. In practice:

  • Encryption in transit everywhere — TLS 1.2 or later on every connection to our sites, our products and our infrastructure — and encrypted backups.
  • Access on a need-to-know basis, individual accounts, multi-factor authentication on every administrative account, and no shared passwords.
  • Hard separation of our domains: human correspondence from daryo89.com, automated outreach from daryo89partners.com, and our products’ infrastructure kept apart from the public website.
  • Least data: our tools request only what a task needs, our plugins send us only what licensing needs, and card data never touches our systems.
  • Logging, monitoring and rate limits at every level — the network edge, the web server, the application and the API — with daily backups.
  • Contracts with every processor that bind them to the same standard; annual review of who has access to what.
  • A written breach procedure: we assess any incident at once, contain it, and notify the ICO within 72 hours and you without undue delay where the law requires it.

No system is perfectly secure. If we ever fail, we will say so plainly and tell you what to do.

14. If you are in the EU or the EEA

  • The EU GDPR applies alongside the UK GDPR to our processing of your data. Your rights are those in section 11; your regulator is your national supervisory authority (section 12).
  • Transfers from the EEA to the UK rely on the European Commission’s adequacy decision for the United Kingdom; transfers onward to the United States use the mechanisms in section 8.
  • We have no representative in the EU because our processing of data about people in the EU is occasional (section 1); contact us directly at the addresses there.
  • Content we produce with AI assistance and publish or send to readers in the EU is labelled where the EU AI Act (Article 50) requires it, and our automated assistants tell you they are automated.

15. Changes to this notice

We review this notice at least once a year and whenever our processing or the law changes. The version and date are at the top; material changes are announced on daryo89.com and, for customers, by email. Earlier versions are available on request.

Version history. 3.0 — 29 September 2026: rewritten in full (this notice). 2.x — 4 June 2026: generated statements (UK and EU), replaced.

Daryo89 Ltd

DARYO89 LTD (14758584) | ICO Registered (ZB970149) | TM (UK00004255208)

WEB: DARYO89.COM | MAIL: D.LAPEGNA@DARYO89.COM · MOBILE: 07466 630557 · 171 Gladiator Road, Upper Cambourne, Cambridge, CB23 6JZ