Privacy Policy
This Privacy Policy explains how we collect, use, share, and protect personal information when you visit our website and/or use the Cluster365 platform (the “Services”).
1) Who We Are
Global Interactive Marketing Online (GIMO) (“we”, “us”, “our”) is the controller for personal data processed in connection with the Services.
- Address: 1 Boundary Row, London, SE1 8HP, England
- Website: www.gimo.co.uk
- Privacy contact: privacy@gimo.co.uk
2) The Personal Data We Collect
Depending on how you use the Services, we may collect:
- Account data: name, username, email address, authentication details, organisation details.
- Usage data: interactions with the Services, features used, timestamps, token/usage metrics, and diagnostics.
- Device and log data: IP address, browser type, operating system, user agent, pages viewed, and error logs.
- Content you provide: prompts, messages, files, and other inputs you submit, plus generated outputs and conversation history.
- Billing data: subscription status and payment references (payment card details are handled by our payment processor where applicable).
3) How We Use Personal Data
We use personal data to:
- Provide, maintain, and secure the Services (including authentication and access control).
- Process your requests and support enquiries.
- Operate platform features such as multi‑LLM routing, tool execution, and conversation history.
- Monitor, troubleshoot, and improve performance, reliability, and safety.
- Comply with legal obligations and enforce our Terms.
4) Legal Bases (UK GDPR)
We rely on one or more of the following legal bases:
- Contract: where processing is necessary to provide the Services you request.
- Legitimate interests: operating, improving, and securing the Services (balanced against your rights).
- Consent: for certain optional activities (for example, non‑essential cookies where required).
- Legal obligation: where we must comply with applicable laws.
5) AI, Model Providers, and Data Sharing
The Services may send your inputs (and relevant context) to third‑party model providers and integrations in order to generate outputs and perform requested actions. These providers act as independent controllers or processors depending on the feature and contract. We share data only as needed to deliver the Services.
We may also share personal data with:
- Service providers: hosting, storage, analytics, customer support, and security vendors.
- Payment processors: to manage subscriptions and payments (where applicable).
- Professional advisers: legal, accounting, and audit advisers.
- Authorities: where required by law or to protect rights, safety, and security.
6) International Transfers
Your data may be processed outside the UK. Where we transfer personal data internationally, we use appropriate safeguards, such as UK International Data Transfer Agreements/addenda, and risk assessments where required.
7) Data Retention
We keep personal data only as long as necessary for the purposes described in this policy, including to comply with legal, accounting, or reporting requirements. Retention periods can vary depending on the type of data and how the Services are used.
8) Security
We use technical and organisational measures designed to protect personal data (for example, access controls, logging, and encryption in transit where supported). No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9) Your Rights
Subject to applicable law, you may have rights to:
- Access your personal data.
- Correct inaccurate or incomplete personal data.
- Delete personal data in certain circumstances.
- Restrict or object to certain processing.
- Data portability (in certain circumstances).
- Withdraw consent where processing is based on consent.
To exercise your rights, contact us at privacy@gimo.co.uk.
10) Cookies
We may use cookies and similar technologies for essential functionality (such as session management) and, where applicable, analytics. You can control cookies through your browser settings. If we implement a cookie banner, it will provide additional controls for non‑essential cookies.
11) Children
The Services are not intended for children, and we do not knowingly collect personal data from children.
12) Changes To This Policy
We may update this policy from time to time. The “Last updated” date above indicates when the latest changes were made.
13) Complaints
You can contact us with concerns at privacy@gimo.co.uk. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).