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Privacy Policy

Last updated: November 2025

1. Who We Are

SeedPath AI Ltd (“SeedPath”, “we”, “our”, “us”) provides automated customer-engagement and lead-prospecting software to estate agents and their partners.

We help estate agents contact their registered buyers and sellers with relevant, timely information and to connect them with related services such as mortgages, valuations and conveyancing.

Registered office: 1 The Links, Herne Bay, Kent, CT6 7GQ
Email: privacy@seedpath.ai
Data Protection Contact: Data Protection Officer, privacy@seedpath.ai

SeedPath AI Ltd is registered in 16815987 and operates in compliance with the UK and EU General Data Protection Regulations (GDPR).

2. Our Role Under GDPR

SeedPath normally acts as a Data Processor on behalf of our estate-agent clients.
The estate agent remains the Data Controller, deciding why customer data is collected and shared with us.


In limited cases – for example, where we improve our models or maintain system performance – we may process certain data as a Joint Controller with our clients.
Any data used for model-training or analytics is pseudonymised and never used to identify an individual.


When we refer customers to regulated mortgage or conveyancing partners (such as Finamply Mortgages Ltd), those partners act as independent Data Controllers for their own activities.

3. What Data We Process

Depending on the services used by your estate agent, we may process:

  • Name, address, phone number and email.

  • Property details and search preferences.

  • Conversation history and enquiry details.

  • Booking and appointment information.

  • Mortgage or service preferences (e.g. first-time buyer, remortgage, buy-to-let).

  • Sentiment or engagement scores generated by our AI models.

  • System metadata (timestamps, message IDs, status codes).

4. Why We Process Data

We process personal data to:

  1. Engage with customers on behalf of the estate agent.

  2. Book or facilitate mortgage, valuation, viewing and conveyancing appointments.

  3. Route enquiries to the correct partner (Finamply Mortgages Ltd, in-house teams, etc.).

  4. Detect and prevent duplicate or fraudulent activity.

  5. Monitor service quality and sentiment to trigger human intervention when needed.

  6. Improve and train our AI models using pseudonymised data to enhance accuracy and response quality.

 

We do not use personal data for unrelated marketing, profiling, or sale to third parties.

5. Legal Basis for Processing

Processing is carried out under the following GDPR Articles:

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  • Article 6(1)(f) – Legitimate Interests of the estate agent in managing and improving customer engagement.

  • Article 6(1)(b) – Contract where data processing is necessary to fulfil a customer’s request (e.g., booking a mortgage call).

  • Article 6(1)(c) – Legal Obligation where required for compliance, audit or regulatory reporting.

  • Article 28 – Processor obligations under written contract with the Data Controller.

6. Pseudonymisation & AI Model Training

To improve our system and reduce bias:

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  • Only data relevant to the intended prospecting purpose is used in identifiable form.

  • All other data is pseudonymised (names, contact details and addresses replaced with random identifiers).

  • Training data is stored and processed separately from live production systems.

  • Models are trained solely to enhance performance and are not used to profile individuals.

  • We never attempt to re-identify individuals from pseudonymised data.

7. Data Sharing & Sub-Processors

SeedPath uses trusted sub-processors to deliver its services. All operate under Data Processing Agreements and equivalent security standards.

Processor

Pipedrive CRM

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AWS (EU Region)

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Twilio

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ResponseIQ

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Microsoft Teams / Outlook

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Finamply Mortgages Ltd

Purpose

Structured data storage

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Hosting for conversation logs & AI models

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SMS delivery

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Instant call connection

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Human hand-off messaging

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Independent controller for mortgage advice

Location/Compliance

EU data centre / ISO 27001

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EU / AES-256 + TLS

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EU SCCs + UK Addendum

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UK / SCCs

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EU/UK tenant

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UK FCA regulated

We do not transfer data outside the UK/EU except through these approved sub-processors using appropriate safeguards (SCCs / UK Addendum).

8. Data Security

We apply technical and organisational measures including:

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  • Encryption at rest (AES-256) and in transit (TLS 1.2+).

  • Access controls and role-based permissions.

  • Multi-factor authentication for staff.

  • Regular vulnerability testing and auditing.

  • Data minimisation and retention controls.

9. Data Retention

Personal data is retained only for as long as necessary to:

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  • Complete the engagement or appointment;

  • Meet regulatory or contractual requirements; or

  • Maintain accurate service performance records.

 

Pseudonymised analytics data may be retained longer for model training.
All data is securely deleted or anonymised when no longer required.

10. Your Rights

Under GDPR you have the right to:

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  • Access a copy of your personal data.

  • Request correction or deletion.

  • Restrict or object to processing.

  • Data portability.

  • Withdraw consent (where applicable).

  • Lodge a complaint with the Information Commissioner’s Office (ICO).

 

Requests should be directed through your estate agent (the Data Controller) or to privacy@seedpath.ai.

11. International Transfers

If data is transferred outside the UK/EU, we rely on:

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  • Adequacy decisions, or

  • Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum.

12. Children’s Data

SeedPath’s services are for adult property applicants. We do not knowingly process data of individuals under 18 years old.

13. Automated Decision Making

Our AI system assists in message routing and sentiment detection but does not make legally significant or solely automated decisions about individuals.


Any decision that could affect an outcome (e.g. appointment booking or follow-up escalation) remains subject to human oversight.

14. Changes to This Policy

We may update this policy from time to time. The latest version will always be available at https://seedpath.ai/privacy with a “last updated” date.

15. Contact Us

Questions about this policy or data-protection practices:
Email: privacy@seedpath.ai

Address:
SeedPath AI Ltd
1 The Links,

Herne Bay

Kent, 

CT6 7GQ

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