Fraction41 Limited — Fai Platform
Privacy Policy
Last Updated: 17 February 2026
1. Introduction
Fraction41 Limited (trading as Fai) ("we", "us", "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data when you use the Fai investment intelligence platform ("Platform") accessible at askfai.co.
This Privacy Policy applies to customers who subscribe to the Platform and their authorised users. It should be read in conjunction with our Terms of Service.
Data Controller: Fraction41 Limited, a company registered in England and Wales under number 16617680, whose registered office is at 49 Fitz Hugh Crescent, Eagle Farm South, Milton Keynes, England, MK17 7BU.
Contact: info@askfai.co
ICO Registration: ZC093203
2. Personal Data We Collect
2.1 Account and Organisation Data
When you subscribe to the Platform, we collect:
- Organisation name and details;
- Your name, email address, and job title;
- Authorised user names and email addresses;
- Subscription tier and seat allocation.
2.2 Usage Data
When you use the Platform, we collect:
- Search queries and filters applied;
- Companies viewed, saved, or analysed;
- Reports and insights generated;
- Time spent on the Platform and feature usage patterns;
- Click data and navigation paths.
This usage data is collected for two purposes: (a) to improve the Platform and provide you with better service; and (b) to generate anonymised market intelligence and trend analysis for our Signal product (see clause 5).
2.3 Technical Data
We automatically collect:
- IP address;
- Browser type and version;
- Device type and operating system;
- Pages visited and links clicked;
- Date and time of access.
2.4 Payment Data
We do not collect or store payment card details. Payments are processed via invoice or through third-party payment providers. If you use a third-party payment provider, their privacy policy will apply to the processing of your payment data.
2.5 Data We Do Not Collect
We do not collect special category data (such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sex life or sexual orientation) or data relating to criminal convictions.
3. How We Use Your Personal Data
3.1 Legal Basis
We process your personal data on the following legal bases:
- (a) Contract: Processing account and organisation data is necessary to provide the Platform and perform our obligations under the Terms of Service.
- (b) Legitimate Interests: We process usage data to improve the Platform, develop new features, and generate anonymised market intelligence. We have assessed that these interests are not overridden by your rights and freedoms.
- (c) Consent: We send marketing communications (product updates, new features, industry insights) with your explicit consent. You may withdraw consent at any time by clicking "unsubscribe" in any email or contacting info@askfai.co.
3.2 Purposes of Processing
We use your personal data to:
- Provide access to the Platform and deliver our services;
- Manage your account and process subscription payments;
- Respond to your inquiries and provide customer support;
- Analyse Platform usage patterns and performance using pseudonymised analytics;
- Improve the Platform, develop new features, and fix technical issues;
- Generate anonymised market intelligence and trend analysis (see clause 5);
- Send service-related communications (invoices, account updates, security alerts);
- Send marketing communications where you have consented;
- Comply with legal obligations and prevent fraud or misuse.
4. Data Sharing and Disclosure
4.1 Within Your Organisation
Authorised users within your organisation with appropriate access rights may view search queries, saved companies, and reports generated by other authorised users within the same subscription.
4.2 Service Providers
We share personal data with the following service providers who process data on our behalf:
- Cloud Hosting: Amazon Web Services (AWS) – hosting infrastructure primarily in Ireland and London, with potential expansion to local regions as the Platform scales. AWS processes data under standard contractual clauses and appropriate security measures.
- Email Services: Microsoft 365 – for sending service and marketing emails.
- Analytics: PostHog – for product analytics and usage tracking. PostHog processes pseudonymised usage data (see clause 9) to help us understand how the Platform is used and improve our services. Data is hosted in the European Union.
All service providers are required to maintain appropriate security measures and process data only in accordance with our instructions.
4.3 API Data Sharing (Where Authorised)
If you use our API (when available) and explicitly authorise data sharing with third-party partners or systems, we will share data in accordance with your instructions and API configuration. You remain responsible for ensuring such sharing complies with data protection law.
4.4 Other Fai Users
We do not share your search queries, saved companies, or usage patterns with other Fai customers. Each customer's data is isolated and confidential (subject to anonymisation for Signal as described in clause 5).
4.5 Legal Requirements
We may disclose personal data if required to do so by law, court order, or regulatory authority, or to protect our rights, property, or safety, or that of our users or the public.
4.6 Business Transfers
If we undergo a merger, acquisition, or sale of assets, your personal data may be transferred to the successor entity. We will notify you of any such change and provide options regarding your data.
5. Anonymised Data and Signal Product
5.1 Anonymisation
We collect and analyse usage data to generate anonymised market intelligence and trend analysis. This data is processed to ensure it cannot reasonably identify:
- You or your organisation;
- Specific companies you have searched for or analysed;
- Individual user behaviour.
Anonymised data reflects aggregated patterns across multiple users and is used to develop our Signal product (trend intelligence and market signals).
5.2 Examples of Anonymised Use
Permitted uses include:
- "VCT managers increased searches for renewable energy companies by 40% in Q1 2025";
- "Fintech investment activity in the North West shows declining interest";
- "Companies with revenue >£5M in the solar sector are experiencing heightened investor attention."
We will never disclose which specific customer or user searched for which companies.
5.3 Withdrawal of Consent
You consented to anonymised data usage when accepting our Terms of Service (clause 5.1). You may request to withdraw this consent by contacting info@askfai.co. Please note that withdrawal of consent may result in adjusted commercial terms, including increased licence fees, as anonymised data usage forms part of our business model.
6. Data Retention
6.1 Active Subscriptions
We retain your personal data for the duration of your active subscription and for as long as necessary to provide the Platform and comply with our legal obligations.
6.2 After Termination
Following termination of your subscription:
- We will retain your data for 30 days to allow for data migration (if requested and paid for);
- After 30 days, we will delete your account data, usage data, and search history unless we are required to retain it for legal, regulatory, or accounting purposes;
- Anonymised data that cannot identify you or your organisation may be retained indefinitely for Signal product development and market analysis.
6.3 Legal Retention
We may retain personal data for longer periods where required by law (e.g., tax, accounting, or anti-money laundering obligations) or to establish, exercise, or defend legal claims.
7. International Data Transfers
Your personal data is primarily processed and stored in Ireland and the United Kingdom (AWS regions). As we expand, data may be stored in local regions closer to your location to improve performance.
Where data is transferred outside the UK or European Economic Area (EEA), we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses approved by the European Commission;
- Adequacy decisions recognising the recipient country as providing adequate data protection;
- Other legally approved transfer mechanisms.
Microsoft 365 is a US-based service but processes EU data in accordance with standard contractual clauses and appropriate security measures. PostHog processes analytics data within the European Union.
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:
- Encryption of data in transit (TLS/SSL) and at rest;
- Access controls and authentication mechanisms;
- Regular security assessments and monitoring;
- Secure hosting infrastructure provided by AWS;
- Employee training on data protection and confidentiality.
Whilst we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your login credentials.
9. Cookies and Tracking Technologies
9.1 Essential Cookies
We use essential cookies that are necessary for the Platform to function, including:
- Session cookies to maintain your login state;
- Security cookies to prevent unauthorised access;
- Preference cookies to remember your settings.
These cookies are necessary to provide the service and do not require consent.
9.2 Analytics and Tracking Technologies
We use PostHog, a product analytics service, to understand how the Platform is used and to improve our services. PostHog does not set any cookies on your device. Instead, analytics data is stored in memory only for the duration of your browser session and is not persisted after you close your browser.
PostHog collects the following data:
- Pages visited and navigation events;
- Page leave events;
- Browser type, version, and operating system;
- Device information.
Your identity is pseudonymised using a one-way cryptographic hash, meaning PostHog cannot access your name, email address, or other directly identifying information. Analytics data is processed in the European Union.
9.3 Marketing Cookies
We do not currently use marketing or advertising cookies.
9.4 Managing Cookies
You can control cookies through your browser settings. However, disabling essential cookies may prevent you from accessing certain features of the Platform.
10. Your Rights
Under UK data protection law (UK GDPR and Data Protection Act 2018), you have the following rights:
10.1 Right of Access
You may request a copy of the personal data we hold about you.
10.2 Right to Rectification
You may request correction of inaccurate or incomplete personal data.
10.3 Right to Erasure
You may request deletion of your personal data in certain circumstances (e.g., where it is no longer necessary for the purposes for which it was collected).
10.4 Right to Restriction
You may request restriction of processing in certain circumstances (e.g., whilst we verify the accuracy of contested data).
10.5 Right to Object
You may object to processing based on legitimate interests. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
10.6 Right to Data Portability
You may request that we provide your personal data in a structured, commonly used, machine-readable format, and you may request transmission to another controller where technically feasible.
10.7 Right to Withdraw Consent
Where processing is based on consent (e.g., marketing communications, anonymised data usage for Signal), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
10.8 Exercising Your Rights
To exercise any of these rights, contact us at info@askfai.co. We will respond within 30 days. Requests are free of charge unless manifestly unfounded or excessive.
10.9 Right to Complain
You have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe we have not handled your personal data in accordance with the law. Contact details:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
11. Children's Privacy
The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will delete it promptly.
12. Third-Party Links
The Platform may contain links to third-party websites (e.g., company websites in search results). We are not responsible for the privacy practices of third-party sites. We recommend reviewing their privacy policies before providing any personal data.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Platform's functionality. We will notify you of material changes by:
- Posting the updated policy at askfai.co/privacy-policy;
- Sending an email notification to your registered email address;
- Displaying a notice on the Platform.
Continued use of the Platform following notification constitutes acceptance of the updated Privacy Policy. The "Last Updated" date at the top of this policy indicates when it was last revised.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:
Email: info@askfai.co
Post: Fraction41 Limited, 49 Fitz Hugh Crescent, Eagle Farm South, Milton Keynes, England, MK17 7BU
Note: The Platform is a business-to-business (B2B) service. This Privacy Policy is designed to comply with UK GDPR requirements whilst recognising the commercial nature of our relationship with subscribing organisations.