1. Controller
VIGENTWORKS LTD 71-75 Shelton Street Covent Garden, London WC2H 9JQ, United Kingdom Email: hello@vigentworks.com
2. Processing overview
We process personal data only to operate and improve Qualea, provide contracted services, and handle support and security obligations.
Types of data
- Account and contact data (name, business email, company details)
- Contract and billing data (plan, invoices, transaction references)
- Uploaded creative assets and related metadata
- Usage and technical data (IP address, browser, logs, timestamps)
- Communication data from support requests
Purposes
- Service delivery, account administration, and support
- Creative analysis generation and result presentation
- Fraud prevention, abuse monitoring, and platform security
- Product quality measurement and operational analytics
3. Legal bases (Art. 6 UK GDPR)
- Art. 6(1)(b) for contract performance and pre-contractual steps
- Art. 6(1)(c) for legal retention and compliance duties
- Art. 6(1)(f) for legitimate interests (security, service stability, diagnostics)
- Art. 6(1)(a) where consent is collected (for optional tracking tools)
4. Recipients and processors
Data may be processed by carefully selected service providers under processing agreements where required.
- Hosting and infrastructure providers
- AI processing providers for creative analysis outputs
- Payment providers for billing operations
- Email and support tooling providers
5. International transfers
Where data is transferred outside the United Kingdom, we rely on UK adequacy decisions or the UK International Data Transfer Agreement (IDTA) to ensure appropriate safeguards are in place.
6. Retention
- Contract and invoice data: 6 years from end of contract (UK limitation period)
- Support communication: 2 years from resolution, unless needed for ongoing compliance
- Uploaded assets and analysis results: 90 days after account deletion, or upon user request
- Security and access logs: 12 months on a rolling basis
7. Cookies and similar technologies (UK PECR)
Storing information on your device or accessing existing information takes place only when legally allowed under the Privacy and Electronic Communications Regulations 2003 (PECR). Non-essential cookies or similar technologies are used only after your prior consent.
- Strictly necessary technologies: enabled without consent where legally permitted
- Optional analytics/measurement technologies: enabled only after opt-in consent
8. Your rights
- Right of access (Art. 15 UK GDPR)
- Right to rectification (Art. 16 UK GDPR)
- Right to erasure (Art. 17 UK GDPR)
- Right to restriction of processing (Art. 18 UK GDPR)
- Right to data portability (Art. 20 UK GDPR)
- Right to object (Art. 21 UK GDPR)
- Right to withdraw consent at any time (Art. 7(3) UK GDPR)
9. Automated decision-making and profiling
Qualea uses AI models to analyse uploaded creative assets and generate quality scores, recommendations, and feedback. This processing is automated but does not produce decisions with legal or similarly significant effects on individuals.
The AI analysis evaluates creative content (images, video, copy) against defined quality criteria. It does not profile individual users or make decisions about access to services based on personal characteristics.
10. Right to lodge a complaint
You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection.
Website: ico.org.uk
ICO registration pending.
11. Contact for privacy requests
Email: hello@vigentworks.com