Privacy Policy

How Trinity collects, uses, shares and protects personal data about website visitors, people who ask us for a demo or free trial, dealership users, and the calls and messages we handle for dealerships.

Last updated
Version
2.0

Who we are

Trinity provides AI agents for car dealerships. On a dealership's behalf, they answer and make phone calls, reply to text messages and emails, book appointments and look up vehicle details, and they give dealership staff recordings, transcripts and summaries of those conversations. Dealership staff can also use Trinity Assistant, our assistant on WhatsApp, to work with their Trinity account by message.

This policy explains what personal data we collect, how we use it, who we share it with, how long we keep it and the rights you have under UK data protection law.

Trinity is a trading name of Future Laboratories LTD, a company registered in England and Wales (company number 17047436), with its registered office at 71–75 Shelton Street, Covent Garden, London WC2H 9JQ. We are registered with the Information Commissioner's Office (ICO) under registration number ZC131206.

For any question about this policy or your personal data, including a request to use your rights, email legal@trinityapp.ai.

When we are the controller

We are the controller, meaning we decide how and why the data is used, for personal data about:

  • visitors to our website;
  • people who ask us for a demo, a callback or a free trial, or who answer one of our adverts;
  • people at dealerships that contact us, whom we research or contact as potential customers;
  • dealership staff who use Trinity, and dealership accounts;
  • the cookie choices you make on our website.

We act as a processor when we handle the calls, messages, bookings and customer records of a dealership's own customers. The dealership is the controller for that data and decides how it is used. We act on the dealership's instructions under our Data Processing Agreement, which forms part of our Terms of Service.

If you have called, texted or emailed a dealership that uses Trinity, the dealership's own privacy notice applies to you. Please contact the dealership first about your data. We will help the dealership respond.

What personal data we collect

Visiting our website

  • The pages you view, the links and buttons you click, how far you scroll and how long you stay.
  • Your IP address, browser and device type, and your approximate location worked out from your IP address.
  • The website, link or advert that brought you to us, including any campaign details in the link.

Some of this depends on your cookie choices. See Cookies and similar technologies.

Demos, callbacks and free trials

  • Demo and callback forms: your name, work email address, mobile number and dealership website, and your dealership's company name and, if you pick it from Companies House, its company number and registered address. We check your mobile number by sending you a one-time code by text message. A bot-protection check receives your IP address to confirm that a person is filling in the form.
  • Free-trial signup: your email address. On some versions of the page we also ask for your name, mobile number and dealership website. If you have contacted us before, we link your signup to your earlier enquiry.
  • Meta lead forms: if you fill in a form in one of our adverts on Facebook or Instagram, Meta sends us your answers, such as your name, email address, phone number and dealership.
  • Demo bookings: if you book a time with us, the name, email address, phone number and meeting details you give when booking.
  • Calls with Trinity's AI: calls to our demo line, and the callbacks you ask us for, are with Trinity's AI, not a person. We record and transcribe these calls and keep an AI summary of each one, so that we can follow up with you and check how our demo went.
  • Messages: the confirmation texts and emails we send you, and anything you write back to us.

After you contact us, we may send you personalised links, for example to a page about your free-trial offer or a page to help you prepare for your demo call. These pages show some of your details, such as your name, your dealership and its logo, and on free-trial pages your email address and your dealership's address. Anyone who opens the link can see those details, so please do not share it. The links stop working after a limited time.

Research about businesses

When you ask us for a demo or answer one of our adverts, we research your dealership so that our conversation with you is useful. We use your dealership's own website, web search, the public register at Companies House (including the company's registered details and the names of its directors), and publicly available logos and profile images. We prepare a short briefing for our team, which may note whether you appear to be one of the company's directors.

We give the tools that do this research your name and your dealership's details, but not your email address or phone number. We do this in our legitimate interest in preparing for a conversation you asked for. You can object at any time by emailing legal@trinityapp.ai.

Dealership users

  • Your name, work email address, phone number and profile picture.
  • The dealership you belong to and your role in Trinity.
  • Sign-in details and account identifiers.
  • Billing contact details and subscription records. We do not store card numbers: our payment processor handles them.
  • The settings you choose, and the documents and information you give us to set up your agents, such as opening hours, services and stock details.
  • How you use the dashboard: pages viewed, actions taken, device, browser, IP address and times.
  • Your support conversations with us.

Trinity Assistant. If your dealership lets you use Trinity Assistant, you can ask questions and take actions in your Trinity account by WhatsApp message or voice note. We process your WhatsApp number, your messages, your voice notes (which we convert to text) and the actions taken on your instructions. WhatsApp, which is owned by Meta, carries these messages as the messaging platform. The content of those messages, and the actions taken on them, form part of your dealership's data, which we handle as its processor under our Data Processing Agreement.

Calls and messages for dealerships

When a dealership uses Trinity, we process the following on its behalf about people who call, text or email the dealership, and people the dealership asks Trinity to contact:

  • Phone numbers, names and email addresses.
  • Call recordings, which are on unless the dealership turns recording off. If Trinity hands a call over to a member of staff, the recording can continue after the handover.
  • Transcripts and a timeline of each call, including the actions the agent took.
  • AI summaries, categories, sentiment and follow-up tasks for each conversation.
  • Notes Trinity keeps about a customer for future conversations, such as a vehicle they asked about or a preferred time to call.
  • The content of text messages and emails.
  • Vehicle registrations and the vehicle details we look up, such as make, model, MOT and recall information.
  • Appointments and bookings.

The dealership decides what Trinity's agent says at the start of a call. We set this up with the dealership based on its requirements, and the dealership approves it. The dealership is responsible for telling callers that they are speaking to an AI assistant and that the call is recorded. Trinity's agent will confirm both if asked.

Where we get personal data from

Most of the personal data we hold comes from you. We also receive it from Meta, when you fill in a lead form in one of our adverts; from public sources such as Companies House and your dealership's website, when we research a business that contacted us; from dealerships, about their staff and customers; and from our service providers, for example whether a message was delivered.

How we use personal data

  • Providing the service: running AI agents that answer and make calls and reply to messages for dealerships; making recordings, transcripts, summaries and bookings available to dealership staff; and running Trinity Assistant.
  • Responding to enquiries: answering demo, callback and free-trial requests, running demo calls, setting up free trials and following up with you about Trinity.
  • Preparing for sales conversations: researching the businesses that contact us, as described above.
  • Running accounts: setting up and managing dealership accounts, billing and support, and sending service messages.
  • Measuring our website and advertising: producing statistics about how our website is used, and measuring which of our adverts lead to enquiries (see Meta and our advertising).
  • Keeping the service working well: we use logs, traces and usage statistics to find and fix faults and keep the service reliable. Our logs are designed to leave out conversation content, email addresses and phone numbers. Where a short extract is needed to find a fault, it is kept only for our log retention period.
  • Security: preventing unauthorised access, fraud and misuse, including checking that our website forms are filled in by people.
  • Legal compliance: meeting our obligations under data protection, tax and other laws.

We do not sell personal data.

AI, model training and decisions

  • We do not use personal data to train AI models. Trinity does not train, retrain or fine-tune any machine-learning model on call recordings, transcripts, messages or summaries. The AI providers we use are engaged on terms under which they do not use this data to train their models and do not keep it after processing it for us.
  • We do not use voice recordings for biometric identification. We do not create voiceprints or voice templates. Turning speech into text, and telling apart the speakers within a single call, does not in our assessment amount to processing for the purpose of uniquely identifying a person under Article 9 of the UK GDPR.
  • No automated decisions: our AI agents talk to callers, reply to messages, book appointments, summarise conversations and help us research businesses that contact us. None of this involves making decisions about you, based solely on automated processing, that have legal or similarly significant effects.

Who we share data with

We use service providers who process personal data for us under contract, only on our instructions and with appropriate security. They fall into these categories:

  • Cloud hosting and storage: runs our website, dashboard and database, and stores call recordings.
  • Telephony and text messaging: phone numbers, call connections, text messages, and one-time codes that check phone numbers.
  • Real-time voice infrastructure: connects live calls to our AI agents and records them.
  • AI speech providers: turn speech into text and text into speech, transcribe Trinity Assistant voice notes, and reduce background noise on live calls.
  • AI language model providers: produce the agent's replies in calls and messages, write summaries and help research businesses that contact us.
  • Email delivery: sends emails for dealerships and for us.
  • WhatsApp: the messaging platform for Trinity Assistant.
  • Sign-in and identity: dashboard login and sessions.
  • Logging and monitoring: finds faults and security problems.
  • Website and product analytics: statistics about how our website and dashboard are used.
  • Bot protection: checks that website forms are filled in by people.
  • Scheduling: demo bookings with us, and calendar and booking systems that a dealership connects.
  • Vehicle data services: public vehicle registration, MOT and recall information.
  • Document processing: reads documents that dealership staff upload to set up their agents.
  • Business research: web search, website reading, company register lookups and public profile images.
  • Customer relationship management and team messaging: where we keep track of enquiries and tell our team about new ones.
  • Payment processing: subscription billing. The payment processor holds card details, not us.
  • Advertising: Meta, as described below.

You can ask us at legal@trinityapp.ai for the names of the providers that handle your data. Dealership customers can ask for our full list of sub-processors and the safeguards for each, and we tell them before we add or replace one, as set out in our Data Processing Agreement.

We may also share personal data with our professional advisers; with regulators, courts or law enforcement where the law requires it; and with a buyer, investor or successor if our business is sold, merged or restructured, under confidentiality terms.

Meta and our advertising

We advertise Trinity on Facebook and Instagram, which are run by Meta. Meta receives personal data from us in these ways:

  • Advertising cookies: if you allow advertising cookies, Meta's pixel on our website tells Meta which pages you visit and when you send us an enquiry.
  • Enquiries and bookings: when you ask us to call you, request a demo, book a time or become a customer, we tell Meta (Facebook/Instagram) about it so we can measure which of our adverts work. We send your details in scrambled (hashed) form, along with your IP address and browser details, the page you were on and, if you arrived from one of our Meta adverts, the ad click reference from the link. We do this under our legitimate interest in measuring our advertising. If you choose "No thanks" on our cookie banner, we don't send Meta anything about you, and Meta's cookies are only used if you choose "Allow".
  • Lead forms: if you contacted us through a Meta lead form, we tell Meta how your enquiry progressed, for example that we spoke or booked a demo.

We never send Meta the content of any call or conversation. Meta uses the data it receives as a separate controller, under its own terms and privacy policy. We share enquiry data with Meta in our legitimate interest in measuring our advertising. You can object at any time by emailing legal@trinityapp.ai, and we will stop sharing your enquiry with Meta.

Where your data is stored

Our database, call recordings, logs and analytics are hosted in the European Union or the UK. Our sign-in, real-time voice, telephony and email delivery providers also process data in the European Union or the UK.

Some of our service providers, or their own providers, process personal data outside the UK, mainly in the United States. These include:

  • AI speech and language model providers, which may process call audio, transcripts and messages there. For agents that use our live AI voice provider, live call audio is processed in the United States.
  • Meta, business research tools, and the tools we use to manage enquiries and message our team.

Where the recipient is certified to the UK Extension to the EU-US Data Privacy Framework, we rely on the UK's adequacy regulations for the United States. Otherwise, we rely on the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses included in that provider's data processing terms. Transfers to the European Economic Area rely on the UK's adequacy regulations for the EEA. You can ask us for more detail at legal@trinityapp.ai.

How long we keep your data

We keep personal data only for as long as we need it for the purposes in this policy and to meet our legal obligations. In general:

  • Call recordings, transcripts, and derived analytics: up to one year from the call date.
  • Enquiries, demo and callback requests, research briefings, records of demo calls and Meta lead-form answers: 12 months from our last contact with you. This applies everywhere we hold them, including the tools we use to manage enquiries and message our team.
  • Free-trial signups: 12 months from your last signup.
  • Records of website visits linked to an enquiry, including your IP address: 30 days.
  • Dashboard account information: for as long as your account is active, plus a short period afterwards to handle any final obligations, then deleted or anonymised.
  • Operational and audit logs: up to one year, unless needed longer for a security investigation or legal compliance.
  • Records of your cookie and consent choices: kept as evidence of the choice you made.
  • Billing and accounting records: for as long as tax and company law requires.

When a retention period ends, or at your written request, we delete the data from our active systems. Backup copies may remain in encrypted form for a short additional period before being overwritten.

Your rights

Where we are the controller for your personal data, you have the right to:

  • Access: ask for a copy of the personal data we hold about you.
  • Rectification: have inaccurate or incomplete data corrected.
  • Erasure: ask us to delete your data, subject to what the law requires us to keep.
  • Restriction: ask us to limit how we use your data in certain circumstances.
  • Portability: receive your data in a structured, commonly used format.
  • Objection: object to our use of your data based on legitimate interests, including research and advertising measurement. You can object to marketing at any time and we will stop.
  • Withdraw consent: where we rely on your consent, withdraw it at any time, for example in Cookie settings. This does not affect what we did before you withdrew it.

To use any of these rights, email legal@trinityapp.ai. We may need to confirm your identity before acting on a request. We will respond without undue delay and in any event within one calendar month. We may extend this by up to two further months where a request is complex or you have made several; if we do, we will tell you within one month and explain why.

If your data is in Trinity because you called, texted or emailed a dealership, the dealership is the controller. Please contact the dealership first; we will help it respond to your request.

Complaints. If you are unhappy with how we have handled your data, please tell us first so we can try to put it right. To complain to us, email legal@trinityapp.ai. We will acknowledge your complaint within 30 days and tell you the outcome without undue delay. You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

Cookies and similar technologies

Cookies are small files that a website stores in your browser. We also use similar technologies, such as your browser's local storage. We group them into three categories, the same ones you see in our cookie banner and in Cookie settings.

Strictly necessary (always on)

These are needed for our website and dashboard to work, and to provide things you have asked for.

  • Sign-in session: keeps you signed in to the dashboard, for up to 400 days or until you sign out.
  • Your cookie choices: remembers what you chose in our cookie banner, for up to one year.
  • trinity_free_trial_offer: set when you open a personalised free-trial link, so that our free-trial page can show your offer. It is only sent to our free-trial pages and lasts 90 days.
  • trinity_precall_invite: set when you open a personalised link to prepare for your demo call, so that the page can show your details. It lasts up to 30 days.
  • Display preferences: remembers dashboard settings. Your choice of light or dark mode is kept in your browser's local storage until you change it, and whether the sidebar is open is kept in a cookie for 7 days.

Analytics (on by default)

We use first-party analytics to understand how people use our website and dashboard: which pages they visit, what they click, how far they scroll, and the device and browser they use. This uses a cookie that lasts up to one year. We also keep a note in your browser's local storage, for up to 90 days, of the page, link or advert that brought you to our website, so that if you then send us an enquiry we know which of our marketing led to it. This is part of our analytics: switching analytics off deletes it. We use the results to improve our website and never share them for advertising. These rely on the UK exemption for statistical purposes, so they are on by default. You can switch analytics off on our website at any time in Cookie settings, and choosing No thanks in our cookie banner also switches them off. To opt out of analytics in the dashboard, email legal@trinityapp.ai.

Advertising (off unless you allow them)

Cookies from Meta (such as _fbp and _fbc, which last up to 90 days) measure which of our adverts lead to visits and enquiries, and can be used to show you Trinity adverts on Facebook and Instagram. A company-recognition tag uses your IP address to help us see which businesses visit our website. These are off unless you choose Allow in our cookie banner or turn them on in Cookie settings.

Changing your choices

You can change your choices at any time using the Cookie settings link at the bottom of our website pages, or the button in this section. You can also block or delete cookies in your browser settings, although parts of the website or dashboard may then stop working.

How we protect your data

We encrypt data in transit (TLS 1.2 or higher) and at rest. We use two-factor authentication on our production systems wherever the provider supports it, and limit access to people who need it. We remove email addresses and phone numbers from our logs where we can, and we review our security regularly. If you find a security problem, please tell us at legal@trinityapp.ai.

Children

Trinity is a service for businesses and is not intended for anyone under 18. We do not knowingly collect personal data from children through our website or dashboard.

Changes to this policy

We may update this policy from time to time. When we do, we will change the "Last updated" date at the top of this page. If the changes are material, we will also tell dealership administrators by email.

How to contact us

For privacy questions, or to use any of your rights, email legal@trinityapp.ai or write to Future Laboratories LTD, 71–75 Shelton Street, Covent Garden, London WC2H 9JQ. For general questions about Trinity, email founders@trinityapp.ai.