Privacy Notice
Version 2.4 · Effective 1 November 2026 · Next review: annually, or on any material change
ICO registration: ZC076984
This notice explains what personal data PreEmpt.Life Limited collects, why we collect it, who handles it, and what rights you have. It applies to our website and to the ALEXIS Navigator™ service.
We collect only what we need.
We tell you who handles it. We never sell personal data.
AI system disclosure (EU AI Act Article 50).
ALEXIS Navigator™ uses artificial intelligence to analyze the decisions you submit. The analysis is a research and thinking tool. It does not make decisions for you. You keep control of every decision.
Contents
- Who we are
- What personal data we collect
- Why we use your data and our legal basis
- AI processing and ALEXIS Navigator
- Who we share your data with
- International transfers
- How long we keep your data
- Your rights
- Cookies
- Changes to this notice
- Contact and complaints
1. Who we are
PreEmpt.Life Limited is the data controller for the personal data described in this notice.
| Controller | PreEmpt.Life Limited |
|---|---|
| Registered in | England and Wales, Company No. 16402220 |
| ICO registration | ZC076984 |
| Data protection lead | Alan Gates, Managing Director |
| Data Protection Officer | External. Contact: data@preempt.life |
| EU Representative (Article 27 EU GDPR) | EDPO (European Data Protection Office), Avenue Huart Hamoir 71, 1030 Brussels, Belgium |
This notice covers our website at www.preempt.life and the ALEXIS Navigator service that our members use.
2. What personal data we collect
Account and profile data. You give us this when you register: name, email address, age range, gender, country, nationality, language, occupation, sector, skills, and your organization if you choose to give it. We also hold your subscription tier and account creation date. We store your password only as a hash.
Decision content. This is what you submit to the service: decision descriptions and context, answers to surveys and tools, responses to scenario questions, reflections, personal stories you write in My Life, and your feedback and ratings on AI outputs. We use it to deliver your analysis and to improve the service from your feedback.
Decision content can include names of other people and business information if you write them in. Include only what you need.
Special category data. We do not ask for health, ethnicity, religion, political views or other special category data. If you include it in a decision description, we use it only to deliver your analysis.
Communications and support data. Your name, email address, the messages you send us, and our support records.
Usage data. We keep logs of how the service is used. We anonymize them before we analyze them. We use the anonymized results to improve the service.
3. Why we use your data and our legal basis
| Purpose | Legal basis (UK GDPR and EU GDPR) |
|---|---|
| Create and manage your account | Article 6(1)(b), performance of your membership agreement |
| Deliver ALEXIS Navigator analysis | Article 6(1)(b), performance of your membership agreement |
| Communicate with you about your account and the service | Article 6(1)(b), and Article 6(1)(f), our legitimate interest in effective member support |
| Develop, test and maintain the service (our technical partner may see data incidentally while doing this) | Article 6(1)(b), and Article 6(1)(f), our legitimate interest in running and improving the service |
| Improve the service with anonymized analytics | Article 6(1)(f), our legitimate interest in improving the service for all members. We anonymize data before we analyze it. |
| Meet our legal obligations | Article 6(1)(c) |
Where we ask for your consent, you can refuse it or withdraw it at any time, and you keep your access. We record your consent with the date and the version of the notice you saw. We also record each withdrawal. If you withdraw consent, we delete the data we collected on that basis within 30 days.
We do not use your personal data for marketing without your explicit consent. We do not sell personal data.
4. AI processing and ALEXIS Navigator
When you submit a decision, the text of your submission goes to an AI model to produce your analysis. We use Anthropic's Claude and OpenAI's GPT models through their APIs. Their terms and data processing addenda govern how they handle that data.
We do not send your name, email address or other registration data to AI providers. They receive the text of your submission. If you write another person's name into that text, it goes with it.
No automated decisions with legal effect. ALEXIS Navigator does not make decisions that have legal or similarly significant effects on you. It provides analysis and thinking tools. Article 22 of UK GDPR and EU GDPR does not apply to the service.
No member profiles. We do not build profiles of our members. We do not use your submissions to train AI models.
5. Who we share your data with
We share personal data only as far as the service needs.
Blackcoffer, our technical implementation partner.
BLACKCOFFER (OPC) PRIVATE LIMITED builds and maintains ALEXIS Navigator. Its team, led by Ajay Bidyarthy, who is also a member of our executive team, can see both your registration data and your decision content. Access is limited to named individuals who need it. A signed Data Processing Agreement governs this. It sets access controls, encrypted transmission, deletion, and notice of a breach within 24 hours.
AI model providers.
| Provider | Role | Data received |
|---|---|---|
| Anthropic PBC | Claude AI model | Text of your decision submission, sent by encrypted API call. No registration data. |
| OpenAI, LLC | GPT AI model | Text of your decision submission, sent by encrypted API call. No registration data. |
Infrastructure and communications providers.
| Provider | Purpose |
|---|---|
| Amazon Web Services (AWS), Ireland (eu-west-1) | Hosting |
| Google Workspace (Gmail) | Member and operational communications |
| Brevo (France) | Transactional email only |
We do not share your personal data with anyone not listed here. We do not let any provider use your data for its own purposes.
6. International transfers
Some providers operate outside the United Kingdom and the European Economic Area. Where we transfer your data, we use the safeguards that UK GDPR and EU GDPR require.
| Provider | Location | Safeguard |
|---|---|---|
| Anthropic PBC | USA | Anthropic Data Processing Addendum with Standard Contractual Clauses |
| OpenAI, LLC | USA | OpenAI Data Processing Addendum with Standard Contractual Clauses and the UK Addendum |
| BLACKCOFFER (OPC) PRIVATE LIMITED | India | UK Addendum to the EU Standard Contractual Clauses (Module 2, controller to processor) for UK members. EU Standard Contractual Clauses (Module 2) for EU members. |
| AWS | Ireland | None needed for hosting inside the EU |
| Google Workspace | USA, with EU data centers available | Google Standard Contractual Clauses with the UK Addendum |
| Brevo | France | None needed. The UK recognizes EU adequacy. |
You can ask for a copy of the safeguards by writing to alan@preempt.life.
7. How long we keep your data
| Data | How long we keep it |
|---|---|
| Account data | While your membership is active, plus 3 years after you close your account |
| Decision submissions and My Life stories | While your membership is active, unless you delete them. You can review and reorder your decision history at any time. We delete decision submissions within 30 days after you close your account. My Life stories are lost when your account is deleted. |
| Communications | While your membership is active, plus 2 years |
| Support records | 3 years |
| Anonymized analytics | 5 years. We cannot link this data to you. |
| Audit trail records (no personal data) | 3 years |
When we no longer need data, we delete it securely. We require our technical partner to delete data held for us when each task ends and when our contract ends.
8. Your rights
Under UK GDPR and EU GDPR you have these rights over your personal data. To use any of them, write to alan@preempt.life. We reply within two weeks. For a complex request we may take up to four weeks, and we will tell you why.
- Access. Ask for a copy of your data and how we use it.
- Rectification. Ask us to correct inaccurate data.
- Erasure. Ask us to delete your data where we no longer have a lawful basis to keep it.
- Restriction. Ask us to limit how we use your data in certain cases.
- Portability. Receive your data in a machine-readable format where we process it by contract or consent.
- Objection. Object to processing based on our legitimate interests. We stop unless we can show compelling grounds.
- Withdraw consent. See section 3.
Exporting your work. You can export an answer from the Export Answer screen as a link, as PDF reports, or through Claude. Clients can also export CSV. Each export starts only when you choose it. Once you export to another service, that service's own privacy terms apply.
9. Cookies
We use essential cookies that the service needs to work, for example to keep you logged in during a session. We do not use tracking, advertising or analytics cookies that follow you across websites.
You can manage cookies in your browser settings. If you turn off essential cookies, you may not be able to use the service.
10. Changes to this notice
We review this notice every year and whenever how we process personal data changes materially. The current version and effective date appear at the top of this page. For a significant change, we email active members.
11. Contact and complaints
Questions about this notice or your data:
- Data Protection Officer (external): data@preempt.life
- Data protection lead: Alan Gates, Managing Director, alan@preempt.life
PreEmpt.Life Limited, registered in England and Wales, Company No. 16402220.
If you are not satisfied with our reply, you can complain to the Information Commissioner's Office (ICO), the UK data protection authority, at ico.org.uk (opens in a new tab) or on 0303 123 1113.
If you are in the EU, you can complain to the supervisory authority in your country. You can also contact the Belgian Data Protection Authority, the authority for the country where our EU Representative is based.
Privacy Notice v2.4 · Effective 1 November 2026