Jairus Ltd Privacy Policy

Last updated: 18th November 2025

1. Who we are

This Privacy Policy explains how Jairus (“we”, “us”, “our”) collects and uses personal data when you:

  • visit or use our website jairus.co.uk

  • contact us about our services

  • engage us to run SPARK Sales Androids™ + SMS campaigns that use your databases and leads

For the purposes of UK data protection law, we are:

  • a data controller in relation to personal data about our own customers, prospects, website visitors and business contacts

  • usually a data processor in relation to personal data you supply to us for AI + SMS - SPARK Sales Androids™ + SMS - campaigns, acting on your documented instructions, unless agreed otherwise in writing

Contact details

Please direct any privacy queries to:

Jairus Ltd
Email: privacy@jairus.co.uk
Postal address: Suite 1, 39 Ludgate Hill, London EC4M 7JN

If you are based in the UK or EU, you also have the right to raise concerns with your local data protection authority. In the UK this is the Information Commissioner’s Office (ICO)

2. Personal data we collect

The information we collect depends on how you interact with us.

2.1 Website visitors

When you visit jairus.co.uk we may collect:

  • Technical data
    IP address, browser type, device identifiers, time zone, operating system, pages viewed and similar information, typically through server logs and cookies.

  • Usage data
    Information about how you use our site, such as clicks, time on page and referrer URLs, often via analytics tools.

  • Form data
    If you submit an enquiry or booking form, we collect the information you provide, such as your name, email address, phone number, company name, role and your message.

We explain cookie use in our separate Cookie Policy, which works together with this Privacy Policy.

2.2 Customers, suppliers and prospects

When you contact us or work with us as a business customer, partner or supplier, we may collect:

  • Contact details (name, email, phone, job title, company name)

  • Business correspondence and records of our communications

  • Contract and billing information (e.g. invoicing contacts, payment records)

2.3 Lead data supplied by our customers

For SPARK Sales Androids™ + SMS, our customers usually provide us with data about their own leads, customers or past enquirers, for example:

  • Names and contact details (for example, mobile phone number, email address)

  • Demographic or segmentation information that you store about them

  • Contact history, previous purchases, enquiries and interactions

  • Tags, interests, consent records or other profile data from your CRM

You remain the controller of this data and must ensure you have a lawful basis and any required consent to share this data with us and to send SMS messages.

2.4 SMS recipients

When our service sends and receives SMS on your behalf, we may process:

  • The recipient’s phone number

  • Message content that we send and that they reply with

  • Timestamps, delivery reports and engagement data (for example, whether they responded or opted out)

This data is processed to run the campaigns you ask us to run and to measure performance.

3. How we use personal data

We use personal data for the following purposes:

  1. To provide and manage our services

    • Setting up and running SPARK Sales Androids + SMS campaigns

    • Integrating with your CRM or database

    • Routing qualified opportunities back to you
      Legal basis: performance of a contract or steps taken at your request prior to entering into a contract; our legitimate interests in operating our business.

  2. To support and communicate with you

    • Responding to enquiries

    • Providing customer support

    • Sending service messages about changes, incidents or updates
      Legal basis: contract and our legitimate interests in maintaining relationships and resolving issues.

  3. To run SMS campaigns to your leads and customers

    We send SMS campaigns to the contact lists you provide, using AI-powered messaging flows.

    • You are usually the controller of this data and decide who should be contacted and for what purpose.

    • You must ensure you have a lawful basis under UK GDPR and that SMS marketing complies with the Privacy and Electronic Communications Regulations (PECR), including any consent or “soft opt in” requirements and opt out rules.

    • We act as your processor and process the data on your documented instructions, except where we are required by law to act differently.

    Legal basis (our side): our legitimate interests in providing services to our customers and their audiences; performance of our contract with you.

  4. To improve and protect our services

    • Monitoring performance, traffic and usage patterns

    • Developing new features and tools

    • Keeping our systems secure and preventing fraud or abuse

    Where possible, we use aggregated or anonymised data that does not identify individuals. Our legal basis is our legitimate interests in improving and securing our services.

  5. To market our services

    • Sending you information about relevant services, events or resources if you are a business contact
      Legal basis: our legitimate interests in promoting our services to business users where it is reasonable to do so, or your consent where required. You can opt out at any time by following the unsubscribe link or contacting us.

  6. To comply with law and enforce our rights

    • Meeting legal or regulatory obligations

    • Responding to lawful requests from authorities

    • Enforcing our contracts and defending legal claims

    Legal basis: compliance with legal obligations and our legitimate interests in protecting our business.

4. Sharing your information

We do not sell personal data. We may share it with:

  • Service providers and sub-processors
    Such as SMS gateways and carriers, hosting providers, cloud platforms, analytics, email services and security providers. They only process data on our instructions and under contract.

  • Telecom carriers and routing partners
    In order to deliver SMS messages.

  • Professional advisers
    Such as lawyers, accountants and auditors, where necessary.

  • Authorities
    Where we are required by law or believe sharing is necessary to protect rights, property or safety.

  • Business transfers
    In the context of a merger, sale or restructuring, subject to appropriate confidentiality and data protection safeguards.

Where we act as a processor, we only share data in accordance with our agreement with the controller.

5. International transfers

Some of our service providers may be located outside the UK or European Economic Area (EEA). If personal data is transferred outside these regions, we will:

  • ensure there is an adequacy regulation in place, or

  • use appropriate safeguards, such as the UK or EU approved Standard Contractual Clauses, and

  • take additional steps where necessary to protect the data.

6. Data retention

We keep personal data only for as long as necessary for the purposes described above, including:

  • to provide services and maintain our relationship with you

  • to meet legal, accounting and reporting obligations

  • to resolve disputes and enforce our agreements

As a guide:

  • Website analytics data is usually kept for a limited period set by the relevant tool.

  • Business contact records may be kept for the life of the relationship and a period afterwards while they remain relevant.

  • Campaign data and SMS logs are typically retained for [insert period, for example 12–24 months] unless you ask us to delete them sooner and we are able to do so in line with our legal obligations.

If we act as your processor, our retention of your data will follow the terms of our agreement with you.

7. Security

We take appropriate technical and organisational measures to protect personal data, for example:

  • limiting access to systems and data to authorised personnel

  • using secure connections and encryption in transit where appropriate

  • applying access controls and authentication

  • backing up key systems and monitoring for unusual activity

However, no system is completely secure. You are responsible for keeping your own systems and access credentials safe.

8. Your rights

Depending on your location and subject to certain conditions, you may have the following rights in relation to your personal data:

  • Right to be informed about how your data is used

  • Right of access to your personal data

  • Right to rectification of inaccurate or incomplete data

  • Right to erasure in certain circumstances

  • Right to restrict processing in certain circumstances

  • Right to data portability

  • Right to object to processing, including direct marketing

  • Right not to be subject to decisions based solely on automated processing where they have legal or similarly significant effects

These rights are set out in the UK GDPR and related laws.

If you would like to exercise any of these rights:

  • For SMS campaigns run on behalf of one of our customers, please contact that organisation directly, as they are usually the controller. We will assist them as required.

  • For data where we are the controller (for example, your dealings with Jairus as our customer or website visitor), please contact us using the details above.

You also have the right to complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we handle your data. Their website explains how to do this.

9. Direct marketing and SMS

Every marketing SMS we send on our own behalf or on behalf of our customers includes an easy way to opt out, for example by replying “STOP”. When you opt out:

  • we will stop sending you further marketing SMS to that number

  • we may keep a record of your number on a suppression list so that we do not contact you again in error, as permitted by law

If you receive a message that appears to be from one of our customers and you wish to exercise your data rights, you should usually contact that organisation directly.

10. Changes to this policy

We may update this Privacy Policy from time to time. The most current version will be posted on jairus.co.uk with the “Last updated” date at the top. We encourage you to review it regularly.

Terms & Conditions | Data Protection / GDPR Policy | Copyright © 2025 Jairus Ltd. All Rights Reserved.