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Gaincraft

Draft, pending counsel review

This document is published in draft so that it can be read before a contract conversation. It has not yet completed review by external counsel and will be superseded by the reviewed version.

Privacy Policy

Last updated: [CONFIRM]

This policy covers two different things: personal data Gaincraft holds about you as a visitor or a contact, and conversation data Gaincraft processes on behalf of a retailer as its processor. The second is governed by that retailer's instructions and the data processing agreement, not by this policy.

1. Who we are

Gaincraft provides in-store conversation intelligence to retailers. The contracting entities are Gaincraft, Inc. in the United States and Gaincraft Technologies Private Limited in India [CONFIRM]. Privacy enquiries and data subject requests should go to privacy@gaincraft.com.

2. Two roles: controller and processor

Where you contact us, request a document, subscribe to updates or apply for a role, we act as controller of that personal data and this policy applies.

Where a retailer deploys Gaincraft in its stores, the retailer is the controller of the conversation data and Gaincraft is the processor, acting only on that retailer’s documented instructions under the data processing agreement. Customers and associates whose conversations are captured should direct requests to the retailer, which we will support.

3. Personal data we hold as controller

Contact and enquiry data: name, work email, telephone number, company, job title, number of doors, vertical, states of operation, and anything you write in a message or application field. Provided by you.

Website usage data: pages viewed, referring source, approximate location derived from IP address, device and browser type. Collected through first-party analytics.

We do not buy contact lists, we do not enrich your record from third-party data brokers, and we do not construct advertising profiles.

4. Why we use it

To reply to your enquiry, prepare the conversation you asked for, send a document you requested, and follow up once. To operate and improve the website. To meet legal and accounting obligations.

Lawful basis, where UK or EU law applies: legitimate interests for business-to-business contact and website operation, consent for optional email updates, and legal obligation where applicable. Consent can be withdrawn at any time.

5. Conversation data we process for retailers

Audio captured at designated counters, transcripts derived from it, redacted at ingestion to remove payment details and personal identifiers, and behaviour scores derived from those transcripts.

We create no voiceprints and no voice embeddings, for customers or associates, at any stage including model training. Speaker attribution is by capturing seat and roster shift. There is no camera or image sensor in any Gaincraft device.

Audio is deleted automatically at the end of the retention window the retailer configures — thirty days by default, with seven-day and twenty-four-hour options. Derived behaviour data persists for the contract term and is exported or destroyed on the retailer’s instruction.

6. Sharing and subprocessors

We share personal data with service providers who host our infrastructure, send our email and run our analytics, each under contract, and with professional advisers or authorities where legally required. The current list of subprocessors used in service delivery is published at the subprocessor page.

No subprocessor is permitted to use retailer data to train its own models. We do not sell personal data.

7. International transfers and residency

Gaincraft operates in the United States and India. Retailer conversation data is processed in the region selected in the agreement, including backups. Where personal data moves between regions, we rely on standard contractual clauses or another lawful transfer mechanism.

8. Retention

Enquiry and contact data is retained while the commercial conversation is live and for [CONFIRM] afterwards, then deleted. Subscription data is retained until you unsubscribe. Conversation data follows the retailer’s configured window as described above.

9. Security

Encryption in transit and at rest, least-privilege access, and an audit log of every access to a conversation including access by Gaincraft staff, available to the retailer. Certifications, with auditor, period and scope, are set out in the Trust Center.

10. Your rights

Depending on where you live, you may have rights of access, correction, deletion, portability, objection and restriction, and the right not to be discriminated against for exercising them. Write to privacy@gaincraft.com and we will respond within the statutory period, verifying identity first.

Where the request concerns a conversation captured in a store, we will route it to the retailer that controls that data and assist them in fulfilling it.

11. Cookies

We use cookies necessary to operate the site and first-party analytics cookies to understand which pages are read. We do not run third-party advertising or cross-site tracking cookies. Browser controls can block them, and the site remains usable if you do.

12. Children

This is a business-to-business service. We do not knowingly collect personal data from children.

13. Changes and contact

Material changes will be posted here with a revised date, and notified to retailer customers under the terms of their agreement. Contact privacy@gaincraft.com, or security@gaincraft.com for a suspected vulnerability.

We use cookies necessary to run this site. Analytics cookies help us see which pages get read, and they load only if you accept. No advertising or cross-site tracking, ever. See our Privacy Policy.