Privacy Policy

This Privacy Policy explains how DAPS Holdings Ltd (“DAPS Holdings”, “we”, “us” or “our”) collects, uses, shares and protects personal data when you visit dapsholdings.co.uk (the “Website”) or use any of the apps and services we operate, including Mockly and CreatorConsole (together, the “Services”).

We process personal data in line with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. Some Services may also have a product-specific privacy notice, which adds to this policy. If they conflict, the product-specific notice applies to that product.

1. Who we are

DAPS Holdings Ltd is the data controller for the personal data described in this policy. We are a company registered in England and Wales under company number 17376186, with our registered office at 17 Albert Road, Clevedon, England, BS21 7RP.

For any question about this policy or your personal data, contact us at hello@dapsholdings.co.uk.

2. Personal data we collect

Information you give us

• Contact information, such as your name, email address and the content of messages you send us.
• Account information, such as your name, email address, login credentials or sign-in identifiers (for example Sign in with Apple), and your preferences.
• Content you provide in the Services, such as information you enter, upload or record. In voice-based features (such as mock-interview practice), this includes audio recordings of your voice and the transcripts and feedback generated from them.
• Business information for our B2B Services, such as your organisation, job title and the campaign and creator data you or your organisation add to the platform.

Information collected automatically

• Technical data, such as IP address, device type, operating system, app version, browser type and crash or diagnostic logs.
• Usage data, such as the features you use, how often you use them, and dates and times of access.

Information from third parties

• App store and payment providers. When you buy a subscription or in-app purchase, the payment is processed by Apple, Google or another payment provider. We receive confirmation of the purchase and its status. We never receive your full card details.
• Sign-in providers. If you use a third-party sign-in such as Sign in with Apple, we receive the information you permit that provider to share with us.

We do not intentionally collect special category data (such as health or biometric data). Voice recordings are used only to provide the feature you have chosen. We do not use them to identify you by your voice.

3. How we use your data and our lawful bases

Under UK GDPR, we must have a lawful basis for each way we use your personal data:

• Providing the Services: creating and managing your account, delivering features (including processing voice input to generate transcripts and feedback), and handling purchases and subscriptions. Lawful basis: performance of a contract.
• Support and communication: answering enquiries and sending service messages such as security or account notices. Lawful basis: contract and legitimate interests.
• Security, reliability and improvement: keeping the Services secure, preventing fraud and abuse, fixing bugs and understanding how features are used. Lawful basis: legitimate interests.
• Marketing: sending product news or offers where you have opted in. You can unsubscribe at any time. Lawful basis: consent.
• Legal obligations: keeping tax and accounting records, and responding to lawful requests from authorities. Lawful basis: legal obligation.

Where we rely on legitimate interests, we have weighed our interests against your rights and freedoms. You can ask us for more information about this assessment.

4. AI features

Some Services use artificial intelligence, for example to transcribe speech, hold a realtime voice conversation or generate feedback. To do this, we send the relevant input (such as audio or text) to carefully selected AI service providers who process it on our behalf under data processing terms. We do not allow these providers to use your content to train their own general-purpose models. AI-generated output is for practice and guidance only. It is not used to make decisions that have legal or similarly significant effects on you.

5. Who we share data with

We do not sell your personal data. We share it only with:

• Service providers (processors) who help us run the Services, such as cloud hosting and databases, AI and speech-processing providers, email delivery, customer support tools, and analytics and crash reporting. They may use your data only on our instructions.
• App store and payment providers, such as Apple, to process purchases and subscriptions.
• Professional advisers, such as accountants, lawyers and insurers, where necessary.
• Authorities, where we are required by law or need to protect our rights, our users or others.
• A buyer or successor, if all or part of our business or a product is sold, merged or restructured. Your data would remain protected in line with this policy.

6. International transfers

Some of our service providers are based outside the UK, including in the United States and the European Economic Area. When we transfer personal data outside the UK, we make sure it is protected by an appropriate safeguard. This can be a UK adequacy regulation (including the UK Extension to the EU-US Data Privacy Framework), the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses.

7. How long we keep data

We keep personal data only for as long as we need it for the purposes above:

• Account data is kept while your account is active. We delete or anonymise it within a reasonable period after you delete your account.
• Content you create, such as recordings and transcripts, is kept until you delete it or delete your account, unless a product-specific notice states a shorter period.
• Enquiries and support messages are kept for up to 24 months after the matter is resolved.
• Financial and transaction records are kept for 6 years to meet UK legal requirements.

8. Your rights

Under UK GDPR you have the right to:

• access the personal data we hold about you
• have inaccurate data corrected
• have your data erased
• restrict or object to our processing, including for direct marketing
• data portability
• withdraw consent at any time, where we rely on consent

To exercise any of these rights, email hello@dapsholdings.co.uk. You can also delete your account from within the relevant app where that option is available. We will reply within one month. We may need to verify your identity first.

9. Security

We use appropriate technical and organisational measures to protect personal data. These include encryption in transit, access controls and choosing reputable providers. No system is completely secure, so we cannot guarantee absolute security.

10. Children

Our Services are not directed at children under 13, and we do not knowingly collect their personal data. If you believe a child has given us personal data, contact us and we will delete it.

11. This website and cookies

This Website is a static information site. It does not use advertising or tracking cookies, and it does not ask you to create an account. Our hosting provider may process standard server logs (such as IP address and request details) for security and to deliver the site. If we add analytics or other non-essential cookies in future, we will update this policy and ask for your consent where the law requires it.

12. Complaints

If you have a concern about how we use your data, please contact us first at hello@dapsholdings.co.uk. You also have the right to complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.

13. Changes to this policy

We may update this policy from time to time. The “Last updated” date at the top shows when it was last changed. If we make a significant change, we will tell you through the relevant Service or by email.

See also our Terms of Use.