Privacy policy

1. Who we are

This website and the services described on it are operated by Push Capital Ventures Ltd., trading as Composed Agents (“Composed Agents”, “we”, “us”). We are the data controller for personal data collected through this website.

If you have any questions about this policy or how we handle your data, contact us at [email protected].

2. What this policy covers

This policy covers two distinct things:

• This website (composedagents.com), including the analytics and marketing tools we use on it.
• The AI systems we build for clients, which are integrated into a client’s own business environment and may give us access to data held there.

The two are handled very differently, so they are described separately below.

3. Data we collect on this website

Information you give us

If you book an AI audit, we collect the details you enter into the booking form: typically your name, email address, company name and anything you choose to tell us about your business. Bookings are handled by Cal.com, which processes this data on our behalf. We also collect whatever you send us if you email us directly.

Information collected automatically

Like most websites, we use third-party analytics and advertising tools to understand how people find and use the site and to measure our marketing. These tools set cookies or use similar technologies and may collect your IP address, device and browser information, approximate location, the pages you visit and how you arrived at the site. The tools we use are:

• Google Analytics (Google LLC) for site usage statistics.
• Google Ads tag (Google LLC) for measuring and attributing our advertising.
• Meta Pixel (Meta Platforms, Inc.) for measuring and attributing our advertising on Facebook and Instagram.

Our hosting provider also keeps standard server logs, which include IP addresses and request details, for security and reliability.

4. How we use website data

We use the data described above to:

• Respond to your enquiry and run the audit you booked.
• Understand how the website is used and improve it.
• Measure the effectiveness of our advertising and reach people who are likely to be interested in our services.
• Keep the website secure and running reliably.

Under UK data protection law, our legal bases for this are: performance of a contract or steps taken at your request (responding to enquiries and bookings), our legitimate interests in running and promoting our business (site security, logs and basic analytics), and your consent for non-essential cookies and advertising tools, which you can withdraw at any time.

5. Cookies and how to opt out

The analytics and advertising tools listed above rely on cookies and similar identifiers. You can control them in a few ways:

• Block or delete cookies in your browser settings. The site will still work without them.
• Opt out of Google Analytics with the Google Analytics opt-out browser add-on, and manage Google advertising at Google Ads Settings.
• Manage Meta advertising through your Facebook ad preferences.

For more on how these providers use data, see the Google Privacy Policy and the Meta Privacy Policy.

6. Data we handle when building systems for clients

Our core work is designing and integrating AI systems into a client’s business environment so that work can be automated. Depending on the project, this may give us access to data held in the client’s systems, which can include personal data about the client’s staff, customers or suppliers.

In this context the client is the data controller and we act as a data processor on their instructions. Our commitments are simple and absolute:

• We access only the data needed to build and maintain the system the client has asked for, and nothing more.
• We use that data solely to build, operate and maintain that system. We do not use it for any other purpose.
• We never sell client data, share it with third parties for their own purposes, or use it for our own marketing.
• We do not run analytics, profiling or model training on client data, unless specifically requested by the client. The only processing that happens is the functionality of the product the client requested.
• Where the system relies on third-party services, such as an AI model provider, they are used only as agreed with the client and only to deliver the requested functionality.
• We handle client data in line with the contract and data processing terms agreed with each client, and delete or return it when the engagement ends or when instructed.

If you are an employee, customer or supplier of one of our clients and have questions about how your data is used in a system we built, please contact that client directly. They control the data, and we will support them in responding.

7. Who we share data with

We do not sell personal data. We share it only with the service providers we need to run the website and our business, such as our hosting provider, Cal.com for bookings, our email provider, and the analytics and advertising providers listed above. Each provider processes data only for the purpose we engage them for.

We may also disclose data where required by law or to protect our legal rights.

8. International transfers

Some of the providers we use, including Google and Meta, are based in or store data in the United States. Where personal data leaves the UK, we rely on safeguards recognised under UK law, such as the UK Extension to the EU-US Data Privacy Framework or the International Data Transfer Agreement, so that your data remains protected.

9. How long we keep data

• Enquiry and booking details: for as long as needed to respond and, if you become a client, for the duration of our relationship and any period required for legal or accounting purposes.
• Analytics and advertising data: according to the retention settings of each provider, which we keep to the shortest practical period.
• Client data accessed during a project: only for as long as needed to deliver and maintain the system, and as set out in our agreement with the client.

10. Security

We take appropriate technical and organisational measures to protect the data we hold, including encryption in transit, access controls and limiting access to the people who need it for the work. No system is perfectly secure, but we treat the security of client environments as the foundation of what we do.

11. Your rights

Under UK data protection law you have the right to access the personal data we hold about you, to have it corrected or deleted, to restrict or object to its processing, to data portability, and to withdraw consent where processing is based on consent. To exercise any of these rights, email us at [email protected].

If you are unhappy with how we have handled your data, you can complain to the UK Information Commissioner’s Office at ico.org.uk. We would appreciate the chance to resolve any concern with you first.

12. Changes to this policy

We may update this policy from time to time. Any changes will be posted on this page with a new “last updated” date.