Privacy Policy

1. Who We Are

This Privacy Policy applies to ABC Companion Co. Ltd. (“ABC”, “we”, “us”, “our”), the company behind B.E.N – Behavioural Enhanced Navigator.

ABC Companion Co. Ltd. – Company Number: 16684359 – Registered in England and Wales. ABC Companion Co. Ltd. is the data controller responsible for your personal information. “Website” refers to abccompanion.co.uk and any subpages. “Services” refers to any information, features, or platforms provided by ABC Companion Co. Ltd.

2. What This Policy Covers

This policy explains how we collect, use, store, and protect personal information when you:

Browse our website (abccompanion.co.uk and related pages).
Contact us via forms, email, or other communication channels.
Express interest in B.E.N devices, pilots, or research participation.
Create or access an account on our platform (now or in the future).

Note: B.E.N is an emerging product. Some features described here relate to the intended platform and may be rolled out in phases.

3. Information We Collect

3.1 Information you provide directly

Contact details (name, email address, phone number) when you reach out to us.
Message content in contact forms, enquiries, or feedback.
Account details (if you register in future) such as login email and password (stored securely).

3.2 Information collected automatically

IP address and general location (country/region).
Browser type, device type, operating system.
Pages visited, time spent, and basic analytics about how you use the site.

We may use privacy-respecting analytics to understand traffic patterns without tracking individuals unnecessarily.

3.3 Emotional and behavioural data (B.E.N ecosystem)

B.E.N is designed as a behavioural and emotional companion. If you participate in future pilots or use a device:

Where emotional or behavioural data is processed during research, pilots, or device use, this will be done strictly under your explicit consent or legitimate interests where appropriate, and always with clear safeguards.
We may process interaction logs (e.g., device button presses, prompts, responses).
We may process anonymised emotional-state labels or events (e.g., “anchor activated”, “override used”).

Wherever possible, such data will be:

Pseudonymised or anonymised.
Stored in secure, access-controlled systems.
Used to improve stability, safety, and reliability – not to profile or exploit users.

4. How We Use Your Information

To respond to enquiries, support requests, and collaboration offers.
To provide and maintain any user accounts or pilot access you hold with us.
To improve our website, content, and user experience.
To develop, test, and refine B.E.N’s behavioural and safety systems.
To comply with legal obligations and protect our rights.
To withdraw consent, you can email info@abccompanion.co.uk at any time.

5. Legal Basis (GDPR / UK GDPR)

We rely on the following legal bases for processing personal data:

Consent – when you choose to contact us, join a pilot, or opt-in to updates.
Legitimate Interests – to secure our systems, fight abuse, and improve our services.
Contract – when processing is necessary to deliver services you have requested.
Legal Obligation – when we must retain or share data for regulatory or legal reasons.

6. Cookies and Analytics

Our website may use cookies or similar technologies to:

Enable core site functionality (e.g., session handling, security).
Collect anonymous or aggregated usage statistics.

You can usually disable cookies in your browser settings, though some features may not work correctly if you do. For full details, please see our Cookie Policy.

7. Sharing Your Information

We do not sell your personal data.

We may share data only with:

Trusted service providers (e.g., hosting, email delivery, secure cloud infrastructure).
Professional advisers (e.g., legal or cybersecurity consultants) under confidentiality obligations.
Authorities or regulators, where legally required.

Any third-party processing is subject to appropriate data-processing agreements and security standards.

8. International Transfers

Our infrastructure or service providers may operate in jurisdictions outside the UK or EEA. Where this happens, we take reasonable steps to ensure appropriate safeguards (such as standard contractual clauses) are in place to protect your data in line with applicable law.

9. Data Retention

We retain personal data only for as long as necessary to:

Respond to your enquiry or support request.
Maintain any account or pilot relationship with you.
Comply with legal, regulatory, or audit requirements.

When data is no longer required, we will delete, anonymise, or securely archive it, depending on context and obligations.

10. Your Rights

Under UK data protection law, you may have the right to:

Access the personal data we hold about you.
Request correction of inaccurate or incomplete data.
Request deletion of your data in certain circumstances.
Object to or restrict certain types of processing.
Withdraw consent where processing is based on consent.
For more information or to raise a concern, visit the ICO: https://www.ico.org.uk

11. Security

We use technical and organisational measures to protect your data, including encryption, access controls, and segregated environments for sensitive functions. No system is ever perfectly secure, but we treat emotional and behavioural data with the same seriousness as any other sensitive information.

12. Children

Our website is primarily aimed at adults. Any future products designed for children (such as B.E.N PATH) will include specific safeguards, parental consent flows, and age-appropriate handling rules.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will change the “Last updated” date below and, where appropriate, provide a clear notice on the website.

Last updated: 26 Oct 2026