Privacy Policy

Effective date: 5 August 2026 · Controller: ESEFE GROUP LTD · Jurisdiction: England and Wales, United Kingdom

This Privacy Policy explains how ESEFE GROUP LTD (“we”, “us”, “our”) collects, uses, stores, shares and protects personal data when you visit esefegroupltd.com, contact us, or engage our AI app development and related technology services. We are committed to clarity, minimisation and accountability under the UK GDPR and the Data Protection Act 2018.

Our registered operating address for correspondence is 16 Peebles Drive, Manchester, England, M40 1WH. You may contact us at leader@esefegroupltd.com or +44 7853 326036. We do not use clickable email hyperlinks in this policy; the address appears as plain text for accuracy and record integrity.

1. Who we are

ESEFE GROUP LTD provides custom AI solutions, machine learning applications, AI powered mobile apps, intelligent automation systems, neural network applications, predictive analytics software and associated AI technology development. Personal data processing is incidental to delivering professional services and operating our website, not a consumer social network business model.

Where we act as a controller, this policy applies. Where we act as a processor for a client, the relevant data processing agreement and client instructions govern processing of client-controlled personal data, and this policy supplements rather than replaces those contractual terms.

2. Scope and definitions

“Personal data” means information relating to an identified or identifiable natural person. “Processing” means any operation performed on personal data. “Special category data” means sensitive categories under UK GDPR Article 9. We do not seek special category data through our public website forms. If a project requires such data, we will document an explicit lawful basis and heightened controls before processing.

This policy covers visitors to esefegroupltd.com, prospective clients, clients, suppliers, and other correspondents. It should be read alongside our Cookie Policy, Terms of Service and Terms and Conditions.

3. Categories of personal data

Depending on your interaction, we may process identity data (name, role, organisation), contact data (email as plain text records, telephone number, postal address), communication content (messages, attachments you choose to send), technical data (IP address, browser type, device category, approximate location derived from IP, referral URLs), usage data (pages viewed, time on page aggregated where possible), and contractual data (statements of work, invoices, payment references without storing unnecessary card detail on our public site).

4. Sources of data

We obtain data directly from you via forms and correspondence, automatically via necessary and optional technologies described in our Cookie Policy, and occasionally from public professional sources or referrals when initiating legitimate business contact. We do not purchase marketing lists of consumer personal data for indiscriminate outreach.

5. Purposes and lawful bases

We process personal data to respond to enquiries (legitimate interests or steps prior to contract), to perform contracts for AI software services (contract), to operate and secure our website (legitimate interests), to comply with legal obligations (legal obligation), and, where required, on the basis of consent for non-essential cookies or optional communications. You may withdraw consent without affecting prior lawful processing.

Legitimate interests assessments consider necessity, proportionality and your rights. You may object to processing based on legitimate interests; we will honour objections unless we demonstrate compelling grounds or legal claims requirements.

6. Detailed processing descriptions

Privacy clause 1 concerning identity and contact data: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that identity and contact data shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where identity and contact data intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that identity and contact data may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to identity and contact data, the legal duty prevails. Questions about identity and contact data may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 2 concerning enquiry messages: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that enquiry messages shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where enquiry messages intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that enquiry messages may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to enquiry messages, the legal duty prevails. Questions about enquiry messages may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 3 concerning project briefing materials: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that project briefing materials shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where project briefing materials intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that project briefing materials may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to project briefing materials, the legal duty prevails. Questions about project briefing materials may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 4 concerning technical logs: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that technical logs shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where technical logs intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that technical logs may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to technical logs, the legal duty prevails. Questions about technical logs may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 5 concerning cookie identifiers: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that cookie identifiers shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where cookie identifiers intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that cookie identifiers may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to cookie identifiers, the legal duty prevails. Questions about cookie identifiers may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 6 concerning analytics events: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that analytics events shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where analytics events intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that analytics events may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to analytics events, the legal duty prevails. Questions about analytics events may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 7 concerning security alerts: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that security alerts shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where security alerts intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that security alerts may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to security alerts, the legal duty prevails. Questions about security alerts may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 8 concerning supplier communications: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that supplier communications shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where supplier communications intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that supplier communications may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to supplier communications, the legal duty prevails. Questions about supplier communications may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 9 concerning recruitment correspondence: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that recruitment correspondence shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where recruitment correspondence intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that recruitment correspondence may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to recruitment correspondence, the legal duty prevails. Questions about recruitment correspondence may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 10 concerning billing references: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that billing references shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where billing references intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that billing references may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to billing references, the legal duty prevails. Questions about billing references may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 11 concerning support tickets: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that support tickets shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where support tickets intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that support tickets may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to support tickets, the legal duty prevails. Questions about support tickets may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 12 concerning meeting notes: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that meeting notes shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where meeting notes intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that meeting notes may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to meeting notes, the legal duty prevails. Questions about meeting notes may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 13 concerning access credentials metadata: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that access credentials metadata shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where access credentials metadata intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that access credentials metadata may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to access credentials metadata, the legal duty prevails. Questions about access credentials metadata may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

Privacy clause 14 concerning device information: ESEFE GROUP LTD, operating from 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom, and contactable at leader@esefegroupltd.com or +44 7853 326036 via esefegroupltd.com, records that device information shall be handled with documented care, proportionate controls, and clear accountability under applicable United Kingdom law. Where device information intersects with AI app development, machine learning applications, artificial intelligence software, AI powered mobile apps, ML solutions development, intelligent automation systems, neural network applications, predictive analytics software, custom AI solutions or AI technology development, the company shall maintain records sufficient to demonstrate fairness, transparency where required, security, and respect for contractual confidentiality. Any individual or organisation interacting with these services should understand that device information may involve collection, processing, storage, transfer within permitted jurisdictions, retention for defined periods, and secure deletion or anonymisation when the lawful purpose ends. ESEFE GROUP LTD will not sell personal data as a commodity, will restrict access on a need-to-know basis, and will evaluate subprocessors for reliability. If a conflict arises between a commercial preference and a legal duty relating to device information, the legal duty prevails. Questions about device information may be sent in plain text to leader@esefegroupltd.com and will be routed to the appropriate responsible person in Manchester. This paragraph is intended to be read with the remainder of this document and does not create rights beyond those provided by law or separate written agreement.

7. Sharing and international transfers

We share personal data with service providers who support hosting, email, analytics (if enabled), security and professional advisers, under confidentiality and data protection terms. We may disclose data when required by law, court order, or to protect rights, safety and security.

If personal data is transferred outside the United Kingdom, we implement appropriate safeguards such as the UK International Data Transfer Agreement, Addendum to EU SCCs, or adequacy regulations, together with transfer risk assessments where required.

8. Retention

Enquiry data is typically retained for up to twenty-four months after the last meaningful contact unless a longer period is needed for legal claims or ongoing negotiations. Contract records are retained for the life of the engagement and thereafter for statutory limitation and accounting periods, commonly six to seven years in the United Kingdom unless a different period is agreed or required. Security logs are retained for shorter operational windows unless elevated for investigation.

9. Security

We apply administrative, technical and physical measures appropriate to risk, including access control, encryption in transit where applicable, least-privilege permissions, supplier diligence and staff awareness. No method of transmission or storage is perfectly secure; we maintain incident response procedures and will notify regulators and individuals when legally required.

10. Your rights

Under UK data protection law you may have rights to access, rectification, erasure, restriction, portability, and objection, as well as rights related to automated decision-making where applicable. We do not make solely automated decisions with legal or similarly significant effects through our public website. To exercise rights, contact leader@esefegroupltd.com. You may also complain to the Information Commissioner’s Office (ICO) in the United Kingdom.

11. Children

Our services are directed to businesses and professionals. We do not knowingly collect personal data from children. If you believe a child has provided personal data, contact us and we will take appropriate steps.

12. Changes

We may update this Privacy Policy to reflect legal, technical or operational changes. The effective date at the top will be revised. Material changes may be highlighted on esefegroupltd.com or communicated to active clients.

13. Contact

ESEFE GROUP LTD, 16 Peebles Drive, Manchester, England, M40 1WH, United Kingdom. Email: leader@esefegroupltd.com. Telephone: +44 7853 326036. Website: esefegroupltd.com.

14. Additional operational transparency

ESEFE GROUP LTD maintains internal registers describing processing activities connected to website enquiries, client delivery, supplier management and security monitoring. These registers support accountability under the UK GDPR and help staff apply consistent retention, access and deletion practices. When we evaluate a new tool that may process personal data, we consider necessity, contractual protections, location of processing, encryption capabilities and the residual risk to individuals before adoption.

If you request access to your personal data, we will verify your identity in a proportionate manner, respond within statutory timeframes, and provide information in a concise and intelligible form. Where requests are manifestly unfounded or excessive, we may charge a reasonable fee or refuse the request, explaining our reasons. We will document such decisions. For complex projects involving multiple data subjects controlled by a client, we will redirect data subject requests to the client where we act only as a processor, while assisting the client as required by contract.

Manchester-based staff and contractors receive guidance on phishing awareness, secure handling of attachments, and the prohibition on using personal messaging channels for confidential client personal data unless expressly approved. Physical correspondence sent to 16 Peebles Drive, Manchester, England, M40 1WH is handled by authorised personnel only. Telephone enquiries to +44 7853 326036 may be logged as communication records. Email to leader@esefegroupltd.com forms part of our business correspondence archive subject to retention rules described above.