ele - Privacy Policy
Version 1 - Effective from 07 August 2026
ele — Privacy Policy
How Kipeople Consulting Ltd (trading as Crisp Professional Development) collects, uses and protects personal data through ele.
| In short Your conversations with ele are private. Nobody at your organisation, including administrators, can see what you have asked ele or how it has responded. The current service does not provide organisation administrators with conversation-content reporting. The only exception is the narrow legal process described in Section 9, used only when Kipeople is legally required to respond to matters such as a court order or a data-subject request. Ordinary administrators at Kipeople or your organisation are not given access through that process. |
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Effective from: 07 August 2026 · Version 1
1. Who We Are
1.1 Kipeople Consulting Ltd, trading as Crisp Professional Development (“Crisp”, “we”, “us” or “our”), of 1 Charlotte Mews, Pavilion Place, Exeter, EX2 4HA, company number 07900483, is the data controller responsible for the personal data described in this policy. Kipeople Consulting Ltd is registered with the Information Commissioner’s Office (ICO) as a data controller under registration reference ZA355830.
1.2 This policy explains how we collect, use, share and protect personal data when you use ele, our AI learning companion — whether you hold an individual monthly or annual licence, or access ele through an organisation that has licensed it for its people (a “client”).
1.3 If you're given access to ele by an employer or other organisation, that organisation is also involved in handling your data — for example, in deciding who receives a licence, and in managing that licence day to day. Where this policy refers to “your organisation” or “client”, it means the organisation that arranged your access to ele.
1.4 We have a nominated Data Protection Lead, a specific and tightly restricted role responsible for overseeing this policy and for handling the exceptional matters described in Section 9. You can reach them using the details in Section 12.
2. The Data We Collect
2.1 Account data: your name, work email address, employer or organisation (where applicable), cohort or programme tier, and login credentials.
2.2 Conversation content: the questions and messages you send to ele, and the responses ele generates for you.
2.3 Usage data: timestamps, session length, which of ele's response modes you use, device and browser information, and the technical logs needed to run and secure the service.
2.4 Payment data: if you hold an individual licence, our payment processor (Stripe) collects your card details directly. We do not store your full card number.
2.5 Special category data: ele isn't designed to collect health, medical or other special category data. However, because ele responds to whatever you choose to write, you may sometimes include this kind of information in a conversation — for example, mentioning stress, wellbeing or a health condition. Where you do, that content receives the same strict confidentiality described in Section 4, and we do not use it for any purpose beyond generating a response to you and the limited retention and security purposes described in this policy.
3. How and Why We Use Your Data
We only use your personal data for the following purposes, and only on the legal grounds shown below.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Provide the ele service and generate responses to you | Account data, conversation content | Performance of a contract with you or your organisation |
| Manage your account, licence and billing | Account data, payment data | Performance of a contract; legitimate interests (fraud prevention) |
| Maintain and improve ele, including the knowledge base and response quality | Anonymised, aggregated usage data only — never identifiable conversation content | Legitimate interests |
| Enforce our Fair Usage Policy and protect the service from abuse | Usage data, technical logs | Legitimate interests |
| Send essential account and service messages | Account data (name and email address), message content and delivery data | Performance of a contract; legitimate interests in service security and delivery |
| Comply with legal obligations and respond to valid legal requests | Limited, ringfenced conversation content, only via the process in Section 9 | Legal obligation |
3.2 We do not sell your personal data. We do not use the content of your conversations to train Kipeople's or any third party's AI models, and we do not use it for advertising, without your explicit, separate consent.
3.3 Where we rely on your explicit consent (for example, to use conversation content beyond providing you the service), you can withdraw that consent at any time by contacting us using the details in Section 12; this will not affect the lawfulness of any processing carried out before you withdrew it. Providing your account data (name and work email address) is necessary for us to enter into a contract with you and provide ele — without it, we cannot create your account or provide the service to you. Where we rely on legitimate interests, you have the right to object at any time. Any optional email communication will include an unsubscribe method where required.
4. The Confidentiality of Your Conversations
4.1 Your conversations with ele are yours. ele is built so that no administrator — whether at your organisation or within Kipeople — can view, download, search or export the content of another individual's conversations.
4.2 This is a structural feature of ele, not a setting that can be switched off on request. Client administrators can see whether a licence is active, paused or removed, but the current service does not provide them with identifiable or aggregate conversation-content reporting.
4.3 The only circumstance in which the content of a conversation may be reviewed by anyone other than the person who wrote it is the narrow, tightly controlled legal process described in Section 9 — and even then, ordinary administrators at Kipeople or at a client organisation play no part in it.
4.4 We can't, however, control access to an individual's own organisational email account or login credentials. If someone other than the intended user gains access to a learner's email account or password, they may be able to access that learner's own ele account, in the same way they could access any other account tied to that email address. That risk sits outside ele, and is addressed in Section 5.
5. Organisational Accounts: Pausing and Removing Access
5.1 Where ele is provided under an organisational (client) licence with more than one seat, the client's nominated administrator(s) can manage individual learners' access using two controls: Pause and Remove.
5.2 Pause immediately blocks the learner's access to ele but preserves their account and conversation history untouched. This is intended for temporary absences — for example, sickness, parental leave or a sabbatical — after which access can be reinstated with the learner's history intact.
5.3 Remove immediately blocks the learner's access to ele and releases the licence seat for reassignment. The learner's account then enters the recovery and controlled deletion process described in Section 6. The administrator does not gain access to the learner's private history.
5.4 Both Pause and Remove take effect immediately, including where a learner is in the middle of an active conversation. This is deliberate: it ensures a learner cannot continue to use, export or copy their conversation data after their organisation has withdrawn their access.
5.5 Clients are responsible for maintaining control of their users' email accounts, promptly pausing or removing access where appropriate, and ensuring that learner accounts are not accessed by, transferred to or reused by another individual. Kipeople is not responsible for access to a learner's ele account obtained through a client's failure to secure its own systems or email accounts — including where one person continues to use a colleague's still-active login. Kipeople's own responsibility, in turn, is to ensure that ele itself never grants any administrator access to another individual's identifiable conversations.
6. How Long We Keep Your Data
6.1 While your licence is active, we retain your conversation content to provide the service — there is no rolling deletion during this period. You can ask us to delete your data sooner at any time.
6.2 Paused accounts (see Section 5) aren't subject to any deletion clock — a paused account's history is preserved for as long as the licence remains paused.
6.3 When paid access ends because a client removes a learner's seat or an individual licence lapses, the account normally enters a restricted recovery period of up to 30 days. At the end of that period, conversation history is no longer available for ordinary use and is handled through Kipeople's controlled deletion or anonymisation process. Trial history may be retained privately so that the same account can continue if the learner subscribes later. A learner may request deletion at any time. Permanent deletion timing may depend on encrypted backup expiry and the limited exceptions in Section 9.
6.4 Account and billing records may be kept for longer where we have a legal or accounting obligation to do so (typically up to seven years for financial records). This does not include the content of your conversations with ele.
7. Who Can See What
This table summarises Sections 4–6 in one place.
| Data | You | Your organisation's administrator | Kipeople support staff | Kipeople's Data Protection Lead |
|---|---|---|---|---|
| Content of your own conversations | Yes | No | No | No — except under the Section 9 process |
| Whether your licence is active, paused or removed | Yes | Yes | Yes | Yes |
| Your account and billing details | Yes | Own organisation only | Where needed to support you | Yes |
8. Who We Share Data With, and International Transfers
8.1 We use a small number of specialist providers to run ele, and share only the data each one needs to perform its role, under a written data processing agreement:
Anthropic (Claude API): processes the content of your conversations to generate ele's responses. Anthropic routes requests globally and may process them using infrastructure in the United States, Europe, Asia, or Australia; any data Anthropic itself stores remains in the United States. These transfers are protected by the EU Standard Contractual Clauses and the UK International Data Transfer Addendum, incorporated into Anthropic's Data Processing Addendum (see the Data Processing Agreement, Clause 4.2, for the exact reference). Anthropic does not use your conversation content to train its models: its Commercial Terms state that “Anthropic may not train models on Customer Content from Services” (see the Data Processing Agreement, Clause 4.4).
Supabase: stores account and application data, hosted on AWS in the eu-west-2 (London, UK) region.
Northflank: hosts the ele application, in London, UK (Europe).
Stripe: securely processes payments for individual licences. We do not see or store your full card details. Stripe may process data internationally under the safeguards in its data-processing and data-transfer terms.
Capsule CRM: may be used for customer and billing administration. It is not currently enabled for learner product-update communications. If this changes, we will update this policy and provide any required notice or unsubscribe choice. Hosted in the UK/EU.
Transpond: may be used for optional customer communications if enabled. It is not currently enabled for learner product-update emails. Hosted in the UK/EU.
GitHub: stores ele's source code. GitHub does not hold personal data about ele's users.
Voyage AI (by MongoDB): helps ele find the relevant learning content for your question (embedding and retrieval). Runs on AWS European data centres.
SMTP2GO: sends one-time sign-in codes and essential account emails. It processes the recipient address, message content and delivery information needed to deliver and protect those emails. Its published policy states that email headers are retained for 35 days and that a small sample of messages may be retained securely for 35 days for compliance monitoring.
Google Fonts: ele’s interface loads a font from Google. This means your browser contacts Google directly, which may reveal your IP address and basic browser information — a very low-risk, common practice shared by most websites.
8.2 Where any of these providers process data outside the UK or European Economic Area, we put appropriate safeguards in place — such as the UK International Data Transfer Addendum or the EU Standard Contractual Clauses — before any transfer takes place.
8.3 We do not sell, rent or otherwise trade your personal data to third parties for their own marketing purposes.
9. Exceptional Legal Disclosure Requests
9.1 On rare occasions, Kipeople may receive a legally valid request connected with a specific individual's conversations with ele — for example, a subject access request from that individual, a court order, or a request made in connection with legal proceedings (which could include, for instance, a coroner's inquiry). This section explains how we handle that situation.
9.2 Client administrators and Kipeople's ordinary support staff never have the ability to view or download the content of a learner's conversations, and this section does not change that. Requests of this kind are handled exclusively by Kipeople's Data Protection Lead — a specific, tightly restricted role held by a nominated individual, separate from ordinary administrator access.
9.3 Kipeople will assess any valid legal request and use the least-privileged technical process available to preserve or retrieve only the information lawfully required. This does not give any ordinary administrator access to conversation content.
9.4 If the relevant information has already been permanently deleted before a valid request is received, we will confirm that it is no longer held.
9.5 Where disclosure is legally approved, the material is reviewed only by an authorised Kipeople representative or an instructed solicitor, who will remove information relating to unrelated third parties and release only what is legally required, using a secure, time-limited method.
9.6 A full record is kept of the request, the assessment carried out, and what — if anything — was disclosed. Any content retained specifically for this purpose is deleted once the legal reason for keeping it has ended.
9.7 This process exists so that Kipeople can respond appropriately and promptly to a genuine legal requirement, without any ordinary administrator — at Kipeople or at a client organisation — ever gaining routine access to identifiable conversation content.
10. Keeping Your Data Safe
10.1 We use industry-standard technical and organisational measures to protect your data, including encryption in transit and at rest, access controls that restrict which systems each type of user can reach, and regular review of our providers' security practices.
10.2 Access to identifiable conversation content is restricted by design (see Section 4); this is enforced through the platform's access controls, not only through policy or staff training.
10.3 If we become aware of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the ICO within the required timeframe and, where required, notify affected individuals directly.
11. Your Rights
11.1 Under UK data protection law, you have the right to: access the personal data we hold about you; have inaccurate data corrected; ask us to delete your data in certain circumstances; restrict or object to certain processing; and receive a portable copy of data you've provided to us.
11.2 If you access ele through an organisational licence, some administrative decisions — such as pausing or removing your seat — are made by your organisation, not by Kipeople. Your data protection rights aren't affected by this: you can contact Kipeople directly at any time using the details in Section 12, and we'll respond to you as an individual, independently of your organisation.
11.3 To exercise any of these rights, contact us using the details in Section 12. We'll normally respond within one month.
11.4 If you're unhappy with how we've handled your personal data, you have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk, or by calling 0303 123 1113.
11.5 Automated decision-making: ele generates conversational, coaching-style responses to your messages, but it does not make automated decisions about you that produce legal effects or similarly significantly affect you, and it is not used to make decisions about your employment, performance, or other significant matters. If this changes, we will update this policy and, where required, provide further information about the logic involved and your rights under Article 22 UK GDPR.
12. Other Important Information
12.1 Children: ele is a workplace learning tool intended for use by adult professionals. It is not directed at, and we do not knowingly collect data from, anyone under the age of 18.
12.2 Changes to this policy: we may update this policy from time to time. Where we make material changes, we'll take reasonable steps to notify active users before the changes take effect. The Privacy Policy is available to view within the ele application. You can also request a copy from info@crisp-cpd.com.
12.3 How to contact us: for any question about this policy or your data, contact our Data Protection Lead at Office 1017, Pynes Hill Business Centre, Maximus House, Pynes Hill, Exeter, EX2 5JL.
Kipeople Consulting Ltd, trading as Crisp Professional Development ·