Privacy Policy
1. Who We Are
| Detail | Information |
|---|---|
| Company name | MotionFlow Ltd |
| Company number | 16905162 |
| Registered address | 34 Waterloo Road, Wolverhampton, WV1 4DG |
| info@motionflow.uk | |
| Website | motionflow.uk |
| ICO registration | Registration in progress — to be completed before trading commences |
| Data Protection Lead | Contactable via info@motionflow.uk |
MotionFlow Ltd ('MotionFlow', 'we', 'us') is a UK company providing AI-powered communication automation services to residential estate agents. We act as a data controller for our own business operations and are completing our registration with the Information Commissioner's Office (ICO).
2. Personal Data We Collect
2.1 From our estate agent clients and their representatives
- Contact details: name, job title, email address, telephone number
- Business information: agency name, registered address, Companies House number
- Contract and payment information: signed agreements, payment records
- Technical information: GoHighLevel sub-account data, integration credentials (excluding passwords, which we never store)
2.2 From visitors to motionflow.uk
- Enquiry form data: name, email address, nature of enquiry
- Analytics data: pages visited, time on site, device type (only if you consent — see Section 10)
2.3 From business prospects (B2B outreach)
- Publicly available business contact information: name, job title, business email, business telephone, LinkedIn profile
- This data may be sourced from business directories, company websites, LinkedIn, or B2B prospecting tools (Apollo.io, Clay)
- We only collect and process business contact data for the purpose of lawful B2B marketing under PECR and UK GDPR legitimate interests
2.4 Data we process on behalf of our clients (as data processor)
When we provide services to estate agent clients, we act as a data processor on their behalf. This includes processing their clients' (property buyers, sellers, landlords, tenants) personal data through AI call handling, messaging automation, and CRM management. For this processing, the estate agency is the data controller and their privacy notice governs how their clients' data is used.
3. How We Use Your Personal Data
| Purpose | Legal basis | Data used |
|---|---|---|
| Delivering contracted services | Performance of contract (Art. 6(1)(b)) | Client contact data, contract data, account data |
| Invoicing and payment | Legal obligation (Art. 6(1)(c)) and contract | Payment records, billing details |
| Responding to enquiries | Legitimate interests (Art. 6(1)(f)) | Name, email, enquiry content |
| Direct marketing to estate agents | Legitimate interests — PECR soft opt-in for existing clients; consent for prospecting lists | Business contact data, communication preferences |
| Improving our services | Legitimate interests | Aggregate usage data, feedback |
| Legal compliance and dispute resolution | Legal obligation / legitimate interests | Contract records, correspondence |
| Staff and contractor management | Legal obligation / contract | Employment and contractor records |
4. Who We Share Your Data With
We share personal data with the following categories of recipients:
- Technology service providers (sub-processors): GoHighLevel Inc. (automation platform), Google LLC (email and documents), Slack Technologies (internal communications), and others listed in our Sub-processor Register. These providers are subject to data processing agreements and international transfer mechanisms.
- Professional advisers: solicitors, accountants, insurers — under duty of confidentiality.
- Regulatory authorities: HMRC, ICO, or other authorities where legally required.
- Prospective buyers of the business: under appropriate confidentiality agreements if MotionFlow is sold or restructured.
We do not sell personal data. We do not share personal data with third parties for their own marketing purposes.
5. International Transfers
Some of our sub-processors are based in the United States. Transfers to US-based sub-processors are made under the UK International Data Transfer Agreement (UK IDTA) or Standard Contractual Clauses with UK Addendum, as approved by the Information Commissioner's Office. Our Sub-processor Register details the transfer mechanism for each sub-processor and is available on request.
6. How Long We Keep Your Data
| Data type | Retention period | Basis |
|---|---|---|
| Contract and client records | Duration of contract + 6 years | Legal obligation (Limitation Act 1980, Companies Act) |
| Website enquiries and prospect data | 24 months from last contact | Legitimate interests |
| Marketing consent records | Duration of consent + 3 years | Legal obligation (PECR / ICO guidance) |
| Complaint records | 6 years from resolution | Legitimate interests (legal defence) |
| Call recordings (via clients' deployments) | Per client agreement — default 90 days | Legitimate interests (quality review) |
| Invoicing and financial records | 6 years | Legal obligation (HMRC) |
7. Your Rights
Under UK GDPR you have the right to: be informed; access your data; rectification; erasure; restrict processing; data portability; object to processing; and rights relating to automated decision-making. Where automated processing is used, you have the right to request human review (see Section 8).
To exercise any of these rights, please email info@motionflow.uk. We will respond within one calendar month. We may request proof of identity before processing your request.
8. Automated Decision-Making and AI
MotionFlow uses AI-powered tools to support our business operations, including AI language models and automation platforms. We are transparent about how we use these tools.
8.1 In our own business operations
We use AI tools to assist with drafting communications, analysing business data, and improving our service quality. These tools support human decision-making and do not make automated decisions about individuals without human review. No decisions with legal or similarly significant effects are made about you solely by automated means.
8.2 In services delivered on behalf of our clients
Our AI Receptionist and Conversation AI products process inbound call and message data on behalf of estate agent clients. These systems may route enquiries, qualify leads, and generate responses. Estate agencies (our clients) are the data controllers for their customers' data. Where MotionFlow deploys AI features on behalf of a client, we require the client to inform their customers about AI use and to maintain human review for compliance-sensitive decisions.
8.3 AI training prohibition
MotionFlow will not use your personal data or client data to train, fine-tune, test, or improve any AI model without your explicit prior written consent. This applies to all AI tools and sub-processors we use.
9. Data Security
Our technical and organisational measures include: role-based access to client data with least-privilege principles; two-factor authentication on all platforms holding personal data; encryption in transit (TLS) for all data transmissions; password management via a professional password manager (no shared passwords); staff awareness briefings; and sub-processor oversight. In the event of a personal data breach, we will notify affected controllers within 72 hours of becoming aware of the breach, in accordance with our Data Processing Agreement and UK GDPR Article 33.
10. Cookies
Our website (motionflow.uk) uses cookies. Cookies are small text files placed on your device when you visit our site.
| Category | Consent required? | Examples |
|---|---|---|
| Essential | No — necessary for the site to function | Session cookies, security cookies, load balancing |
| Analytics | Yes — consent required | Page views, session duration, traffic source (only if enabled) |
| Marketing | Yes — consent required | Retargeting or advertising pixels (only if enabled) |
You can manage your cookie preferences using the cookie banner on our website, or through your browser settings. Withdrawing consent for non-essential cookies does not affect the lawfulness of any prior processing. See our Cookie Policy for full detail.
11. Changes to This Notice
We review and update this Privacy Notice periodically — at least annually and whenever there is a material change to how we process personal data. The current version is always available at motionflow.uk/privacy. Where changes are significant, we will notify you by email if we hold your contact details.
12. How to Contact Us or Complain
For any questions about this notice or to exercise your rights:
- Email: info@motionflow.uk
- Post: MotionFlow Ltd, 34 Waterloo Road, Wolverhampton, WV1 4DG
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO): website ico.org.uk; helpline 0303 123 1113; post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. We would appreciate the opportunity to address your concern before you contact the ICO, so please reach out to us first.