Privacy Policy

Effective: March 2026

1. Introduction & Data Controller

This Privacy Policy describes how Tyga.Cloud Ltd (company number 14643275), registered in England and Wales ("we", "us", "our"), collects, uses, and protects personal data when you use the AgentSME platform ("Service"). AgentSME is a division of Tyga.Cloud Ltd.

Data Controller: Tyga.Cloud Ltd, Ground Floor, Unit 2 Mallard Court, Mallard Way, Crewe Business Park, Crewe, Cheshire, CW1 6ZQ, United Kingdom.

Data Protection Officer: dpo@tyga.cloud

2. Information We Collect

Information you provide:

• Account details (name, email address, password)
• Business and company information
• Agent configuration data (persona, skills, identity settings)
• Chat messages and conversation history with your AI agent
• Contact details of people you interact with via the agent (LinkedIn connections, email recipients)
• Payment information (processed securely via Apple App Store or Google Play)
• Communications with our support team

Information collected automatically:

• IP address and approximate location
• Device type, operating system, and app version
• Features used, session duration, and usage patterns
• AI model usage and token consumption metrics
• Cookies and similar technologies (see our Cookie Policy)

3. How We Use Information

We use your personal data to:

• Provide, operate, and maintain the Service and your AI agent
• Process AI model requests and deliver agent responses
• Execute agent actions (sending emails, LinkedIn messages) on your behalf
• Process subscription transactions and send related notifications
• Respond to your enquiries and support requests
• Send service updates and important notices
• Track usage for billing and cost transparency
• Analyse usage to improve the Service
• Detect, prevent, and address fraud, abuse, or security issues
• Comply with legal obligations

4. Legal Basis for Processing (GDPR Article 6)

Purpose	Legal Basis
Providing the Service and AI agent functionality	Performance of a contract (Art. 6(1)(b))
Processing subscriptions	Performance of a contract (Art. 6(1)(b))
Executing agent actions on your behalf	Performance of a contract (Art. 6(1)(b))
Sending service notifications	Legitimate interest (Art. 6(1)(f))
Analytics and service improvement	Legitimate interest (Art. 6(1)(f))
Marketing communications	Consent (Art. 6(1)(a))
Legal compliance	Legal obligation (Art. 6(1)(c))

5. Data Sharing & Third Parties

We share personal data only with parties necessary to deliver the Service:

Provider	Purpose	Data Shared
OpenAI	AI language model processing	Chat messages, agent prompts
Anthropic	AI language model processing (Claude)	Chat messages, agent prompts
Google AI	AI language model processing (Gemini)	Chat messages, agent prompts
Apple / Google	Subscription billing	Purchase details, account identifiers
LinkedIn	Professional networking actions	Connection requests, messages (as directed by you)
Email providers	Agent email delivery	Email addresses, message content

We do not sell your personal data. We do not use your data to train AI models. We may disclose data if required by law, court order, or to protect the rights and safety of Tyga.Cloud Ltd and its users.

6. International Transfers

Some of our service providers (including AI model providers) are based outside the United Kingdom and European Economic Area (EEA). Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office.

7. Data Retention

We retain your personal data for as long as your account is active and as needed to provide the Service. When you terminate your account:

• You may request a data export within 30 days of termination
• Account data is deleted within 90 days of termination
• Chat history and agent conversation logs are deleted within 90 days
• Anonymised and aggregated usage data may be retained indefinitely for analytics

8. Your Rights (GDPR)

If you are located in the UK or EEA, you have the following rights under the General Data Protection Regulation:

• Right of access — request a copy of the personal data we hold about you
• Right to rectification — request correction of inaccurate data
• Right to erasure — request deletion of your personal data ("right to be forgotten")
• Right to restrict processing — request that we limit how we use your data
• Right to data portability — receive your data in a structured, machine-readable format
• Right to object — object to processing based on legitimate interests
• Right to withdraw consent — withdraw consent at any time where processing is based on consent

To exercise these rights, contact our Data Protection Officer at dpo@tyga.cloud. We will respond within 30 days.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

9. CCPA Rights (California)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights:

• Right to know — what personal information we collect, use, and share
• Right to delete — request deletion of your personal information
• Right to opt-out — opt out of the sale of personal information (we do not sell personal data)
• Right to non-discrimination — we will not discriminate against you for exercising your rights

To exercise CCPA rights, contact us at dpo@tyga.cloud.

10. Children's Privacy

AgentSME is not intended for use by anyone under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child under 16, we will take steps to delete it promptly.

11. Security Measures

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Regular security assessments and vulnerability scanning
• Access controls and authentication mechanisms
• Credentials encrypted at rest with no cross-tenant data leakage
• Regular backups and disaster recovery procedures

While we take reasonable precautions, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

12. AI & Data Training

We do not use your conversations, agent data, or any personal information to train AI models. Your data is processed solely to provide the Service. Third-party AI providers (OpenAI, Anthropic, Google) process your prompts under their respective API terms, which prohibit using API data for model training.

13. Cookies

We use cookies and similar technologies to operate and improve the Service. For detailed information about the cookies we use and how to manage your preferences, please see our Cookie Policy.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email or in-app notification. The "Effective" date at the top of this page indicates when the policy was last revised.

15. Contact & DPO

For questions about this Privacy Policy or to exercise your data rights, contact our Data Protection Officer:

Data Protection Officer
Tyga.Cloud Ltd
Ground Floor, Unit 2 Mallard Court, Mallard Way
Crewe Business Park, Crewe, Cheshire, CW1 6ZQ
Email: dpo@tyga.cloud