Privacy Policy

Data Controller

Capture It Limited (Trading as MarketExtra)
12 St. Paul's Court, Standard Road, Hounslow TW4 7AP
richard@marketextra.co.uk

1. Introduction

Capture IT Limited trading as MarketExtra ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This privacy notice explains how we collect, process, and safeguard your personal data when you visit our website, purchase our services, or interact with our platform.

Capture IT Limited, operating from 12 St Pauls Court, Standard Road, Hounslow, TW4 7AP, is registered with the Information Commissioner's Office (ICO) under registration number Z1220620.

2. Our Dual Role: Controller vs. Processor

Because we provide a business-to-business (B2B) Software-as-a-Service platform, our legal obligations depend on how the data is being used:

When we act as a Data Controller: When you (a business or tradesperson) sign up for a MarketExtra subscription, we determine how and why your account, billing, and contact data is processed.
When we act as a Data Processor: When your end-customers interact with your MarketExtra provided website or your AI Receptionist, you are the Data Controller of their data. We act exclusively as your Data Processor, processing those customer enquiries, names, and phone numbers strictly in accordance with your documented instructions and our Terms of Service.

3. The Data We Collect As a Controller

We may collect, use, store, and transfer different kinds of personal data about our business clients, grouped as follows:

Identity Data: First name, last name, and business name.
Contact Data: Billing address, email address, and telephone numbers.
Financial and Transaction Data: Payment card details (processed securely via our third-party payment gateway) and details about payments for your subscription.
Technical Data: Internet protocol (IP) address, browser type, time zone setting, and operating system used to access our platform.

4. How We Use Your Data and Our Lawful Basis

Under the UK GDPR, we will only use your personal data when the law allows us to. We rely on the following lawful bases:

Performance of a Contract: To register you as a new business client, provision your AI routing numbers, and deliver the monthly service.
Legitimate Interests: To study how clients use our services, to develop our products, and to ensure network security.
Legal Obligation: To retain basic financial and billing records to comply with HMRC tax laws.
Consent: Where you have explicitly opted in to receive automated SMS communications from us regarding your own account or technical support. You may withdraw this consent at any time by replying "STOP".

5. Third-Party Disclosures and International Transfers

We do not sell, trade, or otherwise distribute personal data to third-party affiliate networks. We may share data with essential third-party service providers (Sub-processors) to facilitate our platform, including cloud hosting providers, AI language model APIs, and telecommunications SMS aggregators.

Some of our external third parties are based outside the UK. Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use service providers in the US or elsewhere, we use specific contracts approved for use in the UK (the International Data Transfer Agreement or standard contractual clauses) which give personal data the same protection it has in the UK.

6. Data Retention

We will only retain personal data for as long as reasonably necessary to fulfil the purposes we collected it for.

Client Account Data: Kept for the duration of your active subscription and up to 6 years thereafter for tax and legal auditing purposes.
Processor Data (Customer SMS Logs): All customer SMS interaction logs and end-customer personal data are stored securely within your dedicated account workspace. As the Data Controller, you determine the retention period for your customers' data and may manually delete records from your dashboard at any time. If you do not manually delete this data, we will retain it for the continuous duration of your active subscription. Upon termination or cancellation of your commercial contract with us, all remaining processor data and SMS logs will be entirely deleted from our active systems.

7. Your Legal Rights

Under UK data protection laws, you have rights in relation to your personal data, including the right to:

Request access to your personal data (a "data subject access request").
Request correction of incomplete or inaccurate data we hold about you.
Request erasure of your personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data where we are relying on a legitimate interest.
Request restriction of processing of your personal data.
Request the transfer of your personal data to you or a third party (data portability).
Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us at richard@marketextra.co.uk. You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.