Privacy Policy Terms of Use &

Data Processing Addendum (DPA)

PRIVACY POLICY

Last updated: 12 May 2026

1. Overview

Stack Integral Limited (“Stack Integral”, “we”, “us” or “our”) is committed to protecting personal data and handling it responsibly.

This Privacy Policy explains how we collect, use, store and protect personal information when you visit stackintegral.com, contact us, interact with our content, submit an enquiry, or use our services.

We provide AI-supported workflow, automation, revenue systems and education-related AI readiness services. Our work may involve business data, customer data, operational data and, where agreed with a school or education setting, education-related data.

We apply the UK GDPR, the Data Protection Act 2018 and applicable privacy laws as our baseline standard.

We do not sell personal data.


2. Scope and Applicability

This Privacy Policy applies to:

Visitors to our website

Individuals who contact us

Individuals who submit forms or enquiries

Clients, prospects, suppliers and business contacts

Users interacting with our content, communications or systems

School leaders, staff, governors, trustees and education contacts

Individuals whose personal data may be processed as part of an agreed client service

This policy does not cover third-party websites, platforms or services that we do not control.

Where Stack Integral processes personal data on behalf of a client, school, trust or organisation, the Data Processing Addendum below also applies.


3. Our Role: Controller and Processor

Stack Integral may act as either a data controller or a data processor depending on the context.

When we act as controller

We act as a data controller when we decide how and why personal data is used. This includes:

Website enquiries

Marketing communications

Client and prospect relationship management

Supplier management

Our own business administration

Website analytics where we control the purpose of processing

When we act as processor

We act as a data processor when we process personal data on behalf of a client, school, trust or organisation under their documented instructions.

This may include:

CRM automation

Lead routing

Follow-up workflows

AI-supported enquiry handling

SMS or email workflow automation

Database reactivation

Reporting dashboards

School AI readiness or implementation support

Education workflow or resource support where personal data is included in scope

Where we act as a processor, the client or school remains responsible for the lawful basis, privacy notices, internal approvals and decisions about how personal data is used.


4. Information We Collect

Personal data you provide to us

We may collect:

Name

Email address

Phone number

Job title

Organisation or school name

Company or school details

Information submitted through website forms

Information provided in emails, calls or messages

Meeting notes or enquiry details

Communication preferences

Any other information you choose to provide

Providing this information is voluntary, but we may not be able to respond to an enquiry or provide services without it.

Information collected automatically

When you visit our website, we may collect:

IP address

Browser type

Device information

Pages visited

Referring URLs

Website interaction data

Cookie and consent preferences

We use this information to operate, secure and improve the website.

Information processed as part of client services

Where we provide services to a client, school, trust or organisation, we may process personal data contained in the systems or workflows they ask us to support.

This may include:

Customer, prospect or lead data

CRM records

Email or SMS communication data

Enquiry records

Quote or proposal information

Workflow status data

Internal notes or task information

Staff or user account information

School operational data

Parent, carer, pupil or staff information where expressly included in the agreed scope

We only process this type of data under the relevant agreement, documented instructions and appropriate safeguards.


5. How We Use Personal Data

We may use personal data to:

Respond to enquiries and communications

Provide information about our services

Arrange calls, audits, consultations or meetings

Deliver services to clients

Design, build, test and improve workflows

Operate AI-supported systems under agreed controls

Manage client relationships

Send service-related communications

Send marketing communications where permitted

Maintain records

Improve our website, services and systems

Monitor security and prevent misuse

Meet legal, contractual and regulatory obligations

We do not use personal data for purposes that are incompatible with the reason it was collected.


6. Lawful Basis for Processing

We rely on one or more lawful bases depending on the context.

Consent

We rely on consent where you have actively agreed to a specific use, such as receiving certain marketing communications or allowing non-essential cookies.

You can withdraw consent at any time.

Contract

We rely on contractual necessity where processing is needed to provide requested services, manage a client relationship or take steps before entering into a contract.

Legitimate interests

We may rely on legitimate interests where processing is necessary for our business operations and does not override your rights and freedoms.

This may include:

Responding to business enquiries

Managing business relationships

Improving our services

Sending relevant B2B communications where permitted

Maintaining security

Keeping appropriate records

Legal obligation

We may process personal data where required to meet legal, tax, accounting or regulatory obligations.

Vital interests

In rare circumstances, we may process personal data where necessary to protect someone’s vital interests, such as where there is an immediate risk to life or safety.


7. AI and Automation Responsibility

Stack Integral designs AI-supported systems with defined boundaries, human oversight and clear escalation points.

AI may be used to support:

Workflow consistency

Enquiry handling

Drafting

Routing

Qualification

Summarisation

Data organisation

Follow-up prompts

Reporting and analysis

AI is not used to remove human accountability from important decisions.

Humans remain responsible for:

Commercial decisions

Sensitive customer conversations

Safeguarding judgement

Educational judgement

Legal or compliance decisions

Final approval where required

Any decision that materially affects an individual

We design systems to support people, not replace responsible human judgement.


8. Education and Schools

Where Stack Integral provides services to schools, colleges, education settings, tutoring organisations or multi-academy trusts, we may process personal data relating to staff, governors, trustees, parents, carers, pupils, prospective pupils or former pupils where this is necessary to deliver the agreed service.

In most education projects, the school or education setting remains the data controller. Stack Integral acts as a data processor and only processes personal data on documented instructions from the school or education setting.

Depending on the agreed project, data may include:

Names and contact details

Role and organisation information

Staff training or CPD records

Communication content

Workflow data

Enquiry data

Parent or carer communications

Pupil-related operational information

Education resource or support information

SEND-related information only where expressly included in scope

Safeguarding-adjacent information only where expressly included in scope

We do not knowingly collect personal data directly from children through this website for marketing purposes.

We do not use pupil data for advertising, resale, unrelated commercial purposes or independent profiling.

Where a project may involve pupil data, SEND-related information, safeguarding-adjacent information, behavioural information or other sensitive context, this must be agreed with the school in advance and handled under appropriate safeguards.

These safeguards may include:

Data minimisation

Access controls

Clear role permissions

Human oversight

Approved tool use

Retention limits

Deletion or return procedures

School-led approval

DPIA support where required

We do not use school, staff, pupil, parent or carer data to train public AI models unless this has been expressly agreed in writing and is lawful for the relevant use case.


9. AI Tool Use and Personal Data

We design AI-supported workflows to avoid unnecessary use of personal data.

Where possible, AI tools are used with anonymised, minimised or non-identifiable information.

Where personal data is required for an agreed workflow, we consider:

The purpose of processing

Whether personal data is necessary

The type and sensitivity of the data

Tool configuration

Retention settings

Access controls

Whether prompts or outputs may be reviewed by humans

Whether data may be used for model training

Whether the tool is appropriate for the client context

We do not intentionally submit personal data into public AI tools where that data may be used to train external models, unless this has been specifically agreed in writing and is lawful for the relevant use case.

AI outputs are used to support workflow consistency, drafting, analysis, routing or triage. They do not replace professional judgement, safeguarding judgement, educational decision-making or human accountability.


10. Cookies and Analytics

We use cookies and similar technologies to operate our website, remember preferences, understand website performance and, where enabled, support marketing.

Essential cookies are used to make the website work.

Analytics and marketing cookies are only used where lawful and where appropriate consent has been obtained.

You can manage your cookie choices through our cookie banner or browser settings.

For more information, please see our Cookie Policy.


11. Marketing Communications

You may receive marketing communications from us if:

You have opted in

You have requested information from us

You have an existing business relationship with us

We have a legitimate interest in contacting you in a B2B context and the law permits this

You can unsubscribe at any time by using the unsubscribe link in our emails or by contacting us.

We do not sell personal data to third parties for marketing.

We do not send marketing communications directly to children.


12. SMS Communications

Where you opt in to receive SMS communications from Stack Integral:

Messages may relate to your enquiry, services, updates or relevant offers

Message and data rates may apply

You may opt out at any time by replying STOP

We do not share phone numbers for third-party marketing without explicit consent

Where SMS workflows are provided for a client, the client is responsible for ensuring that recipients can lawfully be contacted and that appropriate consent, legitimate interest assessment or other lawful basis is in place.


13. Data Retention

We retain personal data only for as long as necessary for the purpose it was collected.

Typical retention periods may include:

Website enquiries: up to 24 months after last meaningful contact

Marketing contacts: until you unsubscribe or object

Client records: for the duration of the client relationship and up to 6 years afterwards where required for legal, tax, accounting or contractual reasons

Contract and invoice records: up to 6 years

Service delivery data: for the period agreed with the client

School or pupil-related data: only for the period agreed with the school or education setting

Cookie consent records: for the period required to evidence consent and manage preferences

Where we act as a processor, data retention is governed by the client’s instructions and the applicable agreement.

We may retain limited records where required to establish, exercise or defend legal claims, comply with law, or maintain suppression lists.


14. International Data Transfers

Personal data may be transferred to and processed in countries outside the UK or European Economic Area where our service providers operate.

Where required, we use appropriate safeguards such as:

UK International Data Transfer Addendum

Standard Contractual Clauses

Adequacy regulations

Equivalent lawful transfer mechanisms

Where we act as a processor, international transfers are handled in accordance with the relevant agreement and documented instructions.


15. Your Rights

Subject to applicable law, you may have the right to:

Access your personal data

Request correction of inaccurate data

Request deletion of your data

Restrict processing

Object to processing

Withdraw consent

Request data portability

Object to direct marketing

Not be subject to solely automated decisions with legal or similarly significant effects

To exercise your rights, contact:

[email protected]

We may need to verify your identity before responding.

Where Stack Integral acts as a processor, we may need to refer your request to the relevant client, school or organisation acting as controller.


15a. Right to Complain

You have the right to lodge a complaint with the Information Commissioner’s Office if you believe your personal data has been handled unlawfully.

ICO website: ico.org.uk
ICO helpline: 0303 123 1113

We would appreciate the opportunity to address your concerns before you contact the ICO.


16. Security

We use appropriate technical and organisational measures to protect personal data.

These may include:

Access controls

Secure systems

Password protection

Encryption where appropriate

Data minimisation

Role-based access

Secure sharing procedures

Monitoring and logging where appropriate

Personnel confidentiality obligations

Supplier due diligence

Incident response procedures

No system is completely secure. Please do not send sensitive information by unencrypted email unless necessary and agreed.


17. Children’s Data

Our website and marketing are intended for adults, including business owners, organisational decision-makers, school leaders, staff, governors and trustees.

We do not knowingly collect personal data directly from children through our website for marketing purposes.

Where we work with schools or education settings, we may process children’s personal data only where instructed by the school or education setting and only for the agreed educational, operational or safeguarding-compatible purpose.

Children’s data is treated with additional care.

Where children’s data is included in scope, we apply appropriate safeguards, which may include:

Data minimisation

Access controls

Clear role permissions

Appropriate security measures

Human oversight

Approved tool use

Clear deletion or return procedures

Where required, the school or education setting is responsible for ensuring that appropriate privacy notices, lawful basis assessments, parental communications, DPIAs and internal approvals are in place.

We do not use children’s data for advertising, resale, unrelated profiling or public AI model training.


18. Policy Updates

We may update this Privacy Policy periodically.

Changes will be posted on this page with an updated “Last updated” date.

Where changes are material, we may take additional steps to notify affected individuals or clients where appropriate.


19. Contact

For questions about this Privacy Policy or how we handle personal data, contact:

Stack Integral Limited
Email: [email protected]
Website: stackintegral.com
Company No: 17014408
ICO Registration Number: ZC110679


DATA PROCESSING ADDENDUM (DPA)

Last updated: 12 May 2026

This Data Processing Addendum (“DPA”) forms part of any agreement between Stack Integral Limited (“Processor”, “Stack Integral”, “we”, “us” or “our”) and the client, school, trust or organisation (“Controller”, “Client” or “you”) where Stack Integral processes personal data on behalf of the Controller.


1. Purpose and Scope

This DPA governs the processing of personal data by Stack Integral on behalf of the Controller in connection with the provision of AI-supported workflow, automation, revenue systems, education readiness, implementation and related services.

It applies where Stack Integral acts as a data processor under:

UK GDPR

EU GDPR where applicable

Data Protection Act 2018

Other applicable data protection laws

Where Stack Integral processes personal data for its own purposes, such as website enquiries or its own marketing, it acts as a controller and those activities are governed by the Privacy Policy above.


2. Roles and Responsibilities

Controller

The Controller:

Determines the purposes and means of processing personal data

Confirms it has a lawful basis for the processing

Confirms it has the right to share personal data with Stack Integral

Provides appropriate privacy notices to data subjects

Handles data subject rights requests unless otherwise agreed

Ensures special category, children’s, SEND or safeguarding-related data is only shared where lawful and necessary

Ensures internal approvals, DPIAs and governance steps are completed where required

Processor

Stack Integral:

Processes personal data only on documented instructions from the Controller

Does not determine the Controller’s purposes for processing

Applies appropriate technical and organisational safeguards

Ensures authorised personnel are bound by confidentiality

Assists the Controller with compliance obligations where reasonably possible

Notifies the Controller if, in our opinion, an instruction appears to infringe applicable data protection law


3. Subject Matter, Duration, Nature and Purpose of Processing

Subject matter

The subject matter of processing is the provision of services agreed between Stack Integral and the Controller.

This may include:

AI-supported workflow design

CRM automation

Enquiry handling workflows

Lead routing and qualification

Follow-up automation

Database reactivation

SMS or email workflow support

Reporting and dashboards

School AI readiness support

Education workflow support

Operational process improvement

Duration

Processing lasts for the term of the agreement, unless a different retention or deletion period is agreed in writing.

Nature of processing

Processing may include:

Collection

Recording

Organisation

Structuring

Storage

Retrieval

Consultation

Use

Analysis

Matching

Routing

Transmission

Restriction

Deletion

Return

Purpose of processing

The purpose of processing is to deliver the agreed services and support the Controller’s workflows, operations, communications, reporting and agreed AI-supported processes.


4. Categories of Data and Data Subjects

Categories of data subjects

Depending on the agreed services, data subjects may include:

Client employees, contractors and authorised users

Customers

Prospects

Leads

Business contacts

Website or enquiry submitters

Suppliers

School staff

Governors

Trustees

Parents, carers and guardians

Pupils, prospective pupils or former pupils, where expressly included in scope

Other individuals whose data is included in systems or workflows provided by the Controller

Categories of personal data

Depending on the agreed services, personal data may include:

Names

Contact details

Job titles

Organisation or school information

CRM records

Communication content

Enquiry details

Lead status

Quote or proposal status

Customer history

Notes, tags and workflow fields

Interaction metadata

System activity

Staff training or participation data

Education-related operational data

Parent, carer or pupil-related information where expressly included in scope

Special category or sensitive data

Special category, safeguarding-adjacent, SEND-related, health-related, behavioural or highly sensitive data must only be processed where:

It is expressly included in the agreed scope

The Controller confirms it is lawful and necessary

Appropriate safeguards are in place

Access is limited to those who need it

Retention and deletion rules are clear


5. Lawful Processing and Confidentiality

Stack Integral shall:

Process personal data only on documented instructions from the Controller

Ensure personnel with access to personal data are subject to confidentiality obligations

Not disclose personal data to third parties except as permitted under this DPA, the main agreement, the Controller’s instructions or applicable law

Take reasonable steps to ensure that any person acting under our authority processes personal data only as instructed


6. Sub-Processors

The Controller gives Stack Integral general written authorisation to engage sub-processors where necessary to deliver the agreed services.

Sub-processors may include providers of:

Hosting

CRM systems

Automation platforms

Email tools

SMS or communication tools

Analytics

Secure storage

AI tools

Project management tools

Integration services

Stack Integral will:

Conduct appropriate due diligence on sub-processors

Ensure sub-processors are subject to appropriate data protection obligations

Remain responsible for sub-processor compliance where required by law

Make sub-processor information available on request

Notify the Controller of material changes where required by the agreement

Current or potential sub-processors may include, depending on the agreed service:

HubSpot

Google Workspace

Microsoft 365

OpenAI or other agreed AI providers

GoHighLevel or website/form providers

Twilio or other SMS providers

Make, Zapier, n8n or other automation providers

Analytics or consent management providers

Other tools agreed with the Controller during onboarding or implementation

The actual sub-processors used for a specific client will depend on the agreed project and tool stack.


7. International Data Transfers

Where personal data is transferred outside the UK or European Economic Area, Stack Integral will ensure appropriate safeguards are in place where required.

These may include:

UK International Data Transfer Addendum

Standard Contractual Clauses

Adequacy regulations

Equivalent lawful transfer mechanisms

Stack Integral will not make international transfers contrary to the Controller’s documented instructions.


8. Security Measures

Stack Integral implements appropriate technical and organisational measures to protect personal data.

These may include:

Access controls

Role-based permissions

Secure authentication

Secure infrastructure

Data minimisation

Encryption where appropriate

Confidentiality obligations

Supplier due diligence

Monitoring and logging where appropriate

Secure data sharing practices

Regular review of workflows and access

Incident response procedures

Detailed security information may be provided on reasonable request.


9. Data Subject Rights

Stack Integral will assist the Controller, where reasonably possible, in responding to data subject rights requests.

This may include requests for:

Access

Rectification

Erasure

Restriction

Objection

Data portability

Withdrawal of consent

Objection to direct marketing

Rights relating to automated decision-making

If Stack Integral receives a request directly in relation to personal data processed on behalf of the Controller, we will refer the request to the Controller unless legally prohibited from doing so.


10. Data Breach Notification

In the event of a personal data breach affecting personal data processed under this DPA, Stack Integral will:

Notify the Controller without undue delay after becoming aware of the breach

Provide available information to support the Controller’s compliance obligations

Take reasonable steps to contain, investigate and mitigate the breach

Cooperate with the Controller’s reasonable requests relating to the breach

The Controller is responsible for determining whether notification to the ICO, another regulator or affected individuals is required, unless otherwise required by law.


11. Data Retention, Return and Deletion

Upon termination of services, or upon written instruction from the Controller, Stack Integral will delete or return personal data processed on behalf of the Controller, unless retention is required by law.

Where deletion is requested, we will take reasonable steps to delete personal data from active systems and instruct relevant sub-processors to do the same where applicable.

Some data may remain temporarily in backups or logs until overwritten according to normal retention cycles, unless earlier deletion is technically feasible.


12. Audits and Compliance

Stack Integral will:

Maintain appropriate records of processing activities where required

Provide reasonable information to demonstrate compliance with this DPA

Cooperate with audits where required by applicable law

Ensure audits are subject to reasonable notice, confidentiality and security requirements

Avoid unnecessary disruption to services or other clients

Where an independent audit, certification or security report is available, this may be provided instead of direct audit access where appropriate.


13. Assistance with DPIAs and Prior Consultation

Where reasonably possible, Stack Integral will assist the Controller with:

Data protection impact assessments

Risk reviews

Security assessments

AI governance reviews

Prior consultation with a regulator where required

This assistance may be subject to reasonable scope, timing and fees depending on the nature of the request.


14. Liability

Each party’s liability under this DPA is subject to the limitations set out in the main agreement, except where prohibited by law.

Nothing in this DPA limits liability where liability cannot legally be limited.


15. Education Services Schedule

This section applies where Stack Integral provides services to a school, college, education setting, tutoring organisation or multi-academy trust.

15.1 Controller and processor roles

The school, trust or education setting is normally the data controller.

Stack Integral acts as data processor unless otherwise agreed in writing.

The school remains responsible for:

Lawful basis

Privacy notices

Parent, carer, pupil or staff communications

DPIAs where required

Internal approvals

Safeguarding procedures

SEND governance

Appropriate use of education records

Decisions about pupil support, safeguarding or educational outcomes

15.2 Pupil data

Stack Integral will only process pupil data where:

It is expressly included in the agreed scope

The school has confirmed that processing is lawful and necessary

The data is limited to what is needed

Access is restricted

Appropriate safeguards are in place

Stack Integral will not use pupil data for:

Advertising

Resale

Unrelated commercial purposes

Independent profiling

Public AI model training

Direct marketing to pupils

15.3 SEND, safeguarding and sensitive information

SEND-related, safeguarding-adjacent, health-related, behavioural or other sensitive pupil information must only be processed where expressly agreed.

Where such data is included, the school must identify:

The purpose of processing

The categories of data involved

Who may access the data

Any safeguarding escalation requirements

Retention and deletion rules

Whether a DPIA is required

Stack Integral does not replace the role of the DSL, SENCO, teachers, governors, school leaders or safeguarding professionals.

15.4 AI use in education projects

Where AI tools are used in education projects, Stack Integral will aim to ensure that:

Personal data is avoided unless necessary

Data is minimised

Sensitive data is not used unless expressly agreed

Tools are selected and configured with appropriate safeguards

Human oversight remains in place

AI outputs are reviewed by appropriate school staff where required

AI does not make final safeguarding, SEND, disciplinary or educational decisions

15.5 Direct contact with pupils, parents or carers

Stack Integral will not directly contact pupils, parents or carers unless instructed by the school and only within the agreed scope.

Where communication workflows involve parents or carers, the school remains responsible for ensuring that messages are lawful, appropriate and aligned with school policies.

15.6 Retention and deletion

Pupil, parent, carer, staff or education-related data will be retained only for the period agreed with the school.

At the end of the service, data will be deleted or returned according to the school’s documented instructions, unless retention is legally required.

15.7 Safeguarding escalation

If Stack Integral becomes aware of information that may indicate an immediate risk to a child or vulnerable person, Stack Integral will follow the safeguarding escalation route agreed with the school or education setting.

Stack Integral does not provide safeguarding advice and does not replace statutory safeguarding duties.


16. Contact

For data protection or DPA-related enquiries:

Stack Integral Limited
Email: [email protected]
Website: stackintegral.com
Company No: 17014408
ICO Registration Number: ZC110679

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