Privacy Policy
Fractionality Limited (“Fractionality”, “we”, “us”, “our”) is committed to protecting your privacy and handling personal data transparently, securely, and in accordance with applicable data protection laws, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.
This Privacy Policy explains how we collect, use, store, and protect personal data when you interact with Fractionality, including through our websites, services, communications, compliance processes, and Frank, our AI-powered financial and strategic discussion tool.
1. Who We Are
Fractionality Limited is a UK-based provider of fractional CFO services, strategic financial advisory services, and related technology-enabled tools.
For the purposes of data protection law, Fractionality Limited is the data controller.
2. Scope of This Policy
This Privacy Policy applies to personal data collected through:
Our websites and domains (including fractionality.xyz and related subdomains)
Direct enquiries, contact forms, and email correspondence
Marketing and business development activities
Recruitment, contractor onboarding, and due-diligence processes
Compliance activities, including AML and KYC where applicable
Analytics, cookies, and website usage tracking
Frank – our AI-powered financial and strategic discussion tool, including both anonymous and account-based usage
3. Personal Data We Collect
3.1 Business and Contact Data
We may collect your name, job title, company name, email address, telephone number, and business information you choose to provide.
3.2 Marketing and Relationship Data
We may collect marketing preferences, records of communications, event attendance, and engagement with content.
3.3 Recruitment and Contractor Data
Where you apply for a role or work with us, we may collect CVs, professional history, qualifications, right-to-work checks, references, and assessment notes.
3.4 Compliance and Regulatory Data
Where required, we may collect AML and KYC information, identification documents, ownership and control details, and transaction-related compliance records.
3.5 Technical and Usage Data
We may collect IP address, browser type, device information, operating system, website usage data, logs, analytics, and cookie identifiers.
3.6 Account and Chat Data (Frank)
When you use Frank, we may collect:
Chat inputs you provide and AI-generated responses
Session metadata (timestamps, session identifiers, device or browser information)
Account details where you choose to register (first name, last name, email address)
Chat data is handled in two distinct ways:
Temporary Chat Logs (All Users)
Chats are temporarily logged for operational, security, and service-quality purposes, whether or not you create an account. These logs are retained for a limited period and are then deleted or anonymised.
Saved Chats (Account Users Only)
Where you create an account and give express permission, chats may be saved and associated with your account so that you can access them when you log back in. You may request deletion of saved chats at any time.
4. How We Use Personal Data
We use personal data to:
Respond to enquiries and provide services
Manage client, prospect, and partner relationships
Deliver marketing communications where permitted
Operate, maintain, and improve our websites and tools
Recruit and manage contractors and employees
Meet legal, regulatory, and compliance obligations
Protect our business, users, and systems
Monitor usage and prevent misuse
In relation to Frank, personal data is also used to:
Enable chat functionality and continuity for account users
Maintain platform security and integrity
Diagnose technical issues
5. Lawful Basis for Processing
We process personal data under one or more of the following lawful bases:
Consent – where you have provided clear permission
Contract – where processing is necessary to perform or enter into a contract
Legitimate interests – to operate, improve, and protect our business
Legal obligation – where processing is required by law or regulation
Saved chats linked to an account are processed on the basis of explicit user consent, which may be withdrawn at any time.
6. Use of Frank – AI-Powered Services
6.1 What is Frank?
Frank is an AI-powered financial and strategic discussion tool operated by Fractionality. It is designed to help founders, CEOs, and senior leaders explore business, financial, and strategic topics. Frank does not provide regulated advice and does not replace qualified professional advisers.
6.2 How Frank Data Is Used
Data collected through Frank is used to:
Generate responses and operate the Frank service
Provide optional chat history functionality for registered users
Monitor, maintain, and improve service quality and performance
Ensure platform security and prevent misuse
Investigate technical issues
Meet legal or regulatory requirements
AI outputs are generated automatically and are not routinely reviewed by humans except where necessary for operational, quality, or security purposes.
6.3 AI Models, Training, and Confidentiality
Conversations with Frank are not used to train any large language models (LLMs), whether public or private
Chat content is not shared with third parties
Chat content is not made publicly available
6.4 Confidentiality and Limitations
Frank is designed as a confidential discussion tool. However, Frank is an AI system and may generate inaccurate or incomplete information. Outputs should not be relied upon as professional advice, and users are responsible for verifying information with qualified professionals.
7. Cookies and Analytics
We use cookies and similar technologies to enable website functionality, analyse usage, and improve user experience. Cookie preferences can be managed through browser settings or any cookie controls provided on our website.
8. Data Sharing
We may share personal data with trusted service providers (including cloud hosting, analytics, and infrastructure providers) and professional advisers, acting under our instructions.
We do not sell personal data.
We do not share Frank chat content with third parties.
9. Data Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or misuse.
10. International Transfers
Where personal data is processed outside the UK, appropriate safeguards are in place to ensure compliance with UK GDPR requirements.
11. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected, including legal, regulatory, contractual, and legitimate business requirements.
12. Your Rights
You have the right to access, correct, delete, restrict, or object to the processing of your personal data, and to withdraw consent where applicable. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).
13. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will always be published on our website.
14. How to contact us
Questions or requests about this policy or your personal data
Email: hello@fractionality.xyz