AK Frames Ltd (company number SC617144), Unit 12, Randolph Place, Randolph Industrial Estate, Kirkcaldy, KY1 2YX, United Kingdom, makes the AK Cortex app and is the data controller for the personal data described in this policy.

You can reach us about anything in this policy at info@akframes.co.uk.

AK Cortex is a private business app for the owner and directors of AK Frames Ltd, and for members of our staff we invite. It is not a public service. You cannot sign up in the app. You sign in with an AK Operations account, and the app shows its figures only to accounts we have given AK Cortex access.

The app shows figures about our own business, taken from our own systems: sales, production-floor activity, orders, couriers, inter-company invoices, and staff information such as names, attendance and right-to-work status. The order page shows its progress, not the customer's name, address or contact details.

The app mostly reads these figures. The one exception is Needs you, a list of items that are waiting for a decision from you. There you can approve or refuse an item, and the decision is recorded in our systems, as described below. Nothing else in the app changes our business records.

The staff information in the app comes from the records we already keep as an employer. This policy covers the personal data the app itself handles.

Your sign-in. You sign in with the email address and password of your AK Operations account. Your password goes only to Firebase Authentication, a Google service; we never see it. Firebase Authentication gives us your email address and your account ID, which we use to check that you are allowed into the app. The phone keeps your signed-in session, never your password, until you sign out.

Technical and security data. Firebase processes IP addresses, device, operating-system, app and SDK versions, account identifiers and the names of server functions called by the app. These support sign-in, security, app functionality and service performance. Server records can show which feature was used and its timing. We do not include an advertising or usage-analytics SDK. See Firebase's Android data disclosures for details of its services.

Decisions you take under Needs you. Needs you lists items such as an expense, a purchase, a pay review, a payroll run, a request for access to AK Operations or an escalated refund. When you tap Approve, Refuse, Mark paid or Give access, the app first shows you in words what will happen, and it sends nothing until you confirm. Some decisions ask you to type something first: a role when you give someone access, or a reason when you refuse a refund.

When you confirm, the app sends our servers which item it is, your decision and anything you typed. Your sign-in identifies you. We record the decision with the item in AK Operations, together with your name, email address, account ID and the time, exactly as if you had decided in AK Operations itself. Refund and access decisions are also written to our audit log. A reason you type is kept with the item and can be seen by the colleagues who handle it. A decision has the same effects as in AK Operations: for example, marking a payroll run as paid emails each person on it their payslip, and giving someone access lets them use AK Operations with the role you chose. The voice assistant cannot take these decisions; only your confirmed tap can.

Your permission before anything goes to Google Gemini.Cortex, the app's assistant, is powered by Google Gemini. Before the app sends anything to Gemini for the first time, whether a voice conversation, a suggested question you tap, a voice-led tour or Explain, or a voice preview in the voice settings, it tells you what will be sent and asks your permission. If you choose not to allow it, nothing is sent to Gemini and the rest of the app still works, including the tour and Explain as captions only. You can withdraw your permission at any time in the app's settings, and nothing more is sent to Gemini unless you allow it again.

What is sent to Gemini.While a conversation is on, the sound from your microphone and any suggested question you tap go to Google's Gemini API (Google LLC), which understands you and produces Cortex's replies. At the start of every conversation Gemini is also given your first name, so that Cortex can address you, and a briefing of the figures on the app's Today, Money, Operations and People pages. That briefing includes staff names, attendance and absences, and right-to-work and visa status with expiry dates. During the conversation Cortex can look up more detail to answer you, such as an order's progress, a person's attendance record, the items waiting under Needs you (a request for access names the person and gives their email address) or the risk register (a parcel in an open courier claim carries its order reference, its tracking number and the customer's postcode). After you accept the expanded notice, an administrator can also ask Cortex to read relevant historical sales, employee attendance, stock, production, finance and other business records. Depending on the question, these can include customer and staff contact details, recorded staff costs, purchase history and business-document metadata. Those lookup results are sent to Gemini to answer the question. Authentication credentials and secret settings are not exposed through these tools.

The microphone.The app asks for your phone's permission to use the microphone the first time you start a voice conversation or a voice-led tour, not when it opens. It uses the microphone only while a conversation or voice-led tour you started is running, or when you open the Ask tab if you have switched on “Listen when I open Ask” (it is off unless you turn it on). Conversations are hands-free unless you choose hold to talk in the voice settings. It does not listen at any other time. iOS and supported Android versions show a microphone indicator while it is in use. On iOS it can also show briefly during a voice preview, although no sound is sent then. Android voice previews do not request microphone access. “Keep talking when locked” is on unless you turn it off: a conversation you started carries on with the screen locked. A conversation ends when you end it or after the period of quiet you choose in the voice settings. You can turn microphone access off at any time in your phone's Settings, under Apps, AK Cortex and its microphone permissions. On Android, an ongoing notification identifies a voice conversation running with the screen locked; ending it stops microphone use.

What we keep of a conversation.AK Frames does not record or keep your voice, and does not save a complete conversation. The written transcript is kept on your phone, in the app's memory only; it is not saved to storage, and it is removed when you tap Clear or when the app is fully closed. You can hide it with “Live transcript” in the voice settings. When a voice-led tour reconnects, the app sends your last few questions to our server as text so that Cortex can carry on where it was; our server passes them to Gemini and does not store them. Our servers keep only brief technical records of a voice session (that it started, which areas of data it looked up and how long that took), not what was said. Longer analyses temporarily store their lookup parameters and results on our server so the app can collect the completed answer. These are private to the requesting administrator. Access expires after fifteen minutes, and expired lookup records and sales caches are removed by a cleanup that runs every six hours.

App feedback. When you request a new feature or report a bug to Cortex, it can save the request, relevant context, your account ID, app version, platform and time in a private review queue. The request applies to both iOS and Android. We use that queue for weekly engineering reviews, including review with OpenAI Codex, to improve the apps. Cortex confirms a save only after the server records it; a saved request does not mean an app update has already been released. We retain feedback while reviewing, implementing and verifying improvements and as their review history.

On Android you can also tap Report on Ask, or Report an AI response in voice settings, without starting voice or allowing the microphone. Before you send, the app explains that your typed report, account ID, app version and platform will be saved with AK Frames on Google Firebase and may be reviewed with OpenAI Codex. This control does not automatically attach voice recordings or a conversation transcript.

What Google does with it.We use the Gemini API on a paid Google Cloud account. Under Google's terms for paid use, Google does not use what is sent to Gemini, or Gemini's answers, to improve its products. Google may keep them for a limited period only to detect and prevent abuse of the service, as described in Google's Gemini API terms.

The guided tour and Explain. The tour and the Explain buttons can be narrated by voice, which uses Gemini and the microphone in the same way as the voice assistant and needs the same permission, or shown as captions only. The tour is narrated by voice unless you choose captions only or use VoiceOver or TalkBack. With captions only, nothing is sent to Gemini and the microphone is not used.

On your phone. The app keeps your settings, your progress through the tour, your recent order searches and a copy of the latest figures on your phone, so that it opens quickly and works when you are offline. These stay on the device. Deleting the app removes them.

The figures the app shows, and the briefing and look-ups it gives Gemini, include personal data about other people: our staff (names, attendance, absences, right-to-work and visa status), people who have asked for access to AK Operations (their name and email address), and, for parcels in an open courier claim, the order reference, tracking number and postcode of the customer. Expanded administrator lookups can also include the business contact, cost and document information described above. We handle that data as described in this policy and under our notices to staff and customers.

AK Cortex contains no advertising and no analytics or advertising software, and it does not send push notifications. We do not track you across other companies' apps or websites, we do not sell your data, and we do not share it with data brokers. We do not use the app to build profiles of you, and we do not use your data to train AI models.

If you have chosen in your iPhone's settings to share analytics with app developers, Apple may give us crash reports that do not identify you. That choice is yours and is controlled by Apple. Google Play may provide Android app-performance information under its own device and Google Play settings.

We process your sign-in details, your Needs you decisions and your conversations with Cortex so that we can give you secure access to the app, carry out and keep a record of the decisions you take, and answer your questions. Our lawful basis is our legitimate interests in running and overseeing our business, and, where you are one of our employees, the performance of your contract with us. We keep records of decisions because we need to know who approved what, and when.

In addition, the app asks your permission before anything is sent to Google Gemini, and you can withdraw it at any time in the app's settings.

Google provides the services the app runs on: Firebase Authentication, Cloud Firestore, Cloud Functions, Cloud Logging and the Gemini API, under its terms for those services. For the limited records the Gemini API keeps to detect and prevent abuse, Google decides how they are used, under its own terms. OpenAI Codex may process the saved app feedback during our engineering review. Apple delivers the iOS app and Google Play delivers the Android app. We disclose data to public authorities only where the law requires it.

The business data the app reads, including the record of your Needs you decisions, is stored in Cloud Firestore in Google's eur3 multi-region, in data centres in Belgium and the Netherlands (European Union). The Cloud Functions that prepare the figures, record your decisions and start voice sessions run in Google's europe-west2 region in London. The brief technical records of voice sessions are kept in Google Cloud Logging.

Firebase Authentication, Cloud Logging and the Gemini API are global Google services. The data they handle, including what is sent to Gemini during a conversation, may therefore be processed outside the UK and the European Union, for example in the United States. Data held in the European Union is covered by the UK's adequacy regulations. Where data goes elsewhere, it is protected by the transfer safeguards in Google's data processing terms, such as the UK International Data Transfer Addendum.

Your sign-in is your AK Operations account, which we keep while you work with us. Your AK Cortex access ends when we remove it or when you ask us to. The brief technical records of voice sessions are deleted automatically after 30 days.

The record of a Needs you decision, including any reason you typed, is part of the business record of that item. It is kept for as long as we keep that record under our normal record keeping, not by the app.

We do not keep voice recordings or complete conversations. Saved app feedback and temporary analysis records are handled as described above. Google may keep what is sent to Gemini for a limited period to detect and prevent abuse, and does not use it to improve its products, as described in Google's Gemini API terms and privacy policy.

The business records the app shows are kept for the periods set by our normal record keeping, not by the app.

The app shows its figures only to accounts we have given AK Cortex access. A Needs you decision is sent only after you confirm it, and most items are checked again first to make sure nobody else has already decided them. Data in transit is protected with TLS. The key for the voice service never leaves our servers: each voice conversation uses a single-use token that must be used within two minutes of being issued.

Under UK data protection law (the UK GDPR and the Data Protection Act 2018) you have the right to ask for a copy of the personal data we hold about you, to have it corrected, to have it erased, to restrict or object to how we use it, and to receive it in a portable format.

Asking for your data. To ask for a copy of your data, or to use any of these rights, email info@akframes.co.uk.

Deleting your account. There is no sign-up in the app, so there is no delete button either. Email info@akframes.co.uk from the address you sign in with to have your AK Cortex access removed. If you also want your AK Operations account closed, say so: we will close it and delete the personal data we hold for it, apart from anything we must keep by law or as part of our business records, such as the record of decisions you took. We will tell you what we have kept and why.

We will respond to every request within one month. You can withdraw your permission for Google Gemini yourself at any time, in the app's settings.

You also have the right to complain to the Information Commissioner's Office at ico.org.uk.

AK Cortex is a workplace app for adults aged 18 and over. Google's Gemini API terms do not allow the service to be used in apps likely to be used by people under 18, so the app is not intended for anyone under 18, and we do not knowingly process children's personal data through it.

If we change how the app handles personal data, we will update this page and the date at the top. If a change is significant, we will tell the people who use the app directly before it takes effect.

Write to AK Frames Ltd, Unit 12, Randolph Place, Randolph Industrial Estate, Kirkcaldy, KY1 2YX, United Kingdom, or email info@akframes.co.uk. For help using the app, see AK Cortex Support.