Privacy policy

1. Introduction

Capital Consult Ltd (trading as Sacher AI) is the data controller for the purposes of the UK GDPR and Data Protection Act 2018 in relation to personal data processed through the PromptSafe^® website and platform, except where we act as a processor on behalf of customers.

Registered office: 6/28a Wincott Street, London, SE11 4NT.
Company number: 06800173.
ICO registration number: ZC144061.
Privacy enquiries: info@sacher.ai.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website at prompt-safe.com and the PromptSafe platform at app.prompt-safe.com.

2. How we act as controller and processor

PromptSafe is a business-to-business software platform.

For website visitors, account administration, billing, analytics, security monitoring, and business operations, Capital Consult Ltd acts as a data controller.

For customer workspace content processed through PromptSafe, customers are generally the controllers and Capital Consult Ltd generally acts as a processor acting on the customer's documented instructions.

Customers remain responsible for ensuring they have an appropriate lawful basis and all necessary rights and permissions for any personal data uploaded or processed through PromptSafe.

3. Information we collect

We collect the following categories of personal data:

• Registration and sign-up data: first name, work email address, company name, and a description of what you are building.
• Account data: login credentials and account settings.
• Usage data: how you interact with the platform, including features used, pages visited, session duration, and actions taken.
• Workspace content: agents, personas, evaluators, conversation transcripts from simulations, and any other content you create or upload within the platform.
• Communications: emails and messages you send to us.

PromptSafe is designed primarily for synthetic AI-generated testing workflows. Customers may choose to upload or process limited personal data within workspaces and remain solely responsible for ensuring lawful processing.

Customers should avoid uploading unnecessary personal data, identifiable patient information, regulated health records, or special category personal data unless they have independently ensured a valid legal basis and appropriate safeguards under applicable law.

4. How we use your data

We use your data to:

• Provide, maintain, and improve the PromptSafe platform and services.
• Manage your account and process payments.
• Send you onboarding communications, product updates, and service notifications.
• Respond to your enquiries and provide support.
• Ensure platform security and prevent abuse.
• Understand how users interact with the platform to inform improvements.

5. Workspace content and our access to it

Customer workspace content (agents, personas, evaluators, conversation transcripts, and any other material you create or upload) is logically segregated from other customer environments and is not intentionally shared across customer workspaces.

We distinguish between Customer Product Assets and Evaluation Assets. Customer Product Assets means materials that describe, configure or reveal the Customer's own AI system or proprietary information, including agent prompts, system prompts, agent instructions, agent documentation, uploaded knowledge base or RAG material, proprietary workflows, business logic and configuration. Evaluation Assets means materials created or used in the PromptSafe evaluation process, including personas (PromptSafe-generated and customer-created), evaluators (PromptSafe-generated and customer-created), synthetic simulation conversations, customer-entered role-play content, evaluator scores, outputs, reasoning and labels, quality scores, evidence metrics, benchmark results, derived metadata and aggregate statistics. We do not use Customer Product Assets, or any workspace content, to train third party or general purpose foundation AI models, and we do not use Customer Product Assets for research or product improvement by default. We may use Evaluation Assets, with appropriate safeguards, to improve our own technology and for research, as described in the Research and product improvement section below.

We do not routinely access customer workspace content. Limited access may occur where reasonably necessary for customer support, platform maintenance, security investigation, legal compliance, or prevention of misuse, and where possible will occur with customer authorisation.

For enterprise engagements, Sacher AI may access and work inside the workspace as part of the agreed engagement. Enterprise access is documented in the order form or statement of work for that engagement.

6. Research and product improvement

We continually improve PromptSafe through scientific research, validation studies, and ongoing product development. Where permitted by law, and relying on our legitimate interests in improving and validating our services, we may use Evaluation Assets and appropriately handled customer-derived information for the purposes of:

• improving PromptSafe products and services;
• developing and validating evaluation methodologies;
• improving automated evaluation methodologies, models, and classifiers;
• benchmarking system performance;
• developing safety, quality, and governance features;
• conducting internal research and validation studies;
• publishing aggregated scientific findings.

Customer Product Assets and Evaluation Assets are defined in section 5. In summary, Customer Product Assets describe your own AI system, and Evaluation Assets are created or used as part of the evaluation process.

We do not use Customer Product Assets for research or product improvement by default. Where their use is exceptionally necessary, it requires a clear legal basis, internal governance approval, and appropriate transparency. PromptSafe improves primarily by learning how AI systems behave during evaluation, not by learning from the proprietary design of customer AI systems.

Our research uses the least sensitive data capable of answering the research question. We prefer evaluation metrics, synthetic assets, evaluator outputs, derived metadata, and aggregated results over raw Customer Product Assets where they provide equivalent scientific value.

Simulation transcripts are part of the evaluation process and may be used as Evaluation Assets, with appropriate safeguards. This covers synthetic simulation conversations generated between personas and your agent, and content you enter manually as part of a simulation. Personas and evaluators you create are also Evaluation Assets and may be used for research and product improvement; they remain your workspace content and are handled with confidentiality and, where appropriate, deidentification safeguards. If PromptSafe ever supports uploading or connecting real end-user conversations, we will treat that as a separate processing activity with its own legal and governance assessment.

We do not use Customer Product Assets or workspace content to train third party or general purpose foundation AI models.

Where we use Evaluation Assets for research, we will hold them in an internal research knowledge base, the PromptSafe Research Knowledge Base, comprising primarily Evaluation Assets, derived metadata, benchmarking data, and aggregated metrics, together with anonymised or appropriately handled customer-derived information where required. Access to the knowledge base will be restricted to authorised personnel and governed by the PromptSafe Research & Data Governance Framework, our internal research governance framework. Before workspace content enters the knowledge base it will undergo a documented deidentification process which, where applicable, removes or replaces names, email addresses, phone numbers, addresses, account identifiers, and other directly identifying information, and assesses the residual risk of reidentification. Where data cannot be genuinely anonymised, we will treat it as pseudonymised personal data and handle it accordingly.

When we use Evaluation Assets for our own research and product improvement, we act as a data controller for that processing, because we determine its purposes and means (see section 2). You keep all your rights under data protection law, including the right to object to processing based on legitimate interests (see section 13). Where we receive an objection, we assess it on its merits and stop the processing unless we have compelling legitimate grounds that override your interests, rights, and freedoms.

Any research we publish will be conducted using the PromptSafe Research Knowledge Base under the PromptSafe Research & Data Governance Framework. It will contain only aggregated or anonymised findings, and will never identify individual customers, organisations, or users without explicit written permission.

7. Sacher AI workspace curation

On the self-serve tier, Sacher AI may add curated example content to your workspace, such as personas or evaluators that are relevant to your sector. Customers are not notified before items are added. Any items Sacher AI adds are clearly labelled as examples so you can distinguish your own work from what we have added. Sacher AI does not intentionally modify or delete content you have created except where required for platform operation, legal compliance, security, abuse prevention, or at your request.

8. Lawful bases for processing

We rely on the following lawful bases under UK GDPR (and EU GDPR where applicable):

9. AI processing and third-party providers

Important. When you use PromptSafe with Sacher AI-provided model access, conversation data is transmitted to third-party large language model providers for processing. This includes your agent's instructions, synthetic persona messages, agent responses, and any messages you type yourself during a conversation. If you connect your own API key on the enterprise tier, your use of those providers is governed by your own agreement with them.

We integrate with the following third-party model providers: OpenAI, Anthropic, and xAI. Each provider processes data in accordance with their own privacy policies. You should not input real personal data of identifiable individuals into the platform without an appropriate legal basis.

10. Service providers and subprocessors

We work with the following service providers to deliver PromptSafe:

We will give customers advance notice of any intended addition or change to our subprocessors, so that customers have the opportunity to review the change. We will provide this notice by email or through a notice on the platform.

11. Cookies and analytics

We use necessary cookies required for operation of the website and platform, and optional analytics cookies to understand usage and improve services. Optional analytics cookies will only be activated where required by applicable law and where appropriate consent has been provided.

For full details, please see our Cookie policy.

12. Data retention

Workspace content is retained while the relevant customer account remains active. Customers may request deletion of workspace content by contacting info@sacher.ai.

We may retain limited backup, billing, audit, security, fraud prevention, or legal compliance records where reasonably necessary.

Analytics data may be retained for operational and product improvement purposes for a limited period.

Any data held in the PromptSafe Research Knowledge Base will be retained under the PromptSafe Research & Data Governance Framework described in section 6. Genuinely anonymised data is not personal data, so it falls outside these retention limits and outside the erasure rights in section 13. Where data in the knowledge base is pseudonymised rather than genuinely anonymised, we retain and handle it as personal data in line with this policy.

13. Your rights

Under UK GDPR (and EU GDPR where applicable), you have the following rights regarding your personal data:

• Right of access: to request a copy of the personal data we hold about you.
• Right to rectification: to request correction of inaccurate data.
• Right to erasure: to request deletion of your data in certain circumstances.
• Right to restriction: to limit how we process your data.
• Right to object: to object to processing based on legitimate interests.
• Right to data portability: to receive your data in a structured, machine-readable format.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, please contact us at info@sacher.ai.

Where we process personal data solely on behalf of customers acting as independent controllers, we may direct requests relating to such data to the relevant customer.

14. US state privacy rights

This section applies to individuals who are residents of the United States, including California and other states that have enacted comprehensive privacy laws.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We have not done so in the preceding twelve months.

Where US state privacy laws apply to you, you have the following rights, subject to the limits and exceptions in the relevant law:

• The right to know what personal information we collect about you and how we use and disclose it.
• The right to access a copy of the personal information we hold about you.
• The right to request correction of inaccurate personal information.
• The right to request deletion of your personal information.
• The right to opt out of the sale of personal information and of sharing for cross-context behavioral advertising. As stated above, we do not sell or share personal information, so there is nothing to opt out of, but you may still exercise this right.
• The right not to receive discriminatory treatment for exercising any of these rights.

To exercise any of these rights, contact us at info@sacher.ai. We will verify your request before acting on it and will respond within the timeframe required by applicable law. You may use an authorized agent to submit a request on your behalf, where the relevant law allows it.

Where we process personal information solely on behalf of a customer acting as the business or controller, we will direct your request to that customer.

15. Automated decision making

PromptSafe does not make legally significant automated decisions about individuals within the meaning of Article 22 UK GDPR.

16. International data transfers

We primarily host customer workspace data within the European Economic Area using infrastructure located in Frankfurt, Germany.

Certain service providers may process limited personal data outside the UK or EEA, including in the United States.

Where transfers occur outside the UK or EEA, we rely on recognised transfer safeguards including adequacy decisions, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or equivalent lawful transfer mechanisms.

Some of our service providers are located in the United States. This includes the third-party AI inference providers we integrate with, namely OpenAI, Anthropic, and xAI. When you use PromptSafe with Sacher AI-provided model access, conversation data is transmitted to these providers in the United States for processing, as described in section 9.

Where personal data is transferred from the United Kingdom or the European Economic Area to the United States or another country outside the UK or EEA, we rely on appropriate safeguards. These include the European Commission Standard Contractual Clauses, the UK International Data Transfer Agreement, the UK Addendum to those clauses, or another lawful transfer mechanism. Customers should avoid inputting real personal data of identifiable individuals into the platform unless they have an appropriate legal basis and have addressed any transfer requirements that apply to them.

17. Security

We maintain technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. No system is perfectly secure; if we become aware of a personal data breach affecting you, we will notify you and the relevant authorities in line with our legal obligations.

18. Age restriction

PromptSafe is intended solely for business and professional use and is not directed to individuals under the age of 18.

PromptSafe is not directed to children. We do not knowingly collect personal information from anyone under the age of 13, consistent with the United States Children's Online Privacy Protection Act (COPPA), or from anyone under the age of 18. The platform contains synthetic test content that references sensitive and adult subject matter, and is intended solely for professional use by adults. If we become aware that we have collected personal information from a child, we will delete it.

19. Marketing communications

If you create an account, contact us, or sign up for a free trial, we may send you service-related communications, onboarding emails, and, where permitted, product updates or marketing communications. Marketing emails sent from info@sacher.ai include an unsubscribe link, and you may opt out at any time.

20. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or via a notice on the platform. The date at the top of this page reflects when the policy was last updated.

21. Contact

Data controller: Capital Consult Ltd (trading as Sacher AI)
Email: info@sacher.ai
Website: sacher.ai

If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.