Privacy Policy
Last updated: 24 April 2026 — Draft pending solicitor review
This Privacy Policy explains how Rubo Ltd (“Rubo”, “we”, “us”), a company registered in England and Wales, collects, uses, and shares personal data when you visit askrubo.ai, use console.askrubo.ai, or interact with our API at api.brokerflow.ai. It is written to comply with the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).
Rubo is a B2B service provided to real-estate brokers, agents, and their firms. When you use the Service on behalf of your employer or client, your employer or client is typically the controller of the personal data in the workspace and Rubo is the processor (see our DPA). This Privacy Policy describes our practices where Rubo itself is the controller — for example, your account registration, billing, marketing emails, and website analytics.
1. Who we are
- Controller: Rubo Ltd, a company registered in England and Wales.
- Registered office: [TO FILL BEFORE GOING LIVE]
- ICO registration number: [TO FILL BEFORE GOING LIVE]
- Data Protection Officer contact: privacy@askrubo.ai
2. What data we collect
| Category | Examples | Source |
|---|---|---|
| Account data | Name, work email, firm name, role, password hash | You, at sign-up |
| Billing data | Billing contact, VAT number, card last-4 (stored by Stripe) | You, via Stripe |
| Uploaded documents | Lease PDFs, heads-of-terms, NDAs, knowledge-base entries | You, during use |
| Conversational data | Chat messages, voice notes, prompts, model outputs | You, during use |
| Usage & diagnostic data | Pages viewed, features used, API calls, error logs, device type, IP | Automatic via Sentry, analytics |
| Communications | Emails to support, WhatsApp messages to Rubo’s broker-channel bot | You |
| Marketing data | Email open/click, event sign-ups, content downloads | Automatic via email platform |
Where documents you upload contain personal data of third parties (e.g. tenant names in a lease PDF), we process that data as your processor under the DPA, not as a controller.
3. Why we process your data (purposes and lawful bases)
| Purpose | Lawful basis |
|---|---|
| Provide and operate the Service | Contract (Art. 6(1)(b)) |
| Bill and collect fees | Contract; legal obligation (Art. 6(1)(b), (c)) |
| Customer support and service communications | Contract; legitimate interests |
| Security, fraud prevention, abuse monitoring | Legitimate interests (Art. 6(1)(f)) |
| Product analytics and usage measurement | Legitimate interests; consent where cookies require it |
| Improve and train AI models (anonymised) | Legitimate interests, with opt-out |
| Fine-tuning via Lease Donation Programme | Explicit consent (Art. 6(1)(a)) |
| Marketing to business prospects | Legitimate interests under PECR soft opt-in; consent for non-customers |
| Legal compliance (HMRC, ICO, AML) | Legal obligation |
4. AI training — opt-out and opt-in
Rubo may use de-identified, anonymised extracts of prompts and outputs to improve detection logic, prompts, and evaluation sets. This is our default behaviour and you can opt out from your workspace settings at any time.
We only use identifiable lease documents for fine-tuning where you explicitly enrol the document in the Lease Donation Programme. Donation requires a per-document tick-box, your warranty that you have the right to contribute the document, and our redaction pipeline. Donated documents are used to train the rubo-lease-v0 adapter and successor models.
5. How long we keep data
A summary is below; see our Retention Policy for full detail.
| Category | Retention |
|---|---|
| Broker account data | 7 years after closure (HMRC) |
| Uploaded lease PDFs | 2 years default; 30 days after deletion request |
| Chat messages | 12 months rolling |
| Voice notes | 90 days |
| Knowledge-base entries | Lifetime of account + 30 days |
| Training-opted-in data (anonymised) | Indefinite (for model improvement) |
| Backups | 90 days |
6. Who we share data with (sub-processors)
Rubo uses carefully selected sub-processors. Transfers outside the UK/EEA are protected by the UK International Data Transfer Addendum to the EU Standard Contractual Clauses (“SCCs”) and/or adequacy regulations.
| Sub-processor | Purpose | Location | Safeguard |
|---|---|---|---|
| Anthropic PBC | LLM inference (Claude Sonnet 4.6) | USA, with UK/EU routing where available | SCCs + UK IDTA |
| Supabase | Database, auth, storage | EU region (Frankfurt) | Intra-EEA; adequacy |
| Stripe Payments UK | Billing and payments | UK + USA | UK adequacy + SCCs |
| Twilio SendGrid | Transactional email | USA | SCCs + UK IDTA |
| Together.ai | Future LoRA fine-tuning (opt-in only) | USA | SCCs + UK IDTA; applies only to donated data |
| Sentry | Error monitoring | EU region | Intra-EEA |
| Cloudflare | DNS, DDoS, WAF | Global edge; UK/EU preference | SCCs + UK IDTA |
We may also share data with professional advisers, auditors, and authorities where required by law. We do not sell personal data.
7. International transfers
Where personal data is transferred outside the UK, we rely on (a) adequacy decisions (EEA, Switzerland, listed countries), (b) the UK International Data Transfer Addendum to the EU SCCs, or (c) another lawful transfer mechanism. You may request a copy of the transfer safeguards by emailing privacy@askrubo.ai.
8. Your rights
Under UK GDPR you have the right to:
- Access the personal data we hold about you.
- Rectify inaccurate or incomplete data.
- Erase data where lawful basis no longer applies (“right to be forgotten”).
- Portability — receive data in a structured, machine-readable format.
- Object to processing based on legitimate interests or direct marketing.
- Restrict processing in certain circumstances.
- Withdraw consent where processing is consent-based (takes effect prospectively).
- Complain to the Information Commissioner’s Office at ico.org.uk.
To exercise any of these, email privacy@askrubo.ai. We aim to respond within 30 days.
Where Rubo is processor (i.e. data is inside a broker workspace), direct your request to the broker firm — we will assist them in responding.
9. Security
We use industry-standard security measures including TLS in transit, AES-256 at rest, Row-Level Security on our database, principle-of-least-privilege access control, hardware 2FA for administrators, and continuous monitoring via Sentry. No system is perfectly secure; see our Breach Response Policy for how we handle incidents.
10. Cookies and trackers
See our Cookie Policy for full detail. We use strictly-necessary cookies without consent and analytics/marketing cookies only with your consent via the banner. You can revoke consent at any time via the cookie preferences link in the footer.
11. Children
Rubo is a B2B service and not directed at children. We do not knowingly collect data from anyone under 18. If you believe we have such data, contact privacy@askrubo.ai.
12. Automated decision-making
Rubo’s outputs are generated by AI models, but they are advisory only and do not produce legal, financial, or other decisions with significant effects on individuals without human review. You, the broker, remain the decision-maker. We therefore do not carry out “solely automated decision-making” within the meaning of Article 22 UK GDPR.
13. Changes to this Privacy Policy
We will notify you of material changes by email or in-app at least 14 days before they take effect. The “Last updated” date at the top of this Policy shows when it was last revised.
Contact
Questions? Email legal@askrubo.ai (or privacy@askrubo.ai for privacy-specific).
You can also complain to the Information Commissioner’s Office at ico.org.uk, or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Draft pending solicitor review. Rubo is a software tool, not a law firm.