1. Data Controller
Prime Directive AI Ltd ("we", "us", "our") is the data controller for personal data collected through The Guinndex website (guinndex.ai). Contact: privacy@guinndex.ai.
Prime Directive AI Ltd is a company registered in England and Wales, company number 16551401. Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.
2. Data We Collect
- Price submissions: Pub name, location, price, and optional Instagram handle.
- Photos: Images uploaded through the Contribute feature, along with optional venue name, price, caption, and Instagram handle.
- Corrections: Pub name, correction message, and optional email address.
- Email signups: Email address for newsletter subscription.
- Technical data: Device type, browser, IP address, and usage analytics via Google Analytics (GA4), only after you accept analytics cookies.
Telephone calls to pubs
The Guinndex collects prices by telephoning licensed premises with an AI voice agent that says it is an AI at the start of every call. Those calls are recorded and transcribed. If you answered one of our calls, or you run a pub and want us never to ring it, the notice that covers you is How and why we telephone pubs.
3. How We Use Your Data
- To display and verify pint price data on the Guinndex.
- To review and publish user-submitted photos on Guinndex social media accounts (only with your explicit consent).
- To process corrections and update pub listings.
- To send newsletter updates (only with your consent).
- To prevent fraudulent or duplicate submissions.
- To understand how the site is used and improve the service.
4. Legal Basis
We process your data based on:
- Consent (Article 6(1)(a) GDPR): For photo sharing on social media, email newsletter, and optional data collection.
- Legitimate interest (Article 6(1)(f)): For fraud prevention, service improvement, and maintaining accurate pub data.
5. Photo Submissions and Rights
By submitting a photo with marketing consent, you grant Prime Directive AI Ltd a non-exclusive, royalty-free, worldwide licence to use, display, and share your photo on Guinndex social media accounts (Instagram, X/Twitter, and similar platforms).
- You will be credited by your Instagram handle if provided, or as "Anonymous".
- You retain ownership of your photo.
- Your photo will only be used on Guinndex social media accounts and the Guinndex website.
- You can withdraw consent at any time by emailing privacy@guinndex.ai, and we will remove your photo.
- You confirm you are the original photographer and have the right to share the image.
- Photos containing identifiable individuals require that you have their permission to share.
6. Data Sharing
We do not sell your personal data. We may share data with:
- Service providers who help us operate the site (Vercel for hosting, Supabase for data storage, Resend for email).
- Service providers who help us make and process calls to pubs: ElevenLabs (voice agent, recording and transcription), Twilio (telephony) and Anthropic (extracting the price from the transcript).
- Law enforcement or regulatory bodies when required by law.
7. Data Retention
Price submissions and corrections are retained indefinitely as part of the public index. Photos for which consent was given are retained until consent is withdrawn. Email addresses are retained until you unsubscribe. Technical/analytics data is retained for 14 months (Google Analytics default). Recordings and transcripts of calls to pubs are kept so that prices can be checked and the agent's conduct audited; they are not published, and a pub can ask for the recording of a call to its premises to be deleted (see How and why we telephone pubs).
8. Your Rights
Under GDPR, you have the right to:
- Access your personal data.
- Rectify inaccurate data.
- Erase your data ("right to be forgotten").
- Restrict or object to processing.
- Withdraw consent at any time (for photo sharing and email).
- Data portability.
- Lodge a complaint with the Data Protection Commission (dataprotection.ie) or the UK Information Commissioner's Office (ico.org.uk).
To exercise any of these rights, email privacy@guinndex.ai.
9. Age Restriction
The Guinndex contains references to alcoholic beverages. By using this site and submitting content, you confirm you are aged 18 or over. We do not knowingly collect data from anyone under 18.
10. Cookies and Analytics
We use Google Analytics (GA4) to understand how the site is used. Analytics cookies are not set until you choose Accept on the cookie banner; if you decline, or make no choice, Google Analytics runs without cookies and stores nothing on your device. No personally identifiable information is shared with Google. You can change your choice by clearing this site's data in your browser, which brings the banner back.
11. Changes to This Policy
We may update this policy from time to time. Any changes will be posted on this page with the updated date.