1. Data Controller
Prime Directive AI Ltd ("we", "us", "our") is the data controller for personal data collected through The Guinndex UK website (guinndex.co.uk). Contact: privacy@guinndex.co.uk.
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. The supervisory authority for data protection complaints is the UK Information Commissioner's Office (ico.org.uk).
2. When We Telephone a Pub
Our AI voice agent telephones licensed premises at their publicly listed business number to ask the price of a pint. It says it is an AI at the start of every call. Calls are recorded and transcribed so the price can be checked and the agent's conduct audited; we do not publish them. How this works, our lawful basis, and how to ask us never to call your pub are set out on How and why we telephone pubs.
3. Data We Collect
From users:
- Price submissions: Pub name, location, price, drink brand, contributor name, and optional Instagram handle.
- Tap reports: What's on tap at a pub, including brand names and prices.
- Photos: Images uploaded through the Contribute feature.
- Corrections: Pub name, correction message, and optional email address.
- Email signups: Email address for newsletter subscription.
- Technical data: Device type, browser, IP address, approximate location (from Vercel headers), and usage analytics via Google Analytics (GA4).
- Press links: If you arrive via a link we sent you, we record that it was opened, the page, and your IP address, kept for 90 days.
From public data sources:
- Google Places API: Pub names, addresses, ratings, reviews, phone numbers, opening hours, photos. This is publicly available data from Google.
- Food Standards Agency (FSA): Food hygiene ratings for UK premises. Published under Open Government Licence.
- Office for National Statistics (ONS): Historical alcohol prices. Published under Open Government Licence.
4. How We Use Your Data
- To display and verify pint price data on The Guinndex UK.
- To maintain and display tap lists (what's on draft at each pub).
- To review and publish user-submitted photos (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.
- To generate aggregate statistics (e.g. average pint price by region). No personal data is included in aggregate statistics.
5. Legal Basis (UK GDPR)
We process your data based on:
- Consent (Article 6(1)(a)): For photo sharing, email newsletter, and optional marketing communications.
- Legitimate interest (Article 6(1)(f)): For fraud prevention, service improvement, and maintaining accurate pub data. Our legitimate interest is providing a useful public price index.
- Public task (Article 6(1)(e)): For displaying publicly available data (Google ratings, FSA hygiene ratings, ONS statistics).
6. Third-Party Data and Attribution
- Google: Pub ratings and review counts are sourced from Google. "Ratings from Google" attribution is displayed.
- Food Standards Agency: Hygiene ratings are Crown copyright, published under the Open Government Licence v3.0. We link to the official FSA record for each rated pub.
- ONS: Historical alcohol price data is Crown copyright, published under the Open Government Licence v3.0.
7. Data Sharing
We do not sell your personal data. We may share data with:
- Service providers who help us operate the site: Vercel (hosting), Supabase (data storage), Resend (email), ElevenLabs (AI voice agent, call recording and transcription), Twilio (telephony), Anthropic (price extraction from call transcripts and AI processing).
- Law enforcement or regulatory bodies when required by law.
Aggregate, non-personal pricing data may be shared with industry bodies and commercial partners. This never includes personal information about individual contributors.
8. Data Retention
- Price submissions and tap reports are retained indefinitely as part of the public index.
- Call recordings and transcripts from our telephone calls to pubs are retained so that prices can be checked and the agent's conduct audited. They are not published. You can ask us to delete the recording of a call to your premises.
- Photos are retained until consent is withdrawn.
- Email addresses are retained until you unsubscribe.
- Technical/analytics data is retained for 14 months (Google Analytics default).
- Real-time visitor session data is deleted after 2 minutes of inactivity.
9. Your Rights
Under UK 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.
- Data portability.
- Lodge a complaint with the Information Commissioner's Office (ico.org.uk).
To exercise any of these rights, email privacy@guinndex.co.uk.
10. International Transfers
Your data is stored on servers in the EU (Supabase, EU West) and may be processed by service providers in the United States (Vercel, Google Analytics, Anthropic). Where data is transferred outside the UK, we rely on Standard Contractual Clauses or equivalent safeguards as required by UK GDPR.
11. Age Restriction
The Guinndex UK 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.
12. Cookies and Analytics
We use Google Analytics (GA4) to understand how the site is used. This involves cookies and similar technologies. No personally identifiable information is shared with Google. We also use a lightweight session tracker for real-time visitor counts (no personal data stored beyond session ID and approximate location).
You can opt out of analytics tracking using the cookie banner or by disabling cookies in your browser settings.
13. 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.