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// Legal
Last updated: 12 June 2026
Draft / Template
This document is a template/draft. It must be reviewed and approved by a qualified solicitor, and all bracketed placeholders completed, before it goes live.
Essenzi Media Ltd ("we", "us", "our") operates the House of Essenzi Creative Engine (the "Service"), available at houseofessenzi.com. We are a company registered in England and Wales under company number 16144272, with our registered office at Capital Tower Business Centre, 3rd Floor, Capital Tower, Greyfriars Road, Cardiff, CF10 3AG, United Kingdom. We are registered with the UK Information Commissioner's Office under registration number ZC006888. We are the data controller for the personal information described in this policy when you use the Service as an individual or account holder. (Where we process personal data on behalf of a business customer, we act as a processor, governed by our Data Processing Agreement.) Our general contact address is studio@houseofessenzi.com; for privacy, data-protection and data-subject requests, contact our privacy contact / Data Protection Officer at studio@houseofessenzi.com.
We collect and process the following categories of personal data:
We do not intentionally collect special category data (e.g. data revealing racial or ethnic origin, health, religious beliefs, or biometric data) and ask that you do not submit it through the Service.
We process your personal data for the following purposes and on the following legal bases:
Where we rely on legitimate interests, you have the right to object (see Section 8). Where we rely on consent, you may withdraw it at any time.
The DNA Extractor lets you submit an Instagram handle or website URL for creative analysis. When you use it: (a) our system, via Apify, temporarily fetches publicly available content from the source you provide; (b) that raw content is processed transiently to generate a structured creative brief and is not stored in our database; (c) only the resulting creative brief (your output) is stored and associated with your account; and (d) we do not build profiles of third-party brands from scraped data, nor retain or redistribute raw scraped content. You are responsible for ensuring your use of this feature complies with applicable law and the terms of service of any platform whose content you submit. See our Acceptable Use Policy.
When you use AI-powered features, the text you submit (including campaign briefs and DNA-extraction inputs) is sent to Anthropic's Claude API for processing. Anthropic therefore receives and processes that content. We do not send identifiers such as your name or email to Anthropic beyond what is inherent in the content you choose to submit. You should not submit other people's confidential information, personal data, or trade secrets into the Service.Anthropic operates under its own privacy and usage policies (anthropic.com); under Anthropic's commercial API terms, inputs and outputs are generally not used to train its models. This reflects Anthropic's stated position and may change; you should review Anthropic's current terms. We do not use your content to train third-party AI models beyond what is necessary to provide the Service to you.
We share personal data with the following sub-processors, each acting under contract and appropriate data-protection terms. A current list is maintained in our Data Processing Agreement.
Several of our sub-processors are based outside the UK and EEA, including in the United States (for example Anthropic, Stripe, Cloudflare and Google). Where personal data is transferred internationally, we rely on appropriate safeguards under UK and EU GDPR, including the European Commission's Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the SCCs, and — where applicable — transfers to countries recognised as providing an adequate level of protection (such as those covered by an adequacy decision or the UK extension to the EU–US Data Privacy Framework). You may request details of the relevant safeguard for any transfer.
Subject to applicable law, you have the right to:
To exercise any of these rights, contact studio@houseofessenzi.com (or studio@houseofessenzi.com). We will respond within the timeframes required by law (generally one month under the GDPR). You also have the right to lodge a complaint with a supervisory authority — in the UK, the Information Commissioner's Office (ICO, ico.org.uk); in the EU, your local Data Protection Authority. We would appreciate the chance to address your concerns first.
If you are a California resident, you have the right to: know what personal information we collect, use and disclose; access and obtain a copy of it; request correction; request deletion; and not be discriminated against for exercising these rights.
Do Not Sell or Share My Personal Information. We do not sell your personal information, and we do not "share" it for cross-context behavioural advertising as those terms are defined under the CCPA/CPRA. Accordingly, no "Do Not Sell or Share" opt-out is required, though you may still contact us with any request. To exercise your California rights, contact studio@houseofessenzi.com; you may use an authorised agent, and we will verify your request as required by law.
We retain personal data only as long as necessary for the purposes set out above:
[Retention periods to be confirmed against the company's actual data-lifecycle configuration before publication.]
We use a single essential session cookie (essenzi_session) and may use privacy-friendly analytics and operational tools. Full details, including the lawful basis for each (essential vs. consent under PECR / the ePrivacy rules), are set out in our Cookie Policy.
The Service is not directed to children. It is intended for users aged 18 or over, and in any event we do not knowingly collect personal data from anyone under 16 in the EEA / under 18 in the UK. If you believe a child has provided us personal data, please contact studio@houseofessenzi.com and we will delete it.
We implement appropriate technical and organisational measures to protect your data, including HTTPS/TLS in transit, one-way bcrypt password hashing, encryption of 2FA secrets, HttpOnly session cookies, server-side management of API secrets, access controls, and use of reputable infrastructure providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
In the event of a personal data breach, we will assess and, where required by the UK/EU GDPR, notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of it. Where a breach is likely to result in a high risk to your rights and freedoms, we will notify affected individuals without undue delay.
We may update this policy from time to time. The "Last updated" date at the top reflects the latest revision, and we will take reasonable steps to notify you of material changes. Continued use of the Service after changes constitutes acceptance of the updated policy.
For privacy enquiries or to exercise your rights, contact our privacy contact / DPO at studio@houseofessenzi.com, or write to Essenzi Media Ltd, Capital Tower Business Centre, 3rd Floor, Capital Tower, Greyfriars Road, Cardiff, CF10 3AG, United Kingdom. General enquiries: studio@houseofessenzi.com.