PRIVACY POLICY
Effective Date: 11th September 2026
This Privacy Policy describes how Super Benji Limited (“Super Benji”, “we”, “us”, or “our”) collects, uses, and discloses information when you use our Services, and explains your privacy rights and how the law protects you.
We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
1. Interpretation and Definitions
1.1 Words with capitalised initial letters have meanings defined in this section. These definitions apply whether the terms appear in singular or plural.
1.2 “Account” means a unique account created for you to access our Service.
1.3 “Affiliate” means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares or equity interest.
1.4 “Company” (referred to as “Super Benji”, “we”, “us”, or “our”) refers to Super Benji Limited, 46 Woodstock Rd, Oxford OX2 6HT, registered in England and Wales, company number 15355853.
1.5 “Controller” means the natural or legal person which determines the purposes and means of processing Personal Data, as defined under UK GDPR and EU GDPR.
1.6 “Customer” means a business that has subscribed to the Services under our Terms and Conditions.
1.7 “Customer Data” means data provided by a Customer to Super Benji in the course of using the Services, including any Personal Data contained within it.
1.8 “Device” means any device that can access the Service, such as a computer, mobile phone, or tablet.
1.9 “Personal Data” means any information relating to an identified or identifiable natural person, as defined under UK GDPR and EU GDPR.
1.10 “Prospect Data” means Personal Data relating to third-party individuals sourced by Super Benji from licensed data providers or publicly available sources, and made available to Customers via the Services for outbound sales and marketing purposes.
1.11 “Service” refers to the Super Benji platform, self-service tool, managed outbound messaging service, and website at https://www.superbenji.ai.
1.12 “Service Provider” means any third party that processes data on behalf of Super Benji.
1.13 “Usage Data” means data collected automatically through use of the Service, such as IP addresses, browser type, and page visit duration.
1.14 “You” means the individual or business accessing or using the Service.
2. What Information Do We Collect?
2.1 When registering or using the Service, we may collect: name, email address, and job title; company name and billing address; payment information (processed by Stripe — we do not store full card details); account credentials and preferences; and messages and communications sent to us.
2.2 We automatically collect certain information when you visit or use our Service, including your IP address, browser type and version, pages visited, time and date of visit, and other diagnostic data (“Usage Data”).
2.3 We may receive information about you from third-party sources, such as data enrichment providers, publicly available sources, and LinkedIn, for the purpose of identifying potential customers and improving our Services.
2.4 When operating the Services, Super Benji sources and processes Prospect Data — business contact information such as names, professional email addresses, job titles, and company affiliations — from licensed third-party data providers and publicly available sources. This data is made available to Customers to support outbound sales campaigns. See Clause 4 for more detail on how this data is handled.
3. How Do We Use Your Information?
3.1 We use personal data for the following purposes:
3.1(a) To provide, operate, and maintain the Service.
3.1(b) To manage your account and process payments.
3.1(c) To send service-related communications, including updates and security notices.
3.1(d) To respond to support requests and enquiries.
3.1(e) To send marketing communications where you have consented or where we have a legitimate interest in doing so. You may opt out at any time.
3.1(f) To analyse usage trends and improve the Service.
3.1(g) To comply with legal obligations.
3.1(h) To detect and prevent fraud or misuse of the Service.
4. What Legal Bases Do We Rely On?
4.1 We process personal data only where we have a valid legal basis to do so under UK GDPR and, where applicable, EU GDPR.
4.2 Contract (Article 6(1)(b)): where processing is necessary to perform our contract with you or take steps at your request before entering into a contract.
4.3 Legitimate Interests (Article 6(1)(f)): where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights. Examples include: sending relevant marketing communications, improving the Service, fraud prevention, and sourcing and supplying Prospect Data for B2B outbound sales purposes. We have assessed that the use of business contact data for B2B outbound sales is within the reasonable expectations of professionals in a business context.
4.4 Legal Obligation (Article 6(1)(c)): where processing is required for compliance with a legal obligation.
4.5 Consent (Article 6(1)(a)): where you have given clear consent for a specific purpose. You may withdraw consent at any time without affecting the lawfulness of prior processing.
5. Prospect Data — How We Handle It
5.1 Super Benji sources Prospect Data from licensed third-party providers and publicly available sources (such as LinkedIn and company websites) for the purpose of enabling B2B outbound sales campaigns on behalf of our Customers.
5.2 Super Benji as Controller: when sourcing and supplying Prospect Data to Customers, Super Benji acts as an independent Data Controller. We rely on legitimate interests as our lawful basis, having assessed that the use of professional contact data for B2B sales outreach is unlikely to override the reasonable expectations of the individuals concerned. We use commercially reasonable efforts to ensure data is sourced from reputable providers and obtained lawfully, and we maintain a documented Legitimate Interests Assessment for this activity.
5.3 Customer as Controller: once Prospect Data is made available to a Customer via the platform, the Customer becomes an independent Data Controller in respect of their use of that data. Customers are solely responsible for ensuring their use of Prospect Data — including any outbound communications — complies with all applicable laws, including UK GDPR, EU GDPR, PECR, and equivalent regulations.
5.4 Your rights as a Prospect: if you have received a communication sent via the Super Benji platform and wish to exercise your data subject rights (including the right to access, erasure, or objection), you should contact the business that sent you the communication, as they are the Controller for that use. If you are unable to identify or contact that business, you may contact us at benji@superbenji.ai and we will assist to the extent required by applicable law. To opt out of future communications, please follow the guidance provided in any email you have received, or contact us directly.
5.5 Transparency (UK/EU GDPR Article 14): where we collect Prospect Data indirectly (i.e. not directly from the individual concerned), we rely on our data providers to maintain appropriate transparency notices at the point of collection. We use commercially reasonable efforts to work only with providers who meet this standard.
6. Cookies and Tracking Technologies
6.1 We use cookies and similar tracking technologies to operate and improve the Service.
6.2 Essential cookies are necessary for the Service to function and cannot be disabled.
6.3 We use Google Analytics to understand how visitors use our website. This data is aggregated and used to improve the Service. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. For more information on Google’s privacy practices, see https://policies.google.com/privacy.
6.4 You can control non-essential cookies via your browser settings or by contacting us. Disabling analytics cookies will not affect your ability to use the Service.
7. How We Share Your Information
7.1 We do not sell your personal data.
7.2 Service Providers: we share data with third-party providers who assist in delivering the Service, including payment processing (Stripe), cloud infrastructure, analytics (Google Analytics), email delivery and mailbox integration (Nylas), AI-assisted features (OpenAI), and data enrichment. These providers act as processors on our behalf and are bound by data processing agreements. A list of our current sub-processors is available on request by contacting through our ‘Contact Us’ form on the website.
7.3 Customers: where you are a Prospect whose contact data has been provided to a Customer via our platform, that Customer acts as an independent Controller of your data for their outbound communications.
7.4 Legal requirements: we may disclose personal data where required by law, court order, or regulatory authority.
7.5 Business transfers: in the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity. We will notify affected users before data becomes subject to a different privacy policy.
8. International Data Transfers
8.1 Super Benji is based in the UK. If you access the Service from outside the UK, your data may be transferred to and processed in the UK or other countries.
8.2 Where we transfer personal data originating in the UK or EEA to countries not recognised as providing an adequate level of data protection, we implement appropriate safeguards, including the UK International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses (SCCs) and UK Addendum, as applicable.
8.3 For more information about our international transfer mechanisms, please contact us via the contact us form on our website.
9. How Long Do We Keep Your Information?
9.1 We retain personal data only for as long as necessary for the purposes set out in this policy, unless a longer retention period is required by law.
9.2 Customer account data is retained for the duration of your subscription and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce agreements.
9.3 Prospect Data is retained for as long as necessary to provide the Services and is deleted or anonymised when no longer required.
9.4 Usage Data is generally retained for a shorter period, unless used to improve security or functionality.
9.5 Upon termination of your subscription, you may request deletion of your Customer Data in accordance with our Terms and Conditions.
10. How We Keep Your Information Safe
10.1 We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. These include encryption in transit and at rest, access controls, and regular security reviews.
10.2 No method of transmission over the internet is completely secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security.
11. Your Privacy Rights
11.1 Depending on your location, you may have the following rights in relation to your personal data:
11.1(a) Right of access — to obtain a copy of the personal data we hold about you.
11.1(b) Right to rectification — to correct inaccurate or incomplete data.
11.1(c) Right to erasure — to request deletion of your data in certain circumstances.
11.1(d) Right to restriction — to restrict processing in certain circumstances.
11.1(e) Right to data portability — to receive your data in a structured, machine-readable format.
11.1(f) Right to object — to object to processing based on legitimate interests or for direct marketing.
11.1(g) Right to withdraw consent — where processing is based on consent, to withdraw it at any time.
11.2 To exercise any of these rights, please contact us via the contact us form on our website. We will respond within 30 days. We may ask you to verify your identity before acting on a request.
11.3 UK residents may lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk/make-a-complaint/.
11.4 EEA residents may contact their local supervisory authority.
11.5 If you have EU/EEA customers and process EU personal data, UK GDPR and EU GDPR may require you to appoint a representative in the EEA. Please seek legal advice on whether this applies to Super Benji.
12. Children's Privacy
12.1 Our Service is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors.
12.2 If you believe we have inadvertently collected personal data from a minor, please contact us via the ‘Contact Us’ form on our website and we will delete it promptly.
13. Links to Other Websites
13.1 Our Service may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before providing any personal data.
13. Google User Data and Connected Mailboxes
14.1 Customers may connect a Google (Gmail or Google Workspace) mailbox to the Service so that outreach emails are sent from their own address and replies return to their own inbox. Access is granted by the Customer through Google’s OAuth consent screen and may be revoked at any time in the Service or at .
14.2 Scope of access. We request only two Gmail permissions: (a) gmail.send — used solely to send messages the Customer has configured and approved, from their connected mailbox; and (b) gmail.readonly — used solely to (i) display prospect replies within the Service, including detecting automatic and out-of-office replies and unsubscribe requests so that we stop contacting anyone who opts out, and (ii) detect delivery-failure notifications so that we stop sending to invalid addresses. We do not request permission to modify, label, archive, or delete mail.
14.3 Limited Use. Super Benji’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy (), including the Limited Use requirements. The use of raw or derived user data received from Workspace APIs will likewise adhere to the Google User Data Policy, including the Limited Use requirements.
14.4 In particular, we do not use Google user data for advertising; we do not sell Google user data; and we do not permit humans to read this data unless we have the Customer’s affirmative agreement, it is necessary for security purposes (such as investigating abuse), it is required to comply with applicable law, or the data has been aggregated and anonymised for internal operations.
14.5 Artificial intelligence. Certain features — reply classification, suggested responses, reply briefings, and delivery-failure parsing — process Gmail message content using OpenAI’s API platform, acting as our Service Provider. Google user data is not used by Super Benji or by any third party to create, train, or improve machine-learning or artificial-intelligence models. Data submitted to OpenAI through its API is not used by OpenAI for model training.
14.6 Sharing. Google user data is shared only with: Nylas, our email API provider (EU-region infrastructure), which brokers the connection to Google’s APIs on our behalf; and OpenAI, as described in clause 14.5. Both act as Service Providers under contractual terms. Google user data is never shared with data enrichment providers, advertisers, or any other third party.
14.7 Retention and deletion. Google user data is retained in accordance with Section 9. Customers may disconnect their mailbox at any time, which revokes our access to the Google account, and may request deletion of associated data as described in Sections 9 and 11.
15. Changes to This Privacy Policy
14.1 We may update this Privacy Policy from time to time to reflect changes to law, our Services, or business practices.
14.2 Material changes will be notified to you by email or by a prominent notice on our website prior to the change taking effect.
14.3 The “Last updated” date at the top of this policy will always reflect the most recent version. Continued use of the Service after the effective date of any changes constitutes acceptance of the updated policy.
16. General
15.1 This Privacy Policy is governed by the laws of England and Wales.
15.2 If any provision of this Privacy Policy is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect.
15.3 Notices and requests relating to this Privacy Policy may be submitted by email or post to the contact details below.
Contact Details
For any questions about this Privacy Policy or to exercise your data rights:
Super Benji Limited
46 Woodstock Rd, Oxford OX2 6HT
Email: benji@superbenji.ai
Website: https://www.superbenji.ai