Legal
Privacy Policy
Last updated: 7 September 2026
This policy explains what personal data Coffee AI Ltd ("Coffee AI", "we", "us") collects, why, and what rights you have over it, when you use coffeeai.co (the "Site") or our products (Scribe, Brew and Extract).
It covers everything, including how we use artificial intelligence and what it learns from. There is no separate AI policy.
Who we are
Coffee AI Ltd, registered in England and Wales, company number 16814265. For any privacy question, or to exercise your rights, email abin@coffeeai.co.
1. The Site
Site analytics. Cookieless, aggregate data: region, device, pages, referrer. No cookies, no cross-site tracking, and we do not identify you. Basis: our legitimate interests in running and improving the Site.
Waitlist. Your name, email, company and industry, so we can keep you updated. Basis: consent and legitimate interests. You can opt out at any time.
Bookings and enquiries. Your name, email and booking details when you contact us or book a call. Basis: taking steps at your request, and our legitimate interests.
Our analytics are cookieless, so we show no cookie banner. Third-party tools you use on the Site, such as our booking widget, may set their own cookies.
2. Our products, and what they record
Our products run on AR glasses worn by engineers at work, and on a connected phone app.
During a job, the glasses and software record:
- audio, including what the engineer says and what is said to them
- photographs and video of the work
- the engineer's spoken notes, and the records our software drafts
- technical information: timings, location, session length, device and diagnostic data
Live Assist. Where an engineer asks for help, our software can open a live audio and video link between the glasses and a person at their employer's office, usually a senior engineer or dispatcher. Live Assist sessions are recorded on the same basis as any other session.
The glasses do not record continuously. Recording starts when a job starts and stops when it ends. The wearer can pause or stop at any time. A light on the frame shows when recording is happening. Nothing is recorded in toilets, changing areas or rest areas, or anywhere the employer has told us not to.
3. Our two roles
This is the important part, so we have set it out plainly.
For delivering the service, we are a processor. The business that employs the engineer is the controller. We process on their instructions, under our agreement with them, to produce their records, their compliance paperwork and their guidance. That material is theirs.
For improving our models, we are a controller in our own right, because we pursue our own purpose. That is described in section 4.
If your employer uses Coffee AI, please contact them first about your data, or contact us and we will help direct your request.
4. Training and improving our models
We use material generated through our products, including recordings, transcripts, spoken notes and the corrections people make while following guidance, to train, fine-tune, evaluate and improve the machine learning models behind Coffee AI. This is how the guidance gets better.
Basis: our legitimate interests in developing and improving our products, together with the agreement signed by the customer organisation, which grants us permission for this use. For this purpose we act as a controller, not a processor.
This purpose is specified before capture begins. It is not a later or secondary use of material collected for something else.
What the models learn belongs to us. Model parameters, weights and general capabilities derived from use of our products are our property, and we may use them for any purpose. They do not identify, and cannot reasonably be used to identify, any customer or any individual.
What stays with the customer. Recordings, records and compliance paperwork belong to the customer that generated them. We do not sell, share or license that material. We do not disclose raw recordings, or anything identifying a business, its staff, its sites, its clients or its commercial arrangements, to any other customer. No output we make available to another customer identifies you.
What improves across our products is the model's general understanding of the work. Not your material.
5. What we never do
- We never use recordings to identify anyone by biometric means, and we never allow a third party to do so.
- We never score, rank, rate or grade individual engineers, and we never produce output used to make decisions about a person's employment, pay, discipline or progression.
- We never use your data for advertising, ad targeting or behavioural profiling.
- We never sell, rent or share personal data with third parties for their own marketing.
- We never make automated decisions producing legal or similarly significant effects about a person without human involvement.
6. Where AI is used, and its limits
Where it is used. Speech recognition turns what an engineer says into text. Vision models read what the camera sees. Models draft the compliance record. Models answer questions asked out loud and decide what guidance to show and when.
A person is in charge. Coffee AI guides. It does not authorise. The engineer on site decides whether to follow any guidance and can ignore, pause or stop it at any time. Where a record is used as evidence of compliance, it is checked and signed off by a person, not by our software.
Safety-critical work. Our products are used on work carrying real risk, including gas, electrical and work at height. Nothing in our products replaces the qualifications, registrations, regulations, manufacturer's instructions or professional judgement that apply to that work. Guidance is support. It is not a substitute for being competent and qualified, and it does not certify that a job has been done correctly or safely. Where guidance conflicts with a regulation, a manufacturer's instruction or an employer's own procedure, those take precedence.
Accuracy. AI systems make mistakes. A model can misread what the camera sees, miss a detail, or answer confidently and be wrong. We test our models before release and monitor them in use, but we do not represent that guidance is complete, accurate or suitable for every situation. If you find guidance that is wrong or unsafe, tell us at abin@coffeeai.co. We treat reports of unsafe guidance as a priority.
7. People who do not work for our customer
Engineers work in occupied buildings and in people’s homes, so other people are sometimes captured incidentally.
We do not use that material to identify anyone. It is subject to the same restrictions and the same retention limits as everything else. Employers can tell us about any site where recording must not happen, and we will disable capture there.
If you believe you have been recorded and you want to know more, or want the material removed, email abin@coffeeai.co and we will deal with it.
8. Telling engineers
Employers are the controller for their own workers' personal data and are responsible for telling them about our products and what is recorded. We provide every customer with a written notice to give to their engineers, and our agreement requires them to issue it before anyone starts using the glasses.
We do not ask engineers to consent individually. Consent given to an employer is rarely a free choice, so we do not rely on it.
9. Sharing and sub-processors
We do not sell your personal data.
We share it only with service providers who help us operate, including cloud hosting and storage, speech recognition, AI model inference, analytics and scheduling. All of them are bound by contracts requiring them to protect it and to process only on our instructions.
A current list of our sub-processors is available on request from abin@coffeeai.co. We give customers at least 30 days' notice before adding or replacing one.
We may also disclose data where the law requires it, or to protect the rights, safety or property of Coffee AI, our users or the public.
10. International transfers
Some providers are outside the UK. Where data is transferred abroad we rely on appropriate safeguards, such as the UK International Data Transfer Agreement, the UK extension to the EU-US Data Privacy Framework, or an adequacy decision.
11. Retention
| What | How long |
|---|---|
| Raw recordings (audio, video, photographs) | No more than 12 months from capture, then deleted or irreversibly converted into non-identifying derived data |
| Compliance records and job records | For as long as the customer requires, and as their industry's rules require |
| Site analytics | Aggregate and non-identifying, kept up to 24 months |
| Waitlist, bookings and enquiries | Until you ask us to stop, or 24 months after our last contact |
| Diagnostic and log data | Up to 12 months |
What deletion does not do. Deleting material does not require us to retrain, reverse or delete models, model weights or parameters that have already learned from it. That is not technically possible, and we say so plainly rather than promise something we cannot do.
12. Security
Data is encrypted in transit and at rest. Access is limited to named personnel who need it, with multi-factor authentication and audit logging. Each customer's data is logically isolated from every other customer's. Our glasses have no removable storage.
13. Your rights
You can ask us to give you a copy of your data, correct it, delete it, restrict or object to our use of it, or send it to someone else, and you can withdraw consent where we rely on it.
Email abin@coffeeai.co. We will respond within one month. If your request is complex we may extend that, and we will tell you if we do.
You can also complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
14. Changes
We may update this policy and will post the new version here with a revised date at the top. Where a change materially affects a customer organisation, we will tell them directly.
Coffee AI Ltd, company number 16814265. abin@coffeeai.co