Legal
Privacy Policy.
Prompt Club is part of Potentially. This Privacy Policy is Potentially’s, and it covers Prompt Club, including our events, sign-ups and partner enquiries. Questions: privacy@potentially.com
Part 1: The essentials
1. Who we are
Potentially is the trading name of the Potentially group (the Potentially Group). The Potentially Group is made up of:
- Potentially AI plc, a public company registered in England and Wales (company number 02882601) with its registered office at 16 Great Queen Street, London, WC2B 5DG. Its shares are admitted to trading on AIM, a market operated by the London Stock Exchange (ticker: AGI);
- Potentially Studios Limited, a company registered in England and Wales (company number 16916925) with its registered office at 159 High Street, Barnet, London, EN5 5SU. This is our operating company and it runs the Potentially platform; and
- Potentially Limited, a company registered in Cyprus (registration number HE 478892). It holds the group's intellectual property.
Where this policy says “we”, “us” or “Potentially”, it means each member of the Potentially Group. Each member processes your personal data as an independent controller on the terms of this policy.
2. This policy at a glance
The full detail is below, but these are the commitments that matter most:
- You can use Potentially without giving your name or email. An account is created automatically the first time you open the app. You do not need to give us your name or email address unless you buy credits or subscribe.
- We do not train AI models on your conversations, and we do not allow the model providers we work with to do so through our platform.
- We do not sell your personal data. We never have and we never will.
- We operate limited data retention. We keep personal data only for as long as we need it, and Part 2 tells you exactly how long for each type of data.
- Your prompts go only where you send them. When you choose a model, your input is passed to that model's provider to generate the response you asked for, and for no other purpose.
3. How this policy works
This is a layered policy. Part 1 covers the essentials that apply to everyone. Part 2 is organised by who you are, so you can go straight to the section that describes your relationship with us. Part 3 covers the things that apply to everyone: sharing, international transfers, retention, security and your rights.
Find yourself in Part 2:
- You use the Potentially app or platform: section 5
- You have signed up for updates or been in touch about our products: section 6
- You have contacted our support team: section 7
- You visit our websites or apps: section 8
- You hold an API or business account: section 9
- You are a shareholder or investor: section 10
- You are a business contact at a customer, supplier or adviser: section 11
- You have applied for a job with us: section 12
If you work for us as an employee, worker or consultant, a separate privacy policy applies. You can request a copy from privacy@potentially.com.
4. How to contact us
For any question about this policy or your personal data, or to exercise any of your rights, contact us at:
- Email: privacy@potentially.com
- Post: Privacy, Potentially AI plc, 16 Great Queen Street, London, WC2B 5DG
Day-to-day responsibility for data protection sits with our Chief Financial Officer.
Part 2: Your section
5. Users of the platform
This section applies if you use the Potentially app or platform, whether unregistered, with a registered account, or as a paying subscriber.
What we collect
All users: a pseudonymous device or account identifier created automatically on first use; an optional display name; your IP address; device and client details (operating system, app version, device type, browser, language); approximate location inferred from your IP address (country or region); usage data (models selected, timestamps, credit and usage counters); and cookie, local storage and mobile identifiers.
Registered and paying users, in addition: your email address; your name and billing name; payment data (card details are collected and stored by Paddle, our merchant of record; we hold only tokens and limited billing metadata such as card brand, expiry and billing country or postcode, never your full card number); subscription status and entitlements, managed across web, iOS and Android through RevenueCat; plan and credit balance; transaction history including purchases, invoices and refunds; account settings; and your communications with us.
Content data: the prompts, files, images, audio, video and other inputs you submit to AI models, and the outputs generated. Inputs are free-form, so they may contain personal data about you or others, including sensitive information, if you choose to include it. We do not seek this information and we ask you not to submit sensitive personal data about yourself or about others without their permission. Please see our Terms and Conditions.
Where it comes from
Almost all of it comes directly from you or your device. Paddle, RevenueCat, and the Apple and Google app stores where you purchase through them, return billing status, tokenised payment metadata, entitlement and subscription events to us.
How we use it and why we are allowed to
- To provide the service: creating and managing your account, routing your prompts to the model you select and returning the output, maintaining your session, metering credits and usage, processing payments and subscriptions, and issuing invoices and receipts. Lawful basis: performance of our contract with you and our legitimate interests in providing our service to you.
- To keep the platform safe: security, fraud prevention, abuse detection, content-safety controls and enforcement of our acceptable use terms. Lawful basis: our legitimate interests in operating a safe and lawful service.
- To improve the product: analytics, debugging, capacity planning and understanding how features are used, using aggregated or pseudonymised data wherever possible. Lawful basis: our legitimate interests in understanding and improving the service.
- To keep records we must keep: transaction and tax records. Lawful basis: legal obligation.
- To send you marketing, only if you opt in. Lawful basis: consent, where we request it and which you can withdraw at any time, or our legitimate interests in marketing our service to you.
How long we keep it
Your chat history is stored locally on your device, which means we cannot recover chats you delete. Account and content data held on our systems is kept while your account is active and deleted within 7 days of closure or prolonged inactivity. Transaction and tax records are kept for six years as required by law. Logs are kept for 30 days and then deleted or aggregated on an anonymous basis.
6. Prospective customers and marketing contacts
This section applies if you have signed up for updates, joined a waiting list, attended one of our events or otherwise been in touch about our products without transacting with us.
What we collect
Your name, email address, how you came to us, your marketing preferences and how you engage with our communications (for example, whether an email was opened).
How we use it and why we are allowed to
We use this data to send you the updates you asked for and to understand interest in our products. Lawful basis: either your consent for direct marketing, given by an unticked opt-in box or a separate subscribe action, or our legitimate interests in developing our business. Every marketing email includes an unsubscribe link, and you can opt out at any time by contacting privacy@potentially.com. If you unsubscribe, we keep a minimal suppression record so we can honour your choice.
How long we keep it
Until you withdraw consent or unsubscribe, after which we retain only the suppression record.
7. Customer support contacts
This section applies if you raise a support conversation with us, whether or not you hold an account.
What we collect
Your name and email address, the content of your conversation with us, any attachments you provide, and any account identifiers needed to resolve your issue.
How we use it and why we are allowed to
To respond to and resolve your request and to maintain a record of the conversation. Lawful basis: performance of our contract with you where you are a user, and our legitimate interests in providing effective support. Support conversations are handled through our own self-hosted support system, so your messages stay on our infrastructure.
How long we keep it
Support conversations, including your contact details, any attachments and account identifiers, are kept for one month and then anonymised. We use the anonymised records to improve future support.
8. Website and app visitors
This section applies if you visit potentially.com, potentially.ai, help.potentially.com or our apps, whether or not you hold an account.
What we collect
Your IP address, device and browser information, analytics events (such as pages viewed and features used) and cookie identifiers.
How we use it and why we are allowed to
To operate and secure our websites and apps and to understand how they are used. Lawful basis: our legitimate interests for essential operation and security, and your consent for non-essential cookies and analytics, which we request through a consent banner on the web and the relevant consent prompt on mobile before any non-essential identifiers are set. You can change your cookie choices at any time through the preference controls. Section 18 explains our use of cookies in more detail.
How long we keep it
Logs and telemetry are kept for 30 days and then deleted or aggregated on an anonymous basis.
Investor tools on our corporate website
The corporate website at potentially.ai includes investor tools and market data provided by Luminate Works. These tools set only the cookies needed to make them work, listed in our Cookie Policy, and process limited technical data such as your IP address and session identifiers to deliver the service.
9. API and business customers
This section applies to the account holders and the billing and technical contacts of organisations that use our API or business services.
What we collect
Your organisation's name, the account holder's name and email address, API keys, billing details (handled by Paddle, our merchant of record), usage and billing records and technical contact details.
How we use it and why we are allowed to
To set up and manage your organisation's account, deliver the service, process payments and provide technical support. Lawful basis: our legitimate interests in providing our service to your organisation and managing the relationship.
Your organisation's own users
Where your organisation sends its own users' personal data through our platform, your organisation is the controller of that data and we act as its processor under the data processing terms in our business agreement. Those users should look to your organisation's privacy policy in the first instance.
How long we keep it
For the life of the account, plus six years for transaction and tax records.
10. Shareholders and investors
This section applies if you hold shares in Potentially AI plc or have invested in the group, including through the recent fundraise.
What we collect
Your name, address, shareholding details, where relevant bank or dividend mandate details and, where verification checks are required, identity documents.
Where it comes from
From you, and from our registrar (Computershare), our broker (Fortified Securities) and settlement systems in connection with admission, fundraising and ongoing trading. Where we receive your data through these intermediaries rather than from you directly, this policy is how we tell you about it.
How we use it and why we are allowed to
To maintain the register of members, communicate with you as a shareholder, administer dividends and corporate actions, and meet our disclosure and record-keeping duties as an AIM-quoted company. Lawful basis: compliance with a legal obligation (including the Companies Act 2006 and the AIM Rules for Companies) and our legitimate interests.
Who we share it with
Computershare maintains our share register. London Co-Sec maintains our statutory registers and filings. We also share shareholder data with our professional advisers and with regulators, Companies House and the London Stock Exchange where required. Some shareholder information, such as the register of members, is public by law.
How long we keep it
For as long as you hold shares and afterwards for the periods required by company law.
11. Business contacts
This section applies to individuals at our customers, prospective customers, suppliers, service providers and professional advisers.
What we collect
Your name, business email address, phone number, role and the correspondence between us.
How we use it and why we are allowed to
To manage the relationship between our organisations, perform contracts, develop our business and pay or get paid. Lawful basis: our legitimate interests in running our business, and legal obligation for financial records.
How long we keep it
For the life of the relationship, plus six years for financial and contractual records.
12. Job applicants
This section applies if you apply for a role with us.
What we collect
Your name, contact details, CV and application information, interview notes and, where relevant, references. Applications are received at studio@potentially.com and managed there or in Employment Hero or, where used, LinkedIn. For a small number of critical roles involving privileged system access, we carry out background checks, which may include a criminal record check. We will tell you before any check is made and ask for your consent.
How we use it and why we are allowed to
To assess your application and, if successful, to prepare your contract. Lawful basis: steps taken at your request before entering into a contract, our legitimate interests in recruiting well, and legal obligation for right-to-work checks. For criminal record checks, we rely on your consent and the conditions set out in the Data Protection Act 2018.
How long we keep it
If your application is unsuccessful, we keep your data for six months after the process ends, then delete it, unless you agree we can keep it on file for future roles. If you join us, your application data becomes part of your employment record and our employee privacy policy applies.
Part 3: What applies to everyone
13. Who we share personal data with
We share personal data only where this policy describes, and we require everyone who processes data for us to protect it under contract. We never sell it.
AI model providers
Potentially gives you access to over 1,000 AI models from providers around the world. When you submit a prompt, the content needed to generate your output is transmitted to the provider of the model you selected, and to no other provider. We assess and contract with each provider before making its models available, and we prioritise providers that offer limited data retention. Open models hosted on our own infrastructure involve no third-party disclosure at all. Where a provider processes your content as an independent controller, its own privacy policy also applies.
Service providers
- Cloudflare: hosting, infrastructure, storage and security for the platform;
- Paddle: our merchant of record for web purchases. Paddle is the authorised seller for those transactions and acts as an independent controller for its own billing, tax, fraud prevention and regulatory compliance;
- RevenueCat: subscription and entitlement management across web, iOS and Android;
- Apple and Google: in-app purchases through their app stores;
- PostHog: product analytics and error tracking;
- Google Workspace: email, document storage and collaboration;
- Luminate Works: investor tools and market data on our corporate website;
- Computershare (share registrar) and London Co-Sec (company secretarial), for shareholder and statutory data; and
- our banks, insurers and payroll, pension, HR and accounting providers, for the corporate data described in the relevant sections.
Professional advisers, regulators and the law
We share personal data with our professional advisers (including our nominated adviser, broker, lawyers, auditors and reporting accountants) where needed for their work, and with HMRC, Companies House, the London Stock Exchange, the Financial Conduct Authority, the Information Commissioner's Office and other authorities where the law requires. We may also disclose personal data to comply with legal process, to enforce our terms, or to protect the rights, property or safety of Potentially, our users or the public.
Business transfers
If the group is involved in a merger, acquisition, reorganisation or sale of assets, personal data may transfer as part of that transaction. We will notify you of any change of controller and any choices you have.
Sharing within the Potentially Group
We share your personal data amongst the entities in the Potentially Group to the extent necessary for the purposes described in this policy.
14. International transfers
We are a UK group and we prefer providers that offer UK or European processing. Some of our providers, including Cloudflare, RevenueCat, PostHog and many AI model providers, operate globally, including in the United States. Paddle, our merchant of record, is a UK company. Where personal data leaves the UK, we protect it using one or more of the following safeguards:
- UK adequacy regulations, for countries the UK government has assessed as providing adequate protection, including the EEA;
- the UK Extension to the EU-US Data Privacy Framework, for certified US providers; and
- the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, built into our contracts with providers, supported by transfer risk assessments where required.
We also apply encryption in transit and at rest, strict access controls and a preference for providers offering limited data retention and regional processing. You can request more information about the safeguards applying to a specific transfer at privacy@potentially.com.
15. How long we keep personal data
We keep personal data only for as long as we need it for the purposes described in this policy, and each section of Part 2 states the periods that apply to you. Before deleting anything, we check for legal holds, ongoing disputes and fraud-prevention needs.
16. How we protect personal data
We apply technical and organisational measures appropriate to the risk, including encryption in transit and at rest, single sign-on and multi-factor authentication, least-privilege access controls, audit logging, web application firewall and DDoS protection through our infrastructure provider, and delegation of card data security to Paddle, our PCI-DSS compliant merchant of record. Access to personal data is limited to people who need it for their role. Independent penetration testing and security reviews form part of our release programme. If a breach occurs that is likely to result in a high risk to your rights, we will notify you and the ICO without undue delay, in line with our legal obligations.
17. Your rights
You have the following rights over your personal data. None of them costs anything to exercise, and we respond within one month (extendable by two months for complex requests, in which case we will tell you).
- Access: ask for a copy of the personal data we hold about you;
- Rectification: ask us to correct inaccurate or incomplete data. You can also edit your profile and email address directly in your account settings;
- Erasure: ask us to delete your data. You can delete your account at any time in the app or via the website;
- Restriction: ask us to pause processing while a concern is resolved;
- Portability: receive the data you have given us in a structured, commonly used, machine-readable format;
- Objection: object to processing based on our legitimate interests, and to direct marketing at any time; and
- Withdrawal of consent: withdraw any consent you have given, at any time, without affecting processing already carried out.
To exercise any right, email privacy@potentially.com or contact us through the app. We may need to verify your identity first. If you use Potentially without registering, we can act on data linked to your device identifier, but we may not be able to link it to you without more information. Some rights have legal exceptions; for example, we cannot delete records we are required to keep for tax purposes.
18. Cookies and similar technologies
We use cookies and similar technologies to run the platform, keep it secure and understand how it is used. Essential cookies are always on because the service does not work without them. Non-essential cookies, including analytics, are set only with your consent, which we ask for through a banner on the web and the relevant prompt on mobile. You can change your choices at any time through the cookie preference controls or your device settings. Our Cookie Policy, linked in the footer of every page, sets out each cookie we use, what it does and how long it lasts, and how to manage your choices.
19. Automated decision-making
We use automated processing for fraud and abuse detection, usage metering, rate limiting and content-safety filtering. Model inference itself is automated, but it runs at your request on your own input. Where an automated decision significantly affects you, for example an account suspension for suspected abuse, you can contact our support team at help.potentially.com to understand the reason, make representations, ask for human review and contest the decision.
20. Children
Potentially is not directed at children, and our terms require users to be at least 13 years old. We do not knowingly process the personal data of anyone under 13, and if we identify such data we delete it. If you believe a child under 13 has used the platform, contact us at privacy@potentially.com.
21. Changes to this policy
We update this policy when our practices, technology or legal obligations change. The date at the top tells you when it was last revised. For material changes, we will notify you in the app or by email if we hold your address, and give you time to review before the changes take effect.
22. Right to complain
If you are unhappy with how we have handled your personal data, you have the right to complain to us by contacting privacy@potentially.com, and we will do our best to put it right. You also have the right to complain to the UK Information Commissioner's Office at ico.org.uk, by phone on 0303 123 1113, or by post to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.