Date of Completion: 26/7/2023

[XEROTECH LTD] takes your privacy seriously. That is why we will only use your personal information to provide you with the products and services you have requested, as well as to administer your account. We will not sell or share your information with third parties unless you grant us explicit permission to do so, and we will never use your personal data for any reason other than the reasons described within this policy.

About our privacy policy

Our privacy policy outlines your relationship with XEROTECH LTD and explains in detail how we use the information that you provide us with.


[XEROTECH LTD] is the developer and provider of the Android Application “Alena Intelligent Avatar” abbreviated as “AIA”. We are registered in the United Kingdom and are compliant with the UK’s Information Commissioner’s Office under the Data Protection Act 2018. Our Data Protection Officer is [DPO], and we encourage you to get in touch with any questions you may have about XEROTECH LTD.

You can reach us by:

  • Post: 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM • Telephone: None • Email: • Website:

Frequently Asked Questions

  1. Who is using my data? [XEROTECH LTD]
  2. What is my data being used for? [XEROTECH LTD] stores and processes data to help us maintain your account, process, and store transaction details, offer customer support, send system updates, and send offer details.
  3. What will happen to my data? [XEROTECH LTD] may use your data to send you information, updates, and offers we think you’ll be interested in.
  4. What data will be kept and stored? [XEROTECH LTD] stores registration details, transaction details, usage information, and any information about your web preferences on our website.
  5. What data will be shared with others? We only share your data with regulators or government bodies if requested.
  6. How long will my data be kept for? [XEROTECH LTD] will store your data for a period of 3 months initially after your last attempted login. After this period, your account will be deleted. You can request your account to be deleted at any time.
  7. Who will be able to access my data? [XEROTECH LTD] will never sell or share your data with any third-party unless you grant us your explicit permission to do so.
  8. How will my data be kept and made secure? [XEROTECH LTD] stores your data on secure servers that are based in the UK. Data is processed in the UK, and we use standard industry security protocols.


When using the Android Application “Alena Intelligent Avatar” (AIA), you will be asked to grant the following permissions:

  • Mic Permission: This permission is required to enable voice calls and communication with the AI.
  • Video Camera Permission: This permission is required to enable video calls and communication with the AI.
  • Local File Storage: This permission is needed to store certain application data locally on your device.
  • Local User Information Store: This permission allows the application to store user information locally.
  • Local Logins, and Guest Login: These permissions are used to manage user logins and guest access within the application.

Third-Party APIs and Plugins

[XEROTECH LTD] uses the following third-party APIs and plugins in the Android Application “Alena Intelligent Avatar” (AIA). Please note that user prompts and/or credentials may be passed to these third parties wherever appropriate under their own respective privacy policies:

  • Unity Technologies
  • OpenAI
  • Crosstales
  • Crazy Minnow Studio LLC

What information this policy applies to

There is a lawful basis for processing your data, and this section of our privacy policy outlines how this applies to the personal information you provide us with or allow us to collect.

The information this policy applies to includes information that you:

  • Provide as part of any registration process.
  • Provide as part of any campaign creation activity.
  • Provide in the form of numerical data, metadata, or communications.
  • Give us as part of our ongoing relationship.

This policy also applies to information that we:

  • Collect relating to how you interact with our Android Application
  • Must process to complete transactions.


Please note that when you install and use our Android Application “Alena Intelligent Avatar” (AIA), you are giving [XEROTECH LTD] your explicit consent that we can use that data in line with our privacy policy.


After giving [XEROTECH LTD] your consent, you are free to amend your consent or withdraw your consent at any time. You have the right to object to the processing of your data. To opt-out, change your preferences, or revoke your consent, simply contact us by emailing [].

Data processing and storage

[XEROTECH LTD] collects and stores data within the Android Application “Alena Intelligent Avatar” (AIA). We will store your data for a period of 3 months initially after your last recorded login attempt unless otherwise noted and explicitly stated.

[XEROTECH LTD] may process your data based on more than one legal ground.

Circumstances under which we may be required to process your data under more than one legal ground may include: Reason Data type Legal basis Customer registration Identity and contact information To carry out a contract we’ve made with you Processing and/or delivering your order Identity, contact information, financial information, financial and transactional data To carry out a contract we’ve made with you and to exercise our legitimate interests to recover debts owed To manage our customer relationship with you Identity, contact information, marketing and communications preferences To carry out a contract we’ve made with you, to comply with legal obligations, and to exercise our legitimate interests to keep our records updated

Marketing and communications

[XEROTECH LTD] may send you marketing communications if you have given us your contact details and opted-in to marketing communications.

You can opt-out of these marketing communications and manage your preferences at any time.

Our security

As part of our ongoing commitment to data protection, [XEROTECH LTD] will report any security breaches or attempted breaches to the relevant authorities within 24 hours. We will subsequently contact all those affected by the breach within 72 hours of its occurrence.

Third Parties

[XEROTECH LTD] never shares your personal data with third parties unless those parties have been explicitly mentioned within our privacy statement.

Sensitive data

[XEROTECH LTD] does not collect any sensitive data about you. Sensitive data refers to (but is not limited to) information about your race or ethnic background, religious or political affiliations, trade union affiliations, sexual orientation, criminal background, or health background.

Who our privacy policy applies to

This privacy policy has been developed to inform users of [XEROTECH LTD] how we use their data. Our privacy policy applies to all individuals registered with us as a user of the Android Application “Alena Intelligent Avatar” (AIA), customer, administrator, or in any other capacity.

Our company obligations

As a data controller, [XEROTECH LTD] is legally responsible for the data you provide us with. In honouring that responsibility, we pledge to uphold our commitments under GDPR and the Data Protection Act 2018.

We will only ever use your data: • In ways that are both fair and legal • In ways that are necessary for the purposes described within this policy.

In addition, [XEROTECH LTD] processes the personal data you submit to us, or we collect as a data processor. As part of this role, [XEROTECH LTD] takes all necessary precautions to secure the personal data we collect, process, and store.

We may occasionally use the data you provide us with for marketing, relationship management, or account management activities. These activities are designed to ensure you have adequate information about other products and/or services we offer, that we have reason to believe you may be interested in. You have the right to opt-out of these activities at any time.

Changing your preferences

If you’d like to change your contact or marketing preferences, you can do so at any time. Simply contact us at [] to request the necessary amendments.

Contact us

[XEROTECH LTD] is committed to upholding your rights. If you have any questions, comments, or concerns about this privacy policy or wish to exercise your rights in relation to your personal data, please contact our Data Protection Officer (DPO) at

We will process any request within 20 days. Subject Access Requests are normally performed free of charge, but we may need to charge individuals for excessive or unreasonable data requests.