Privacy Policy — Spectrum Alpha

1. Who We Are

Spectrum Alpha Ltd is a private limited company registered in England and Wales (Company Number: 16947569). Our registered address is St John's Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom.

We operate Alfie — an AI thinking partner for neurodiverse teenagers aged 13 to 18 and their parents and caregivers — delivered via WhatsApp. References to "SA", "we", "us", or "our" in this policy refer to Spectrum Alpha Ltd.

For privacy queries, contact us at support@spectrumalpha.org.

2. Important Notice — AI Disclosure

      Alfie is an AI thinking partner, not a human. When you or your teenager interacts with Alfie via WhatsApp, you are communicating with an artificial intelligence system built on Anthropic's Claude API. Alfie will always confirm its AI nature if asked directly.
    

3. Who This Policy Covers

This policy applies to:

Parents and caregivers who register for and use Alfie for Parents
Teenagers aged 13 to 18 who use Alfie for Teens, with the consent of their parent or legal guardian
Visitors to spectrumalpha.org

We do not knowingly collect personal data from children under 13. If we become aware that personal data has been submitted by a child under 13 without parental consent, we will delete it promptly.

4. Data We Collect

When you register for the Spectrum Alpha beta programme, we collect:

Your full name
Your email address
Your WhatsApp number (including country code)
Your country of residence
Which Alfie gateways you are registering for (Parent, Teen, or both)
How you heard about Spectrum Alpha
Any additional information you choose to share in the optional notes field

When you or your teenager uses Alfie via WhatsApp, we may also collect:

The content of conversations with Alfie, to enable memory and personalised support
Engagement metadata — including when conversations take place and general topics discussed
Feedback submitted during conversations

5. How We Use Your Data

We use your data to:

Verify your registration and send your WhatsApp beta invitation
Deliver Alfie's AI support via WhatsApp
Enable Alfie's memory feature, which allows Alfie to recall prior conversations and provide more relevant support over time
Monitor for safeguarding concerns and escalate to the appropriate support where necessary
Improve Alfie's responses and the overall product during the beta period
Communicate with you about your registration, the beta programme, and any changes to the service

We do not use your data for advertising. We do not sell your data to third parties. We do not share your data with third parties except as described in Section 7 below.

6. Legal Basis for Processing

We process your personal data on the following legal bases:

Consent — you provide explicit consent when submitting the registration form and agreeing to this Privacy Policy
Legitimate interests — to operate and improve the Alfie service during the beta period
Legal obligation — where we are required to process data to comply with applicable law, including child safeguarding obligations

For teenage users, we process data on the basis of parental or guardian consent, which is confirmed at the point of registration.

7. Third Parties and Data Processors

We use the following third-party services to operate Alfie:

Anthropic — provides the Claude AI model that powers Alfie's responses. Conversation data is processed via Anthropic's API in accordance with their privacy policy and commercial terms.
Meta (WhatsApp Business Platform) — delivers Alfie's messages via WhatsApp. Message data is processed by Meta in accordance with their WhatsApp Business Terms of Service.
Airtable — stores registration data and engagement metadata securely.
n8n — our workflow automation platform, used to route messages between WhatsApp and Alfie.
Cloudflare — hosts spectrumalpha.org and provides security services.

All third-party processors are required to handle your data in accordance with applicable data protection law. We do not authorise any processor to use your data for their own purposes.

8. Children's Data — Special Provisions

      We take the privacy and safety of teenage users seriously. The following provisions apply specifically to data relating to users under 18.
    

Alfie for Teens is designed for users aged 13 to 18. We require explicit parental or guardian consent before a teenager can access Alfie for Teens. This consent is confirmed at registration.

We apply the following additional safeguards to teenage users' data:

Conversation content involving teenagers is used only to deliver and improve Alfie's support — never for advertising or profiling
Safeguarding triggers within Alfie are designed to detect signs of distress and direct teenagers to appropriate crisis resources immediately
Safeguarding escalation events are logged and reviewed by the SA team
Teenage users can end their use of Alfie at any time by messaging STOP, and their data can be deleted on request

9. Regulatory Compliance by Country

The Spectrum Alpha beta is available in 10 countries. We comply with the applicable data protection regulations in each of those countries as follows:

Country	Applicable Regulation	Our Commitment
United Kingdom	UK GDPR, Data Protection Act 2018, UK Children's Code (Age Appropriate Design Code)	We apply the UK Children's Code standards to all services likely to be accessed by under-18s, including data minimisation, age-appropriate privacy notices, and no profiling of children.
Ireland	GDPR (EU) 2016/679, Data Protection Acts 1988–2018	We process EU residents' data in accordance with GDPR, including lawful basis, data subject rights, and appropriate technical safeguards.
Germany	GDPR (EU) 2016/679, Bundesdatenschutzgesetz (BDSG)	As above for GDPR. We apply BDSG requirements where applicable.
Netherlands	GDPR (EU) 2016/679, Uitvoeringswet AVG (UAVG)	As above for GDPR. We apply UAVG requirements where applicable.
Sweden	GDPR (EU) 2016/679, Dataskyddslagen (2018:218)	As above for GDPR. We apply Swedish data protection law where applicable.
Denmark	GDPR (EU) 2016/679, Databeskyttelsesloven	As above for GDPR. We apply Danish data protection law where applicable.
United States	COPPA (Children's Online Privacy Protection Act) — note: Alfie for Teens serves 13–18 year olds only, above COPPA's 13-year threshold. State privacy laws including CCPA (California) where applicable.	We do not knowingly collect data from children under 13. We do not sell personal data. California residents have rights under CCPA including the right to know, delete, and opt out.
Canada	PIPEDA (Personal Information Protection and Electronic Documents Act), provincial privacy laws where applicable	We collect only what is necessary, obtain consent, and provide access to personal information on request.
Australia	Privacy Act 1988 (Cth), Australian Privacy Principles (APPs)	We comply with the 13 Australian Privacy Principles, including transparency, data quality, and security obligations.
New Zealand	Privacy Act 2020	We comply with the New Zealand Privacy Principles, including notification of collection, data security, and individual access rights.

10. Data Retention

We retain your registration data for the duration of the beta programme and for up to 12 months afterwards, unless you request earlier deletion.

Conversation data is retained to enable Alfie's memory feature. You can request deletion of your conversation history at any time by emailing support@spectrumalpha.org.

Where data is no longer needed for its original purpose, we delete or anonymise it securely.

11. Your Rights

Depending on your country of residence, you have the following rights regarding your personal data:

Right to access — request a copy of the data we hold about you
Right to rectification — request correction of inaccurate data
Right to erasure — request deletion of your data
Right to restriction — request that we limit how we use your data
Right to portability — request your data in a portable format
Right to object — object to processing based on legitimate interests
Right to withdraw consent — withdraw consent at any time without affecting prior processing

To exercise any of these rights, email support@spectrumalpha.org. We will respond within 30 days.

If you are not satisfied with our response, you have the right to lodge a complaint with your national data protection authority.

12. Data Security

We take reasonable technical and organisational measures to protect your personal data, including encrypted data storage, access controls, and secure API connections between our service components.

No system is completely secure. If you believe your data has been compromised, contact us immediately at support@spectrumalpha.org.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered families of material changes by email. The date at the top of this page reflects the most recent update. Continued use of Alfie after a change constitutes acceptance of the updated policy.

14. Contact Us

For any privacy-related queries, requests, or complaints:

Email: support@spectrumalpha.org
Post: Spectrum Alpha Ltd, St John's Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom