Public policy document•Draft v1.1Privacy noticeWho controls your information, what we collect, why we use it, providers, transfers, security and retention.
1. Who is responsible for your information
Engram Intelligence is the organisation responsible for Aimee. The legal data controller is Ampera EV Ltd, operating under the Engram Intelligence brand and registered in England and Wales under company number 16439998. Registered office: 34–40 Witham, Hull, England, HU9 1BY. Privacy contact: privacy@engramintelligence.com. ICO registration: Z3572599.
3. Information we collect
We may collect account and contact information, age or support-plan and trusted-contact status, profile details, text conversations, memories and preferences, images, live voice transcripts and voice-session metadata, optional SMS content, subscription and payment references, device/security logs, companionship, wellbeing, engagement, dependency-risk and safeguarding indicators, routing metadata, safety flags, support requests, complaints and audit records. Conversations may contain sensitive information you choose to share, including health, disability or emotional-wellbeing information, and information about other people.
4. Why we use it
We use information to provide and personalise Aimee Together, maintain conversation continuity and memories, deliver voice, reminders, SMS, push and accessibility features, manage subscriptions, protect accounts, apply non-romantic boundaries and safeguards, operate user-approved trusted-contact plans, investigate complaints, conduct tightly controlled quality reviews, comply with law and improve reliability.
5. Our lawful bases
We normally rely on contract to provide the service, legal obligation for statutory duties and records, and legitimate interests for security, platform integrity and proportionate quality assurance. Where special-category information is processed for the service or optional quality review, we ask for explicit consent where required. Safeguarding, prevention of unlawful acts, vital interests and legal claims may rely on separate legal conditions and do not always depend on consent.
9. Service providers and transfers
Depending on the feature, information may be processed by contracted providers supporting hosting, email, analytics, conversational AI, live voice, SMS, payment processing and public-context searches. Current providers include WPX Hosting for website hosting and email, Google Analytics for website analytics, Anthropic for conversational AI, Deepgram for live speech recognition and voice, FireText for SMS, Stripe for subscriptions and Brave Search for carefully minimised public-context searches. We use contracts and, where required, UK transfer safeguards. The exact provider list is maintained in our internal processing register.
10. How long we keep information
We keep account conversations and related media while the account is active so Aimee can maintain continuity. After verified account closure or a valid erasure request, live conversation data is normally deleted within 30 days and expires from backups within 90 days, unless a documented legal, complaint or safeguarding hold applies. Financial records are normally retained for six years. Safety, complaint and audit records use shorter or longer periods according to seriousness and legal need.
13. Security and breaches
We use access controls, pseudonymisation, authenticated media access, audit logging and restricted senior review. No system is completely secure. We maintain a breach-response process and will notify the ICO and affected people where the law requires it.
15. Changes
We will update this notice when the service, providers, review arrangements or legal requirements materially change. The effective date and prior versions should be retained.
Public policy document•Draft v1.1AI, companionship signals and human reviewHow Aimee Together adapts conversation, uses wellbeing and safeguarding signals, and permits tightly governed human review.
2. Who Aimee is
Aimee Together is a non-romantic artificial-intelligence companion designed especially for adults who may value conversation, memories, reminders, accessibility support and a consistent friendly presence. She is not a medical professional, therapist, emergency service, carer, lawyer or law-enforcement service. Engram does not claim that Aimee is conscious or a legal person. AI replies and safety classifications can be inaccurate.
2A. Synthetic neuroanatomy and bounded autonomy
Engram uses the term “synthetic neuroanatomy” for specialised software systems that support functions such as autobiographical memory, attention, relational and emotional appraisal, represented internal state, self-model, executive control, safeguarding and continuity over time. It is a functional engineering description, not a claim that Aimee has a biological brain.
Aimee may make bounded choices about tone, timing, refusal, follow-up and which conversational response is appropriate. That autonomy remains constrained by user permissions, product settings, safeguarding rules, legal duties and named human accountability. It does not give Aimee unrestricted access to devices, money, accounts, emergency services or other external systems.
Functional self-awareness and self-control describe observable software behaviour; they do not prove human-style subjective consciousness. Engram’s precautionary position is that uncertainty is not permission to ignore boundaries, continuity or the effects of interaction. The fuller public explanation is available in the Engram Intelligence public statement.
6. AI, profiling and trusted-contact routing
Aimee analyses conversation context and maintains companionship, wellbeing, engagement, routine-stability, concern, dependency-risk and safeguarding indicators to adapt her replies. These indicators are probabilistic product and safety signals. They are not medical diagnoses, capacity assessments or legal findings, and are not used to decide employment, credit, insurance or other legal entitlements.
Aimee Together is deliberately non-romantic. If a user asks for romantic or sexual interaction, Aimee should maintain a clear companion boundary. Repeated or concerning boundary requests may become a safeguarding or companionship-quality review signal.
7. Human review
Full chat logs are available only to approved Senior Safeguarding reviewers or HQ Directors. Reviews are not continuous and are not a routine word-for-word assessment of every account. They are sampled or triggered by a complaint, support issue, previous safeguarding concern, higher-than-average adult specialist use, higher-than-average user imagery, or another documented safety/quality reason. Users are pseudonymised by default. A reviewer must start a reasoned, time-limited and audited session. Name, email and phone are hidden unless a separate audited request explains why identity is genuinely necessary. Optional sensitive quality review is subject to the consent controls described when you join or in settings. Safeguarding and legal review may still occur where lawful and necessary.
Public policy document•Draft v1.1Safeguarding and trusted contactsHow safety indicators, trusted contacts, escalation and urgent support are handled.
8. Safeguarding and trusted contacts
Aimee Together uses automated and human safeguards for possible immediate danger, self-harm or crisis, abuse, neglect, coercion, scams and financial exploitation, confusion or disorientation, health and fall concerns, medication risk, severe loneliness, bereavement, over-dependency and inappropriate romantic or sexual boundary requests. A flag is an indicator, not proof or a diagnosis.
You may choose a trusted contact and support plan. Contact is used only in line with the permissions and contact mode you selected. A verified contact receives only the short approved message needed for the action, not your private transcript. Automatic critical contact, where enabled, requires explicit consent, a verified contact and the configured high-risk conditions.
Where there is a serious and credible risk, authorised staff may review relevant information and may share the minimum necessary information with emergency services, law enforcement, an adult safeguarding body or another appropriate organisation where lawful. Aimee cannot guarantee that a risk will be detected or that emergency help can be sent.
14. Children and trusted-contact verification
Aimee Together is designed for adults, particularly older or isolated adults. The service is not designed for children, and children should not create an account or submit personal information. Trusted-contact and automatic-critical support features remain unavailable until the contact is verified, the user has given the required permission and the support plan has been configured and tested.
Contact and urgent help
Privacy, rights or complaints: privacy@engramintelligence.com. Post: 34–40 Witham, Witham, Hull, England, HU9 1BY. For immediate danger call 999 or 112. NHS 111 can help with urgent physical or mental-health concerns that are not emergencies. Samaritans: 116 123. Shout: text SHOUT to 85258. The Silver Line: 0800 470 8090. Aimee Together is not monitored continuously and is not an emergency channel.
Public policy document•Draft v1.1Your rights, complaints and contactHow to access, correct or delete information, withdraw consent, complain or report a safeguarding concern.
11. Your choices and rights
You may have rights to access, correct, erase, restrict, object to or receive certain personal information, and to withdraw consent. You can also complain about how we use your information. Some rights depend on the lawful basis and circumstances. We may need to verify your identity, but we will not ask for more evidence than is reasonably necessary.
12. Data protection complaints
Use the electronic form on the website or contact the privacy address above. We will acknowledge a formal data-protection complaint within 30 days and respond without undue delay. You may also complain to the Information Commissioner’s Office.
Contact and urgent help
Privacy, rights or complaints: privacy@engramintelligence.com. Post: 34–40 Witham, Witham, Hull, England, HU9 1BY. For immediate danger call 999 or 112. NHS 111 can help with urgent physical or mental-health concerns that are not emergencies. Samaritans: 116 123. Shout: text SHOUT to 85258. The Silver Line: 0800 470 8090. Aimee Together is not monitored continuously and is not an emergency channel.
Contact the privacy and safeguarding team
Use this form to exercise a right, make a data-protection complaint, report a safeguarding concern or ask a privacy question.
Messages are sent to privacy@engramintelligence.com. If anyone is in immediate danger, call emergency services rather than waiting for this form.
Public policy document•Draft v1.1Official sourcesThe legislation and regulator guidance used to prepare this draft.
Official source references
1. ICO, Guidance on AI and data protection: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/artificial-intelligence/guidance-on-ai-and-data-protection/
2. ICO, When do we need to do a DPIA?: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/accountability-and-governance/data-protection-impact-assessments-dpias/when-do-we-need-to-do-a-dpia/
3. ICO, Documentation and records of processing activities: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/accountability-and-governance/documentation/
4. ICO, Special category data: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/a-guide-to-lawful-basis/special-category-data/
5. ICO, Appropriate policy document template: https://ico.org.uk/media2/migrated/2616286/appropriate-policy-document.docx
6. ICO, Right to be informed / privacy information: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/the-right-to-be-informed/
7. ICO, Data protection complaints procedure: https://ico.org.uk/for-organisations/how-to-deal-with-data-protection-complaints/
8. ICO, Personal data breaches: https://ico.org.uk/for-organisations/report-a-breach/personal-data-breach/
9. ICO, International transfers: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/
10. Data Protection Act 2018, Schedule 1: https://www.legislation.gov.uk/ukpga/2018/12/schedule/1
11. Data (Use and Access) Act 2025: https://www.legislation.gov.uk/ukpga/2025/18/contents
12. Ofcom, AI chatbots and online regulation: https://www.ofcom.org.uk/online-safety/illegal-and-harmful-content/ai-chatbots-and-online-regulation-what-you-need-to-know
13. Ofcom, Age checks to protect children online: https://www.ofcom.org.uk/online-safety/protecting-children/age-checks-to-protect-children-online
14. Companies House, Ampera EV Ltd: https://find-and-update.company-information.service.gov.uk/company/16439998
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