PRIVACY POLICY

Four10 Group Ltd trading as BayAssist
Telford, Shropshire, United Kingdom
Last Updated: February 2026

1. INTRODUCTION

This Privacy Policy explains how Four10 Group Ltd (trading as BayAssist), registered in England and Wales, with its registered address in Telford, Shropshire ("we", "us", "our", "the Company") processes personal data in connection with the BayAssist service, a cloud-based telephone answering and booking system for automotive businesses.

This policy applies to:

  1. End callers whose calls are routed through BayAssist systems
  2. Business customers who subscribe to the BayAssist service
  3. Visitors to our website bayassist.co.uk

2. DATA CONTROLLER AND DATA PROCESSOR

2.1 Business Customers When Four10 Group Ltd provides the BayAssist service to an automotive business (a "Business Customer"), that Business Customer is the Data Controller under Article 4(7) of UK GDPR. Four10 Group Ltd acts as a Data Processor under Article 28 of UK GDPR on behalf of the Business Customer. Data processing is governed by a separate Data Processing Agreement provided to each Business Customer at the time of service setup.

2.2 Website Visitors For visitors to bayassist.co.uk and related websites, Four10 Group Ltd is the Data Controller.

2.3 End Callers End callers to BayAssist-enabled telephone numbers may have their data processed by both the Business Customer (as Data Controller) and Four10 Group Ltd (as Data Processor).

3. PERSONAL DATA WE COLLECT

We collect the following categories of personal data:

  1. Caller Data: Telephone numbers provided during calls to BayAssist-enabled numbers
  2. Vehicle Data: Vehicle registration numbers provided during calls, obtained from callers and subsequently queried against the DVSA public database
  3. Call Recordings: Complete audio recordings of calls made to BayAssist-enabled telephone numbers
  4. Call Transcripts: Text transcripts of recorded calls, generated by automated speech-to-text processing
  5. Booking Data: Appointment details including date, time, vehicle information, and service type requested
  6. SMS Content: Text and content of SMS messages sent on behalf of Business Customers, including confirmation and reminder messages
  7. MOT History: Vehicle MOT history and advisory information obtained from the DVSA public database
  8. Website Visitor Data: IP addresses, browser type, pages visited, referral sources, and duration of visit for all website visitors
  9. Business Customer Data: Business name, contact name, email address, registered business address, telephone number, and calendar integration credentials

4. LAWFUL BASIS FOR PROCESSING

We rely on the following lawful bases under UK GDPR for processing personal data:

  1. Performance of Contract (Article 6(1)(b)): Processing necessary to deliver the BayAssist service, including call answering, booking management, and SMS confirmation delivery to Business Customers and their customers.
  2. Legitimate Interest (Article 6(1)(f)): Call recording for purposes of quality assurance, staff training, dispute resolution, and service improvement. This processing is conducted with appropriate safeguards and disclosure to callers at the beginning of each call.
  3. Consent (Article 6(1)(a)): Marketing communications and opt-in SMS follow-up messages are processed on the basis of explicit consent provided by recipients.
  4. Legal Obligation (Article 6(1)(c)): Where processing is required to comply with applicable UK law or lawful regulatory requirements.

5. HOW WE USE PERSONAL DATA

We use personal data for the following purposes:

  1. To answer inbound telephone calls to Business Customer numbers on a 24/7 basis
  2. To extract caller information and create appointment bookings based on call content
  3. To send booking confirmation SMS messages to end callers
  4. To send reminder SMS messages to reduce no-shows
  5. To query the DVSA database for vehicle MOT history and advisory information relevant to the call
  6. To provide Business Customers with access to call recordings, transcripts, and booking data via the BayAssist portal
  7. To send follow-up SMS messages regarding vehicle advisories
  8. To analyse service usage and improve our systems and AI models
  9. To comply with legal obligations or respond to lawful requests from authorities

6. THIRD-PARTY DATA PROCESSORS AND INTERNATIONAL TRANSFERS

6.1 Sub-processors In delivering the BayAssist service, we engage the following third-party Data Processors:

  1. Retell AI (United States): Provides voice AI processing, call recording, and call analysis. Personal data transferred to and processed in the USA.
  2. Twilio (United States): Provides SMS delivery and telephone routing infrastructure. Twilio operates with EU processing capabilities and implements appropriate data protection safeguards.
  3. Cloudflare (Global): Provides website hosting, content delivery, and data storage on a global CDN with EU data residency options.
  4. GoHighLevel (United States): Provides CRM functionality and workflow automation for Business Customers. US-based processing with standard safeguards.
  5. Meta Platforms (United States): Provides website analytics through Meta Pixel (Pixel ID: 1434697488069766) and advertising services.
  6. DVSA (United Kingdom): We query the DVSA public database for vehicle MOT history. DVSA data is not stored by us.

6.2 International Data Transfers Personal data is transferred to and processed in the United States by Retell AI, Twilio, GoHighLevel, and Meta Platforms. These transfers are protected by Standard Contractual Clauses (SCCs) as approved by the UK Information Commissioner's Office, and where applicable, by processors' certifications under applicable data transfer frameworks. All US-based processors maintain appropriate technical and organisational safeguards consistent with UK GDPR requirements.

7. DATA RETENTION

We retain personal data for the following periods:

  1. Call Recordings and Transcripts: 90 days from the date of the call, then automatically deleted
  2. Booking Data: 24 months from the date of the booking
  3. SMS Logs and Message Content: 12 months from the date of the message
  4. Business Customer Account Data: Duration of the service agreement plus 12 months following termination or cancellation
  5. Website Analytics Data: 26 months as per Meta Pixel and Cloudflare retention policies

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Meta Pixel We use Meta Pixel (Pixel ID: 1434697488069766) on our website for the purposes of website analytics and advertising. Meta Pixel may set cookies on your device to track your behaviour across our website and on other websites.

8.2 Essential Cookies We use essential cookies necessary for website functionality, security, and performance. These cookies are necessary for the website to function and cannot be disabled.

8.3 Your Consent By using bayassist.co.uk, you consent to the use of cookies and tracking technologies as described in this policy.

9. YOUR RIGHTS UNDER UK GDPR

You have the following rights in relation to your personal data:

  1. Right of Access (Article 15): You may request a copy of the personal data we hold about you.
  2. Right to Rectification (Article 16): You may request that we correct inaccurate or incomplete personal data.
  3. Right to Erasure (Article 17): You may request deletion of your personal data in certain circumstances (the "right to be forgotten").
  4. Right to Restrict Processing (Article 18): You may request that we limit how we use your personal data.
  5. Right to Data Portability (Article 20): You may request that we provide your personal data in a portable, machine-readable format.
  6. Right to Object (Article 21): You may object to processing of your personal data for direct marketing or on grounds of legitimate interest.
  7. Right to Withdraw Consent: If processing is based on consent, you may withdraw that consent at any time.

To exercise any of these rights, please contact us at dave@four10.agency with details of your request. We will respond within 30 calendar days of receipt.

10. CALL RECORDING DISCLOSURE

Callers to BayAssist-enabled telephone numbers are informed at the start of each call, by automated announcement, that the call is being recorded. Recordings are made for quality assurance, training, staff development, and dispute resolution purposes. By continuing the call after this disclosure, callers consent to the recording.

11. COMPLAINTS AND REGULATORY CONTACT

If you are dissatisfied with our handling of your personal data or believe we have breached UK GDPR, you have the right to lodge a complaint with the Information Commissioner's Office (ICO).

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
United Kingdom
ico.org.uk

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The latest version of this policy will always be available at bayassist.co.uk/privacy. We will notify Business Customers of material changes via email.

13. CONTACT INFORMATION

Four10 Group Ltd trading as BayAssist
Telford, Shropshire
United Kingdom
Email: dave@four10.agency
Telephone: 01952 767 010

For Data Processing Agreement queries or data subject requests, please contact dave@four10.agency.