Legal Document

BioAgent Privacy Policy

This policy explains how BioAgent (operated by Intelligent Labs Ltd) collects, uses, stores and protects personal data — including data processed through the BioAgent AI receptionist service (operating as Stacy) and Meta platform integrations (Instagram and Facebook).

📅 Last updated: June 2026 — v1.3 🏢 Intelligent Labs Ltd — Co. No. 17250096 🌐 Applies to: BioAgent — intelligent-labs.co.uk
Contents
  1. Who we are
  2. What data we collect and why
  3. Meta platform integrations — Instagram & Facebook
  4. How we use your data
  5. Legal basis for processing
  6. Data sharing and third parties
  7. Data retention
  8. Your rights under UK GDPR
  9. Cookies
  10. Children's data
  11. International transfers
  12. Security
  13. Changes to this policy
  14. Contact us

1. Who We Are

BioAgent is an AI receptionist and messaging automation service operated by Intelligent Labs Ltd — a UK registered company. BioAgent provides AI-powered receptionist, call handling, and social media DM automation services to businesses across the UK, UAE, and Saudi Arabia.

Intelligent Labs Ltd is the data controller for personal data collected through our website and the data processor for personal data collected on behalf of our business clients through the BioAgent platform.

DetailInformation
Service / Brand nameBioAgent
Legal entityIntelligent Labs Ltd
Company number17250096
Registered inEngland & Wales
Registered addressThe Warehouse, 53 Ormrod St, Bury, BL9 7HF
Emailinfo@intelligent-labs.co.uk
Websiteintelligent-labs.co.uk

2. What Data We Collect and Why

2.1 Website visitors

When you visit our website we may collect:

2.2 Business clients

When a business signs up for BioAgent services we collect:

2.3 End users — callers and DM senders

When an end user interacts with a BioAgent-powered service on behalf of one of our business clients, the following data may be collected on behalf of that client:

Important: When BioAgent is deployed for a business client, that business is the Data Controller for their customers' data. Intelligent Labs Ltd acts as the Data Processor. The client's own privacy policy also applies to their customers' data.

3. Meta Platform Integrations — Instagram & Facebook

📘 Meta Platform Compliance

BioAgent (operated by Intelligent Labs Ltd) integrates with Meta's Messenger Platform API and Instagram Graph API to provide automated DM handling on behalf of business clients. The AI assistant operating within these conversations is named Stacy — BioAgent's AI receptionist persona. This section specifically addresses how BioAgent handles data from these integrations in accordance with Meta's Platform Terms and Developer Policies.

3.1 What the integration does

BioAgent's DM Automation service connects to a business client's Instagram Business account and/or Facebook Page via Meta's official APIs. Conversations are handled by Stacy — BioAgent's AI receptionist. When a user sends a Direct Message to that business account, Stacy (powered by BioAgent):

3.2 How we connect to Meta platforms

BioAgent connects directly to Meta's official APIs — the Instagram Graph API and the Messenger Platform API — via secure webhooks. We do not use third party intermediary platforms to access Meta data. All data received from Meta is processed directly by BioAgent's systems in compliance with Meta's Platform Terms and Developer Policies.

3.2a Data received from Meta platforms

When processing Instagram and Facebook DMs on behalf of a business client, we receive and process the following data from Meta:

Data typeSourcePurposeRetention
Subscriber ID (unique Meta user identifier)Meta webhook payloadIdentify the user across the conversation30 days maximum
First name and last nameMeta webhook payloadPersonalise responses30 days maximum
Message contentMeta webhook payloadGenerate AI responses30 days maximum
TimestampMeta webhook payloadConversation management30 days maximum
Channel type (Instagram/Facebook)Meta webhook payloadRoute responses correctly30 days maximum

3.3 What we do NOT collect from Meta

3.4 Opt-out and consent

Users who interact with a BioAgent-powered Instagram or Facebook account (including conversations with Stacy, BioAgent's AI receptionist) can opt out of automated messaging at any time by sending any of the following keywords in a Direct Message:

Upon receiving any of these keywords the system will immediately cease all automated responses, send a single confirmation message — "You've been unsubscribed from automated messages. Reply START to opt back in." — and add the user to an opted-out list. No further automated messages will be sent unless the user actively opts back in.

Users can opt back in at any time by sending START. Upon receipt of START the system will resume automated responses and send a welcome confirmation message.

Opt-out requests are processed immediately and automatically — no human intervention is required.

3.5 Meta's own privacy policy

Use of Instagram and Facebook is also subject to Meta's own Privacy Policy, available at facebook.com/privacy/policy. Intelligent Labs Ltd operates within Meta's Platform Terms and Developer Policies at all times.

3.6 24-hour messaging window

In compliance with Meta's Messenger Platform policy, BioAgent only sends automated responses within the 24-hour messaging window following a user-initiated message. We do not send unsolicited messages outside of this window.

3.7 Message tags

BioAgent does not send messages outside the standard 24-hour messaging window.

3.8 AI identity disclosure — Stacy

BioAgent's DM automation service operates under the persona name Stacy — an AI receptionist. Stacy is not a human. When a user asks whether they are speaking to a real person or an AI, Stacy is configured to identify itself as a AI assistant and will never claim to be human.

Stacy responds on behalf of the business whose account the user has contacted. The business is responsible for informing their customers that automated AI responses may be used when contacting their social media accounts.

If a user wishes to speak to a human representative, Stacy will offer to connect them with the business team during business hours.

3.9 Automated data deletion

BioAgent operates an automated nightly data cleanup process that permanently deletes all Instagram and Facebook DM conversation history older than 30 days from our systems. This process runs automatically every night without manual intervention.

This means:

Note that the business client's own CRM may retain a summary of the booking or enquiry outcome (name, phone number, treatment interest) for their own legitimate business purposes and in accordance with their own data retention policy.

3.10 Webhook security

BioAgent uses secure HTTPS webhooks to receive data from Meta's platforms. All webhook endpoints are:

Any request that fails webhook validation is rejected immediately and logged.

3.11 Human handoff

BioAgent's AI persona Stacy is configured to offer human handoff in the following situations:

During business hours, human handoff connects the user with the business client's team directly. Outside business hours, the user is informed of business hours and offered a callback.

3.12 Prohibited uses

BioAgent's Meta integration is strictly prohibited from being used for:

Business clients who use BioAgent agree in writing (via our Service Agreement) that they will not attempt to use the platform for any prohibited purpose. Intelligent Labs Ltd reserves the right to immediately suspend access for any client found to be in breach of these restrictions.

4. How We Use Your Data

We use personal data for the following purposes:

We do not use personal data for automated decision-making that produces legal or similarly significant effects on individuals.

5. Legal Basis for Processing

We rely on the following legal bases under UK GDPR Article 6:

Processing activityLegal basis
Responding to website enquiriesLegitimate interests (Article 6(1)(f))
Delivering BioAgent services to business clientsContract performance (Article 6(1)(b))
Processing end user data on behalf of business clientsLegitimate interests of the data controller (our client) (Article 6(1)(f))
Instagram and Facebook DM automationLegitimate interests — the user initiated the conversation by contacting the business (Article 6(1)(f))
Legal and compliance obligationsLegal obligation (Article 6(1)(c))

6. Data Sharing and Third Parties

We use the following third party platforms to deliver our services. Each is subject to a data processing agreement or operates under equivalent safeguards:

PlatformPurposeData sharedLocation
Retell AIVoice AI engineCall audio, transcriptsUSA (SCCs in place)
Make.comWorkflow automationConversation data, booking detailsEU
HubSpotCRMContact name, phone, enquiry detailsUSA (SCCs in place)
StripePayment processingPayment data (processed by Stripe directly)USA (SCCs in place)
Zoho MailEmail communicationsEmail contentEU
NetlifyWebsite hostingContact form submissionsUSA (SCCs in place)
Anthropic (Claude API)AI language modelConversation text (processed in real time)USA (SCCs in place)
Meta (Instagram/Facebook)DM platformMessage content, subscriber IDUSA (SCCs in place)

We do not sell personal data to any third party. We do not share personal data for marketing or advertising purposes.

7. Data Retention

Data typeRetention periodReason
Website contact form submissions12 monthsTo manage and respond to enquiries
Instagram / Facebook DM conversation history30 days maximum — automatically deleted by nightly cleanup processConversation context only. An automated nightly process checks all records and permanently deletes any conversation history older than 30 days. This is automatic and requires no manual intervention.
Call recordings and transcripts90 days maximumQuality assurance and dispute resolution
CRM contact records (client data)Duration of client contract + 30 daysService delivery
Business client account dataDuration of contract + 7 yearsLegal and financial compliance
Payment records7 yearsHMRC legal requirement

On termination of a client contract, all end user personal data held on behalf of that client is deleted within 30 days of the termination date.

8. Your Rights Under UK GDPR

Under UK GDPR you have the following rights in relation to your personal data:

To exercise any of these rights please contact us at info@intelligent-labs.co.uk. We will respond within 30 days. There is no charge for reasonable requests.

If you are not satisfied with our response you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

9. Cookies

Our website uses minimal cookies. We do not use advertising cookies, tracking pixels, or third party analytics cookies that identify individual users.

Standard session cookies may be set by our hosting provider (Netlify) for security and performance purposes. These do not contain personal data and expire when you close your browser.

Our contact forms use Netlify Forms which may set a session cookie for spam prevention. This cookie does not track you across other websites.

10. Children's Data

Our services are not directed at children under the age of 18. We do not knowingly collect personal data from children.

Where a BioAgent-powered AI agent detects that a caller or DM sender may be under 18, the agent is configured to decline to book treatments requiring minimum age compliance and to direct the individual to contact the business directly during business hours.

If you believe we have inadvertently collected data from a child please contact us immediately at info@intelligent-labs.co.uk and we will delete it promptly.

11. International Data Transfers

Some of our third party service providers are based outside the UK and EEA. Where personal data is transferred internationally we ensure appropriate safeguards are in place including:

All international transfers are documented and assessed under our Transfer Impact Assessment process.

12. Security

We take the security of personal data seriously. Our technical and organisational measures include:

In the event of a personal data breach we will notify affected clients within 48 hours and the ICO within 72 hours where required by UK GDPR Article 33.

Our full Information Security Policy is available on request.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, or legal requirements. When we make significant changes we will update the "Last updated" date at the top of this page.

We encourage you to review this policy periodically. Continued use of our services following any update constitutes acceptance of the revised policy.

14. Contact Us

For any questions about this Privacy Policy, to exercise your data rights, or to report a data protection concern please contact us:

Data Controller — BioAgent / Intelligent Labs Ltd

🏢 BioAgent — operated by Intelligent Labs Ltd
The Warehouse, 53 Ormrod St, Bury, BL9 7HF
🌐 Website: intelligent-labs.co.uk
🏛️ Company No. 17250096 — Registered in England & Wales
📘 Meta Platform Enquiries

For enquiries specifically relating to Instagram or Facebook DM data processed through a BioAgent-powered account, please contact the business whose account you interacted with directly. Alternatively contact us at info@intelligent-labs.co.uk with the subject line "Meta Data Enquiry" and we will assist within 5 business days.