Legal Updated 15 August 2026

Privacy Policy

1. Who we are

Oxygen Bubbles Limited ("we", "us", "our") is a company registered in England and Wales. Our registered office is at Brookfield Court, Selby Road, Garforth, Leeds, LS25 1NB. We are committed to protecting your privacy and handling your personal data responsibly.

2. What data we collect

We collect personal data through the following channels:

2.1 Website analytics

We use Google Analytics 4 to understand how visitors use our website. This collects data including pages visited, time on site, device type, browser type, approximate geographic location and referral source. Google Analytics uses cookies to distinguish unique users. We do not ask Google Analytics to collect names, email addresses or other directly identifying information. Analytics only loads if you accept cookies.

2.2 Session recording and heatmaps

We use Microsoft Clarity to see how visitors interact with our pages. Clarity records session activity such as mouse movement, clicks, scrolling and the pages you view, and combines this into aggregated heatmaps and session replays. It also records your IP address, browser and device. Clarity masks text input by default, so what you type into the contact form should not appear in a replay. Clarity only loads if you accept cookies.

2.3 Contact form

When you submit an enquiry through our website contact form, you provide your name and email address, and optionally your phone number and company name, together with your message. We also record the IP address the submission came from, which we use to rate limit the form against abuse. This data is sent through our Azure-hosted API and used to respond to your enquiry and arrange any subsequent meetings.

2.4 Oxi, our AI chat assistant

If you use the chat assistant, the messages you send are transmitted to our Azure-hosted API and processed by Microsoft Azure OpenAI Service to generate a reply. Please do not enter confidential or special category information into the chat. Your recent chat history is also stored locally in your own browser so the conversation survives a page reload. That copy stays on your device, and you can erase it at any time using the clear button in the chat window or by clearing your browser storage.

2.5 Oxi voice conversations in your browser

If you start a voice call with Oxi, your browser asks for permission to use your microphone. Audio is streamed to ElevenLabs, which provides the speech recognition, the conversational AI and the synthesised voice. We do not receive or store the raw audio. Nothing is captured unless you grant microphone permission and start a call, and you can end the call at any time.

2.6 Telephone calls answered by Oxi

Our telephone number is answered by the same AI assistant. Calls are transcribed by ElevenLabs, and when a call ends we receive a written transcript together with the call duration and, where your network provides it, your telephone number. We use this to follow up on your enquiry. If you would rather not speak to an AI assistant or be transcribed, please email us instead.

2.7 Cookie consent record

When you accept or decline cookies we record your choice, the time you made it, your IP address and your browser user agent in Microsoft Azure Table Storage. We keep this as evidence that consent was properly obtained, which is itself a requirement of data protection law.

2.8 Direct contact

If you email us at hello@oxygenbubbles.com or contact us through LinkedIn, we will receive and store your name, email address and the content of your message.

3. How we use your data, and our lawful basis

  • Responding to enquiries and arranging meetings. Lawful basis: legitimate interest in replying to people who contact us.
  • Delivering our consulting services if you engage us. Lawful basis: performance of a contract.
  • Answering questions through the chat and voice assistants. Lawful basis: legitimate interest in providing information you have asked for.
  • Understanding how our website is used, through analytics and session recording. Lawful basis: consent.
  • Recording your cookie choice. Lawful basis: legal obligation.
  • Protecting our forms and voice service from abuse. Lawful basis: legitimate interest in keeping the service available.
  • Sending you information about our services. Lawful basis: consent, and only if you have opted in.

Our chat and voice assistants generate their replies automatically. They answer questions about our services and pass enquiries to us. They do not make any decision that produces a legal effect for you or similarly significantly affects you, and no automated decision is taken about whether we will work with you.

4. Cookies and browser storage

Our website sets the following cookies, and none of them load until you accept:

  • Google Analytics (_ga, _ga_*). Distinguish unique users and sessions for analytics. These expire after up to 2 years.
  • Microsoft Clarity (_clck, _clsk and related). Link session recordings to a returning visitor. These expire after up to 1 year.

We also use your browser's own storage, which is not shared with us:

  • ob-cookie-consent. Remembers your cookie choice so we do not ask again.
  • oxi-chat-history. Keeps your recent chat messages on your device.
  • oxi-voice-calls. Counts voice calls in the current session so we can apply a fair usage limit. Cleared when you close the tab.

You can control cookies through your browser settings, and clear the items above by clearing site data. Declining cookies, or clearing this storage, will not affect the core functionality of our website.

5. Data sharing

We do not sell your personal data. We share data only with the following third parties, solely for the purposes described above:

  • Google LLC (website analytics), data processed under Google's privacy policy
  • Microsoft Corporation (Azure hosting, contact form processing, Azure OpenAI Service for chat replies, Clarity session recording, Azure Table Storage for consent records, and Microsoft Teams where we forward enquiry notifications internally), data processed under Microsoft's privacy policy
  • ElevenLabs Inc. (voice conversations, speech recognition, synthesised speech and call transcription), data processed under ElevenLabs' privacy policy
  • Twilio Inc. / SendGrid (email delivery for contact form submissions and call transcripts), data processed under Twilio's privacy policy

6. International transfers

Some of the providers above are based in the United States or process data outside the United Kingdom. Where personal data is transferred outside the UK, we rely on the transfer mechanisms offered by those providers, which include the UK extension to the EU-US Data Privacy Framework and the International Data Transfer Addendum to the European Commission's standard contractual clauses. You can ask us for more detail about the safeguards that apply to a particular transfer.

7. Data retention

We retain personal data only for as long as necessary for the purpose it was collected.

  • Enquiry data, including contact form submissions and call transcripts, is retained for up to 24 months after our last contact with you.
  • Analytics data is retained for 14 months, the Google Analytics default.
  • Microsoft Clarity session data is retained for up to 13 months.
  • Cookie consent records are retained for up to 24 months, so we can evidence the consent that was in force.
  • Chat history held in your own browser is limited to your most recent 50 messages and stays until you clear it.

8. Your rights

Under the UK General Data Protection Regulation (UK GDPR), you have the right to:

  • Access the personal data we hold about you
  • Request correction of inaccurate data
  • Request deletion of your data
  • Object to or restrict processing of your data
  • Request data portability
  • Withdraw consent at any time

To exercise any of these rights, contact us at hello@oxygenbubbles.com.

9. Data security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or destruction. All data is transmitted over encrypted connections (HTTPS).

10. Changes to this policy

We may update this policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this page periodically.

11. Contact

If you have questions about this privacy policy or wish to exercise your data rights, please contact us:

Oxygen Bubbles Limited
Brookfield Court, Selby Road, Garforth, Leeds, LS25 1NB
Email: hello@oxygenbubbles.com

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

See also our terms of service, read about how we govern AI in client work, or get in touch if anything here needs explaining.