Privacy notice for Buddy – CIFO’s AI website agent
Set out below is CIFO’s notice to users of Buddy and its processing of data submitted to Buddy.
1. What is Buddy?
Buddy is an online website assistance tool provided by the Channel Islands Financial Ombudsman (CIFO). It is intended to help users navigate website information the website interface. Buddy operates on a platform that is separate from CIFO’s internal operating systems and does not access CIFO’s internal case management or other internal data systems.
2. What information may be processed?
- Information you type into Buddy, including prompts or questions.
- Technical information needed to operate, secure and improve the service, such as usage logs, timestamps and device or browser information, depending on system configuration.
- Responses generated by Buddy during your interaction.
3. Please do not submit personal data
Buddy is designed for general website assistance only. You must not submit personal data, special category data, or information about another person through Buddy. Before using the service, you will be asked to confirm that you understand this warning. If personal data is nevertheless submitted, CIFO may need to process and delete it to protect individuals and manage the service safely.
4. Who is responsible for your information?
CIFO is the controller for any personal data processed in connection with Buddy. This means CIFO is responsible for deciding why and how personal data is processed for this service. If you have questions about this notice or about how CIFO handles personal data, please review CIFO’s Data Protection Privacy Notice – Privacy & Cookies | Channel Islands Financial Ombudsman.
5. Why do we process information and what is the legal basis?
CIFO processes information through Buddy to provide website assistance, maintain the security and performance of the service, and manage the website environment. Where personal data is processed, CIFO expects the relevant legal basis under the Data Protection (Jersey) Law 2018 to be its legitimate interests in operating and protecting an accessible website support service, provided those interests are not overridden by the rights and freedoms of individuals and as part of its statutory function as an Ombudsman service.
6. Optional use of content to improve Buddy
CIFO may wish to use submitted prompts or interaction content to improve or enhance Buddy beyond what is strictly necessary to provide the service itself, in this event CIFO will ask for a separate opt-in choice. If that option is made available, CIFO will explain clearly what will be used, for what purpose, for how long, and whether any de-identification or minimisation measures will be applied. You should be able to use the core Buddy service without being required to agree to this optional use.
7. Who may receive or access information?
CIFO may use third-party service providers to help design, host, support or maintain Buddy and the related website environment. CIFO will require any third party handling personal data on its behalf to do so only under appropriate written terms, with suitable confidentiality, security and data protection obligations.
8. How long will information be kept?
CIFO will keep prompts, outputs and related logs only for as long as necessary for the purpose for which they were collected, including service operation, security, troubleshooting and any optional improvement use that you have agreed to. Exact retention periods are set out in CIFO’s Data Retention Schedule which you can request from CIFO’s Data Protection Team.
9. Your rights and complaints
If you believe personal data has been submitted through Buddy, or if you wish to exercise your rights or complain, you should contact CIFO using the details provided in the main website privacy notice Privacy & Cookies | Channel Islands Financial Ombudsman.