Privacy Notice

This Privacy Notice explains how Stroika International Ltd collects, uses, stores and protects personal information when you register for or use Phronesis, including information submitted when seeking HR guidance.

Version: 5 October 2026
Effective from: 5 October 2026

This Privacy Notice explains how personal information is collected, used, stored and protected when you visit, register for or use Phronesis.

Phronesis is provided by Stroika International Ltd (“Stroika”, “Phronesis”, “we”, “us” or “our”).

For the personal information described in this Notice, Stroika International Ltd will generally act as the data controller.

1. Our approach to privacy

Phronesis is designed to help organisations obtain practical HR guidance while encouraging users to minimise the amount of personal information they provide.

We recognise that HR matters can involve confidential, sensitive and sometimes special category personal information. We therefore encourage users not to identify employees, workers, applicants or other individuals where identification is unnecessary.

For example, in many circumstances, descriptions such as “Employee A”, “the employee” or “the manager” will provide Phronesis with sufficient context.

Users should provide only the information reasonably necessary for Phronesis to understand and respond to the HR issue being considered.

2. Information we may collect

The information we collect depends upon how you use Phronesis.

Account and registration information

This may include:

  • first name;

  • surname;

  • work email address;

  • company or organisation name;

  • number of employees;

  • account identifiers;

  • registration date;

  • account status;

  • usage allowances;

  • subscription information; and

  • information relating to services or additional usage purchased.

Contract and acceptance records

When you create an account or accept updated terms, we may record:

  • your account or email identifier;

  • the date and time of acceptance;

  • the version of the Terms of Use accepted;

  • the version of the Privacy Notice acknowledged; and

  • associated audit information necessary to demonstrate that acceptance.

Acceptance of the Phronesis Terms of Use does not constitute consent to receive marketing communications.

Information submitted when using Phronesis

When asking Phronesis a question, you may provide information concerning employees, workers, applicants, managers or other individuals.

This could include information about:

  • employment;

  • performance;

  • conduct;

  • attendance and absence;

  • sickness;

  • workplace relationships;

  • disciplinary matters;

  • grievances;

  • redundancy;

  • flexible working;

  • family-related leave;

  • contractual issues;

  • dismissal;

  • safeguarding; or

  • other HR and employment matters.

Depending upon the circumstances, information submitted by users could include special category personal data or other sensitive information.

You should only provide personal information that is reasonably necessary for Phronesis to understand the issue.

Technical and usage information

We may collect information necessary to operate, secure, analyse and improve Phronesis, including:

  • account activity;

  • authentication events;

  • number and frequency of interactions;

  • categories or types of HR issues presented;

  • service usage;

  • error information;

  • security events; and

  • limited browser or device information generated through ordinary operation of the website or service.

We do not intend to collect IP address or device information as part of the contractual acceptance record itself.

3. Why we use personal information

We may process personal information to:

  • create and administer Phronesis accounts;

  • verify email addresses;

  • authenticate users securely;

  • provide Phronesis HR guidance;

  • respond to questions submitted by users;

  • manage usage allowances and paid services;

  • maintain records of contractual acceptance;

  • provide customer support;

  • identify and resolve technical problems;

  • protect Phronesis against fraud, misuse or security threats;

  • monitor the quality and effectiveness of the service;

  • understand how Phronesis is being used;

  • understand the types of HR issues users are experiencing;

  • improve Phronesis and develop new functionality and services;

  • identify broader patterns and trends in HR and workplace issues;

  • produce aggregated statistical, research and benchmarking information;

  • comply with legal and regulatory obligations; and

  • establish, exercise or defend legal claims where necessary.

4. Analysis, service improvement and Phronesis insights

One of the ways we may improve Phronesis is by analysing how the service is used and the types of HR issues users ask it to help address.

For example, we may analyse whether users are seeking guidance about absence management, performance, disciplinary matters, grievances, redundancy, flexible working or other categories of HR issue.

We may use this analysis to:

  • understand the HR challenges experienced by Phronesis users;

  • monitor and improve the quality and effectiveness of Phronesis;

  • identify areas where users may need additional guidance or support;

  • improve existing features;

  • develop new products, services, guidance and functionality;

  • identify patterns and emerging workplace trends;

  • undertake statistical analysis and research;

  • produce benchmarking information; and

  • develop aggregated Phronesis insights for reports, articles, presentations, publicity, media commentary and marketing.

Aggregated and anonymised insights

Where information derived from use of Phronesis is used externally for research, benchmarking, publicity or marketing, our intention is to use information that has been aggregated and/or anonymised so that individual users, employees, workers and organisations are not identified.

For example, we may report that:

“32% of Phronesis HR enquiries during a particular period related to absence and sickness management.”

We may also analyse aggregated information by factors such as:

  • organisation size;

  • industry or sector;

  • broad geographic region;

  • category of HR issue;

  • time period; or

  • other sufficiently broad characteristics.

We will take reasonable steps to avoid publishing statistics or combinations of information where the number of relevant users or organisations is so small that an individual or organisation could reasonably be identified.

We will not publish an identifiable user's question, identify an employee, identify an organisation or use an identifiable HR case in external marketing or publicity without an appropriate lawful basis and, where required, permission.

Where information has been effectively anonymised so that an individual is no longer identifiable, that information is no longer personal data for the purposes of UK data-protection law.

Removing a person's name does not necessarily make information anonymous. We recognise the distinction between anonymised information and pseudonymised personal information and will treat information that remains capable of identifying an individual as personal data.

5. Our lawful bases for processing

Under UK data-protection law, we must have an appropriate lawful basis for processing personal information.

Depending upon the circumstances, we may rely upon:

Contract

Where processing is necessary to create and administer your Phronesis account and provide the service you have requested.

Legitimate interests

Where processing is reasonably necessary for our legitimate interests in:

  • operating and administering Phronesis;

  • maintaining the security and integrity of the service;

  • preventing misuse;

  • supporting users;

  • improving the quality and functionality of Phronesis;

  • analysing how the service is used;

  • understanding the types of HR issues users encounter;

  • identifying patterns and trends;

  • developing our products and services; and

  • producing aggregated statistical and business insights,

provided those interests are not overridden by the rights, freedoms and legitimate interests of affected individuals.

Legal obligation

Where processing is necessary for us to comply with applicable legal or regulatory requirements.

Consent

Where we specifically ask you to consent to a particular activity.

Where processing is based upon consent, you may withdraw that consent in accordance with applicable law.

Different requirements apply to special category personal data. Organisations using Phronesis remain responsible for ensuring that they have an appropriate lawful basis and, where necessary, an appropriate additional condition for processing information about their employees, workers or other individuals.

6. Employer and user responsibilities

Where you submit personal information about employees, workers, applicants or other individuals to Phronesis in connection with your organisation's HR activities, your organisation may itself be the data controller for that information.

You are responsible for ensuring that your organisation is entitled to collect, process and submit that information.

You should not use Phronesis as a repository for complete personnel files or submit personal information that is unnecessary for the question being considered.

Where possible, anonymise or minimise information before submitting it.

7. Special category and sensitive information

HR issues can involve information concerning:

  • physical or mental health;

  • disability;

  • racial or ethnic origin;

  • religious or philosophical beliefs;

  • sexual orientation;

  • trade union membership; and

  • other sensitive or legally protected matters.

Some HR circumstances may also involve allegations of criminal behaviour.

Where possible, minimise or anonymise this information before entering it into Phronesis.

Phronesis may require some contextual information to identify discrimination, reasonable-adjustment, whistleblowing, safeguarding or other significant HR risks. However, users should provide only the information reasonably necessary to understand the issue.

8. Artificial intelligence

Phronesis uses artificial intelligence and related technology to process questions and generate HR guidance.

Information submitted to Phronesis may therefore be processed using technology supplied by third-party AI and application providers.

We seek to use appropriate contractual, technical and organisational arrangements with suppliers processing personal information in connection with Phronesis.

Phronesis is designed to provide guidance to human decision-makers.

It should not be used to make solely automated decisions about individuals that produce legal or similarly significant effects without appropriate human consideration and review.

Employment decisions remain the responsibility of the employer or other organisation making them.

9. Technology and service providers

We use specialist technology suppliers to operate Phronesis.

Depending upon the services and functionality being used, these may include:

Pickaxe — application and AI workflow infrastructure.

OpenAI and/or other approved AI model providers — artificial-intelligence processing used to generate Phronesis responses.

Vercel — application hosting, API and authentication infrastructure.

Resend — transactional email services, including account verification and service-related emails.

Neon — database infrastructure, including storage of account-related contractual acceptance records where implemented.

Payment service providers — processing payments for paid Phronesis services.

These organisations may act as processors, sub-processors or, in some circumstances, independent controllers depending upon the service being provided.

Our technology infrastructure and suppliers may change as Phronesis develops.

10. Email verification and service communications

When you register for Phronesis, we may send communications necessary to create, verify, secure or administer your account.

These are service communications and not marketing communications.

They may include:

  • email verification links;

  • account security messages;

  • important service notifications;

  • information about material changes affecting your account;

  • usage or account notifications; and

  • information necessary to administer a purchase.

Receiving these communications does not mean that you have consented to receive marketing.

11. Marketing communications

Where we send electronic marketing communications to identifiable individuals, we will do so in accordance with applicable data-protection and electronic-marketing law.

Where consent is required, marketing consent will be requested separately.

Creating a Phronesis account or accepting the Phronesis Terms of Use does not automatically opt you into marketing.

Where applicable, you can unsubscribe from marketing communications using the unsubscribe facility provided or by contacting us.

Service communications necessary to administer your Phronesis account may continue even if you opt out of marketing.

This is separate from our ability to use appropriately aggregated or anonymised Phronesis usage statistics in our own marketing, research, reports and publicity as described in Section 4.

12. Cookies and authentication

Phronesis may use cookies or similar technology where necessary to:

  • keep users securely signed in;

  • maintain authenticated sessions;

  • protect accounts;

  • remember essential preferences; and

  • operate the service.

Some cookies are essential for Phronesis to function.

Where non-essential cookies or similar technologies requiring consent are used, we will provide appropriate information and seek consent where required.

13. International processing and transfers

Phronesis uses cloud, application and artificial-intelligence technology supplied by organisations that may operate infrastructure in the United Kingdom, European Economic Area, United States or other countries.

Personal information may therefore, in some circumstances, be processed outside the United Kingdom.

Where personal information protected by UK data-protection law is transferred internationally, we will seek to ensure that an appropriate transfer mechanism or other safeguard required by applicable law is in place.

Depending upon the circumstances, this may include UK adequacy regulations, recognised contractual safeguards or another legally permitted transfer mechanism.

14. How long we retain information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to satisfy legal, contractual, security and legitimate business requirements.

Account information will normally be retained while an account remains active and for an appropriate period afterwards.

Contractual acceptance records may be retained for longer where reasonably necessary to demonstrate which terms governed your use of Phronesis.

Information associated with Phronesis interactions will be retained in accordance with our applicable service configuration, supplier arrangements and retention requirements.

Information used to create statistical analysis may subsequently be retained in aggregated or effectively anonymised form.

Where information is no longer required, we will delete or anonymise it where reasonably practicable, subject to applicable legal or regulatory requirements.

15. Security

We use technical and organisational measures intended to protect personal information against unauthorised access, alteration, disclosure, destruction or loss.

Depending upon the relevant system, these measures may include:

  • secure authentication;

  • restricted access;

  • encryption in transit;

  • appropriate access controls;

  • secure cloud infrastructure;

  • supplier due diligence;

  • security monitoring; and

  • appropriate contractual safeguards.

No internet-based service can guarantee absolute security, but we aim to apply safeguards proportionate to the nature and sensitivity of the information processed.

16. Sharing personal information

We do not sell personal information.

We may share personal information where reasonably necessary with:

  • technology providers used to operate Phronesis;

  • professional advisers;

  • payment providers;

  • regulators or public authorities where legally required;

  • law-enforcement bodies where disclosure is lawful and necessary; and

  • another organisation in connection with a legitimate corporate restructuring, acquisition or sale, subject to appropriate safeguards.

Where suppliers process personal information on our behalf, we seek to ensure appropriate data-protection arrangements are in place.

17. SME HR Consultancy and human support

Phronesis may identify circumstances where obtaining human HR support would be sensible.

In those circumstances, you may be offered the opportunity to obtain support from SME HR Consultancy Ltd.

A Phronesis Red Alert or recommendation to seek human support does not automatically transfer your case information to SME HR Consultancy and does not oblige you to purchase consultancy services.

Where you choose to obtain consultancy support and information needs to be shared to provide that service, the relevant arrangements will be explained to you.

SME HR Consultancy may act as a separate data controller in relation to consultancy services it provides directly to you.

18. Your data-protection rights

Depending upon the circumstances, UK data-protection law may give you rights including:

  • the right to be informed about how personal information is used;

  • the right to access your personal information;

  • the right to have inaccurate information corrected;

  • the right to request deletion in certain circumstances;

  • the right to restrict processing in certain circumstances;

  • the right to data portability where applicable;

  • the right to object to certain processing; and

  • rights relating to automated decision-making.

These rights are not absolute and may depend upon the circumstances and applicable legal requirements.

To exercise a right, contact us using the details below.

19. Information about other people

If you believe that another Phronesis user has submitted personal information about you, you may contact us.

We will consider requests in accordance with applicable data-protection law and taking into account the respective responsibilities of Stroika International Ltd and the organisation that submitted the information.

20. Complaints

If you have concerns about how we use personal information, please contact us first so that we have an opportunity to investigate.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.

Information about the ICO and how to make a complaint is available at www.ico.org.uk.

21. Changes to this Privacy Notice

We may update this Privacy Notice to reflect changes to Phronesis, our technology, suppliers, processing activities or applicable law.

The current version and effective date will appear at the top of this page.

Where a material change affects how we process personal information, we will take appropriate steps to notify affected users.

Where appropriate, users may be asked to acknowledge a revised Privacy Notice or accept revised Terms of Use.

22. Contact us

For questions about this Privacy Notice or the way Phronesis uses personal information, please contact:

Stroika International Ltd
Phronesis
United Kingdom

Website: www.phronesis.org.uk

Privacy email: marc@phronesis.org.uk