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Privacy Policy

Effective Date: January 31, 2026

Introduction

PassWithAI Limited (trading as Dialoro) (“we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and share your personal data when you use our services, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Important Information and Who We Are

1.1 Controller

PassWithAI Limited is the Data Controller and is responsible for your personal data.

  • Company Number: 16288293
  • Registered Address: 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ
  • Email: support@dialoro.com

1.2 Contact Details

If you have any questions about this Privacy Policy, please contact us at support@dialoro.com.

1.3 Changes to the Privacy Policy

We keep our privacy policy under regular review. This version was last updated on January 31, 2026.

2. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data

Your mobile phone number (which acts as your primary user identifier). In rare cases of suspected fraud, we may temporarily collect copies of government-issued ID or utility bills.

Financial Data

We process payments via third-party payment processors. We do not store full credit/debit card numbers on our servers. We retain records of your top-ups, wallet balance, and transaction history.

Transaction Data

Details of the calls you make using our Service, including the destination number, date, time, duration of the call, and the cost incurred.

Technical Data

Internet Protocol (IP) address, login data, device type, time zone setting, operating system, and platform.

Usage Data

Information about how you use our website and Service, including error logs and performance metrics.

3. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

To register you as a new customer

Data: Identity Data

Lawful Basis: Performance of a Contract — We need your number to create your account and verify your device.

To deliver the Service

Data: Identity, Transaction, Financial Data

Lawful Basis: Performance of a Contract — We cannot provide the Service without processing this data.

To prevent fraud and money laundering

Data: Identity, Usage, Transaction Data

Lawful Basis: Legal Obligation — Compliance with anti-money laundering laws. Legitimate Interest — Protecting our business from fraudulent use.

To manage our relationship with you

Data: Identity, Contact Data

Lawful Basis: Performance of a Contract. Legal Obligation — To notify you of material changes.

To comply with regulatory requirements

Data: Transaction, Identity Data

Lawful Basis: Legal Obligation — Compliance with Ofcom General Conditions and data retention laws.

To improve our website and services

Data: Technical, Usage Data

Lawful Basis: Legitimate Interest — To keep our Service updated, secure, and relevant.

4. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in Section 3.

  • Telecommunications & SMS Providers: To route your calls and send verification SMS messages.
  • Payment Processors: To securely process your top-ups and manage credit balances.
  • Cloud Infrastructure & Analytics Providers: To host our Service, monitor performance, and detect technical errors.
  • Law Enforcement & Regulators: If we are required to do so by law, or if we reasonably believe disclosure is necessary to prevent, detect, or investigate serious crime or prevent serious harm.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International Transfers

We use external service providers to facilitate our Service. Some of these providers are based outside the UK and the European Economic Area (EEA), specifically in the United States.


Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Adequacy Decisions: Transferring data to countries deemed to provide an adequate level of protection by the UK Government.
  • Standard Contractual Clauses (SCCs) / UK International Data Transfer Agreement (IDTA): Where we use providers based in the US or other non-adequate jurisdictions, we use specific contracts approved by the UK ICO which give personal data the same protection it has in the UK.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Access to your personal data is limited to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

Call Metadata

Retained for 12 months from the date of the call, as required for regulatory compliance and fraud prevention.

Account Data

Retained for the lifetime of your account. If your account is inactive for 12 months, your balance will expire. We may retain basic account records for up to 6 years after you cease being a customer for tax and legal purposes.

Identity Verification Documents

If you are asked to provide ID documents for fraud checks, the copies are deleted immediately after the verification decision is made. A text record of the check outcome will be retained for the lifetime of the account.

8. Your Legal Rights

Under the UK GDPR, you have rights in relation to your personal data, including the right to access, correct, or erase your data, and the right to object to processing.


Please note that Right to Erasure is not absolute. We may be legally required to retain certain data (such as call metadata for 12 months) even if you ask us to delete it.


To exercise any of these rights, please contact us at support@dialoro.com. We aim to respond to all legitimate requests within one month.

9. Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.