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Privacy Policy

Effective date: 25 March 2025

Version: v1.0

1. Data Controller

Indexeli Intelligence Limited (“we”, “us”, “our”) is the data controller for personal data processed through supplyindex.io (“SupplyIndex”, “the Service”). Registered in England and Wales. For data protection enquiries, contact our DPO at dpo@supplyindex.io.

2. What Data We Collect

  • Account data: Name, email address, practice name, postcode, CQC/GDC registration numbers.
  • Invoice data: Supplier invoices you upload, including supplier names, product names, quantities, and prices (ex-VAT, GBP pence).
  • Usage data: Pages visited, features used, timestamps — for product improvement only.
  • Price entries: Product prices you manually enter for benchmarking.
  • Consent records: Timestamped records of your data sharing and marketing consent choices, including IP address and browser user agent at the time of consent, retained as a consent history.

3. How We Use Your Data

  • To provide pricing benchmarks aggregated across all participating practices.
  • To verify invoice authenticity and prevent fraud.
  • To send membership and service emails (benchmark updates, invoice confirmations, access grants, and alerts).
  • To improve our benchmark accuracy and product matching.

We never sell your data. We never share identifiable pricing data with other practices or suppliers.

4. Data Sharing with Third Parties

We may share anonymised, aggregated data with the following categories of third parties:

  • Commercial partners: Aggregated market intelligence reports and benchmarking data for industry analysis. No data shared can identify individual practices, their pricing, or their supplier relationships.
  • Regulatory bodies: Anonymised, aggregated supply chain data that may be used for market oversight and policy research.
  • Industry bodies: Aggregated benchmarking data for sector reports and publications.

All shared data is subject to the same minimum thresholds applied throughout the platform: a minimum of 5 practices and 5 data points must contribute to any aggregated figure. This ensures no individual practice can be identified from shared data.

We will never share your raw invoice images, identifiable pricing data, or practice-level information with any third party.

5. Legal Basis (UK GDPR)

  • Contract: Processing necessary to provide the benchmarking service you signed up for, including integral account, service, and benchmark updates.
  • Legitimate interest: Aggregated benchmarking across participating practices, fraud prevention, product improvement, and maintaining data quality. We have conducted a legitimate interest assessment and concluded that the benefits to practice owners (transparent pricing) outweigh any limited privacy impact, given that all outputs are anonymised and aggregated.
  • Consent (data sharing): At registration, you explicitly consent to your anonymised supply chain data being used for industry benchmarking and shared with regulatory and commercial partners in aggregated form. You may withdraw this consent at any time by contacting dpo@supplyindex.io.
  • Consent (marketing): Deals, offers, and optional promotional product news are only sent if you opt in. You can unsubscribe at any time via the link in any marketing email or in Settings.

6. Data Storage and Security

  • Invoice files stored on Cloudflare R2 with encryption at rest.
  • Database hosted on Neon Postgres with TLS encryption in transit.
  • All benchmark queries aggregate across a minimum of 5 practices and 5 data points.
  • Supplier accounts cannot access individual practice pricing data.

7. Data Retention

  • Invoice image files: deleted after 24 months from upload date.
  • Extracted pricing data: retained in anonymised, aggregated form indefinitely for benchmark accuracy.
  • Account data: retained while your account is active, deleted within 30 days of account closure.
  • Audit logs: retained for 36 months for security and compliance.
  • Consent audit records: retained indefinitely as evidence of consent under UK GDPR.

8. Your Rights

Under UK GDPR, you have the right to:

  • Access: Request a copy of all personal data we hold about you.
  • Rectification: Correct inaccurate personal data.
  • Erasure: Request deletion of your personal data (subject to legal retention obligations).
  • Portability: Receive your data in a machine-readable format.
  • Objection: Object to processing based on legitimate interest.
  • Restriction: Request restricted processing while we address your concerns.

To exercise any right, email dpo@supplyindex.io. We respond within 30 days.

9. Erasure Process

To request full account deletion:

  1. Email dpo@supplyindex.io with subject “Erasure Request” from your registered email.
  2. We verify your identity and process the request within 30 days.
  3. We delete: your account, practice profile, uploaded invoice files, manual price entries, and any prices you contributed without an account.
  4. We retain: anonymised, aggregated benchmark data that cannot be linked back to you (this is no longer personal data under GDPR).

10. Prices You Contribute

Anyone at a practice can tell us what they paid for a product at supplyindex.io/contribute, without an account.

What we collect: the product, the price you paid, the date, and optionally who you bought it from; your work email; and optionally your practice name and postcode. We keep a one-way hash of your IP address to spot automated abuse, not the address itself. If you upload an invoice instead, we store the file securely and use automated extraction (Anthropic’s Claude) to read the products and prices from it; a member of our team checks the result before any price is used, and the invoice is never shared beyond SupplyIndex and the processors listed below.

Why we need your email: to confirm a real person at a real practice sent the prices. It decides how much your prices count towards a benchmark — a confirmed practice email counts most — and we send one email with a confirmation link. We do not add you to any mailing list.

How prices are used: only in anonymised benchmarks, published as a range once at least 5 prices from at least 5 practices exist. Your prices are never shown individually, never linked to your practice or email, and never shared with a supplier. Who you bought from is used only in our own analysis and is never shown next to a price.

Lawful basis and retention: legitimate interests in producing accurate, anonymised benchmarks. Prices older than twelve months stop counting towards benchmarks. Ask us at dpo@supplyindex.io and we will delete your email and prices.

11. Research Surveys

We occasionally run research surveys — for example the aesthetic device survey, which asks equipment owners what they paid, what servicing costs and how often their machines break down. Taking part is voluntary and open to non-members.

What we collect: your answers about the equipment and your practice, whether you are planning to buy in the next twelve months and what interests you, plus a work email address. Responses are confidential rather than anonymous: we ask for the email so we know each response comes from a real clinic, which is what makes the published findings trustworthy. Your clinic name and your own name are optional. Every question except the device type, the price band and the email is optional.

Marketing is separately consented. Your email is required to submit, but what we may send you is not assumed from that. Each checkbox is independent: sending you the findings, quoting your written comment anonymously, joining the deals mailing list, and hearing about equipment and finance offers are four separate permissions, and ticking one never implies another. Untick them all and we will not contact you at all.

Your identity is never published. Knowing who responded is for our verification and follow-up only — it is never shown to another clinic, never attached to a published figure, and never shared with a supplier.

How findings are published: as aggregates only — ranges, medians and percentages. We never publish an individual response, never name a practice, and never report a group of fewer than five respondents, because below that an individual becomes identifiable. Written comments are published only where you have consented, and only without identifying detail.

Who does not get it: suppliers, manufacturers and distributors are never given access to survey responses — not individually, and not for their own products. We do not sell survey data.

Lawful basis: consent, which you may withdraw at any time by emailing dpo@supplyindex.io. Withdrawal removes your response from future analysis; findings already published as anonymised aggregates cannot be unpicked, as they are no longer personal data.

Retention: individual responses are kept for the life of the research programme so waves can be compared year on year, then deleted. Ask us to erase yours sooner and we will.

12. Cookies

Essential cookies: We use a small number of strictly necessary cookies to keep you signed in and to remember your cookie preferences. These are always active and require no consent under UK PECR.

Cookie-free analytics: We use Clicky to count visits and see which pages are read. It runs with cookies disabled — it stores nothing on your device and reads nothing from it — so it needs no consent and runs for everyone. It does process your IP address, which is personal data, on the basis of our legitimate interest in knowing whether the site works. It does not identify you and we do not use it to build a profile of you.

Analytics cookies: We use Google Analytics for more detailed analysis. Its cookies are only set after you actively accept them via the cookie banner. If you decline — or take no action — no analytics cookies are placed and Google Analytics does not load. You can change your choice at any time by clearing the site’s cookies in your browser.

Advertising cookies: We advertise to practice owners, and use the LinkedIn Insight Tag and Google Ads conversion tracking to measure which advertising leads to an enquiry, and to show our ads to people who have visited the site. These are advertising and cross-site tracking technologies. Like everything else here, they load only after you actively accept cookies, and not at all if you decline or take no action. We never sell your data.

Business visitor identification: We use Leadsy (VTag) to identify the organisation a business visitor is browsing from, so we can tell which kinds of practice are interested in us. Like analytics, it loads only after you actively accept cookies, and not at all if you decline or take no action. It identifies organisations, not named individuals, and we do not use it to build profiles of identified people or to contact individuals who have not asked to hear from us.

13. Third-Party Processors

  • Neon (database): EU-hosted PostgreSQL.
  • Cloudflare R2 (file storage): EU region.
  • Anthropic (AI extraction): Invoice content sent for automated data extraction. No data retained by Anthropic beyond the API call.
  • Resend (email): Transactional email delivery.
  • Vercel (hosting): Application hosting.
  • Stripe (payments): Supplier subscription billing only.

14. Contact

Data Protection Officer: dpo@supplyindex.io

General enquiries: hello@supplyindex.io

You have the right to lodge a complaint with the ICO (ico.org.uk) if you believe your data rights have been infringed.