AI and Automated Decision Making Notice

AI and Automated Decision Making Notice

This Notice explains how Substantial Group Limited and its subsidiaries listed in our Privacy Policy use artificial intelligence (“AI”) and other automated technologies when providing and managing our services.

It supplements our Privacy Policy, which explains more generally how we collect and use your personal data, the legal bases on which we process it and your data protection rights.

How we use AI

We use AI and automated technologies to help us provide, manage and improve our services. These technologies may be used to:

• provide customer support and respond to customer enquiries;
• assist with and carry out actions relating to customer accounts;
• analyse information relating to our customers and services;
• identify issues, risks or unusual activity;
• make predictions, recommendations, classifications or other assessments; and
• make or support decisions relating to our customers and services.

The ways in which we use AI will develop over time. We will update this Notice where we introduce material new uses of AI involving personal data.

What personal data do we use?

Depending on the particular use of AI, we may process information including your Identity Data, Contact Data, Transaction Data, Usage Data, Technical Data, Profile Data and information contained in your communications with us.

Further information about these categories of personal data and how we collect them is available in our Privacy Policy.

AI systems may also generate information about you from the information available to them, such as recommendations, classifications, predictions or other assessments.

How do we use AI to make decisions?

Some of our AI systems may make or support decisions or take actions relating to you. The table below provides further information about the material ways in which we currently use these technologies.

Automated decisions which significantly affect you

We may use automated technologies to make decisions without meaningful human involvement.

Where applicable, we will put appropriate safeguards in place, including providing you with information about the decision and enabling you to make representations about the decision and obtain human intervention.

These may include giving you the opportunity to:

• ask us to review the decision;
• obtain human intervention;
• provide additional information or express your point of view; and
• challenge the decision.

Details of any significant automated decisions we currently make are identified in the table above.

Your rights

You have rights in relation to your personal data, including rights of access, correction, erasure, restriction and objection in certain circumstances which are described in the Your Legal Rights section of our Privacy Policy.

Where we make a decision about you based solely on automated processing which produces a legal or similarly significant effect on you, you also have additional rights and safeguards. These include the right to:

• receive information about the decision;
• make representations to us about the decision; and
• obtain human intervention in relation to the decision.

You can contact us if you believe an automated decision is incorrect or would like us to reconsider it. We will consider any information you provide as part of that review.

Contact us

If you have any questions about our use of AI or automated decision-making, or wish to ask for human review of an automated decision, please contact us using the details in our Privacy Policy.

Last updated 27 October 2026