Website: brainyboilers.com Operator: Carpe Lab LTD Last updated: 3 March 2026
1. Who we are
This website, brainyboilers.com, is owned and operated by Carpe Lab LTD, a company registered in England & Wales.
- Company number: 16941453
- Registered office: 124 City Road, London, England, EC1V 2NX
- ICO registration: ZC101041
- Contact: legal@carpe-lab.com
Carpe Lab LTD is the data controller for personal data collected through this website.
When you proceed with a boiler quote and purchase, you enter into a contract with our installation partner. Our current installation partner is Ewan McLean LTD t/a Brainy Boilers, registered in Scotland (SC452002), with a registered office at Unit 17, Kirkcaldy, Scotland, KY1 3PF. Ewan McLean LTD becomes an independent data controller for the personal data required to fulfil your installation and, where applicable, arrange finance.
2. What data we collect
We collect different data at different stages of your journey on our site.
When you browse the site
- IP address and approximate location
- Browser type, device, and operating system
- Pages visited, time spent, and referral source
- Cookie identifiers (see our Cookie Policy)
When you use our AI quote assistant
- Your name, email address, and phone number
- Your postcode and property details (e.g. property type, number of bedrooms, number of bathrooms)
- Your heating requirements and preferences
- Full transcripts of your text chat conversations with our AI assistants
- Recordings of voice conversations conducted through our AI voice assistant
- Technical metadata related to your chat or voice session (e.g. session IDs, timestamps)
When you save your quote (before boiler selection)
After you complete the property questions, we ask for your mobile number (required) and optionally your email before showing you boiler options. We use this to:
- Text you a link to your quote so you can come back to it later
- Contact you by text or phone if you don't get a chance to finish your quote
Your phone number is shared with your local installation partner so they can follow up with you about your quote. We only collect this after you tick a box to confirm you're happy for Brainy Boilers and our installation partner to contact you by text or phone. We won't share your number with anyone else.
When you make a purchase or arrange finance
- Payment card or bank details (processed securely by Stripe — we do not store your full payment details)
- Information required for credit applications, which is collected and processed by Ewan McLean LTD and their finance partner, Shermin Finance
3. How we use your data
We use your personal data for the following purposes:
Carpe Lab LTD (platform operator)
| Purpose | Legal basis |
|---|---|
| Operating and improving brainyboilers.com | Legitimate interest |
| Providing the AI quote and recommendation service | Contract performance (taking steps prior to entering a contract) |
| Sharing your details with our installation partner so they can fulfil your quote and installation | Legitimate interest / Contract performance |
| Analytics and understanding how visitors use the site (via PostHog, Google Analytics) | Legitimate interest |
| Marketing and advertising measurement (via Meta Pixel) | Consent (via cookie banner) |
| Monitoring and improving our AI assistants using chat transcripts and voice recordings | Legitimate interest |
| Contacting you about your quote or enquiry | Legitimate interest / Contract performance |
Ewan McLean LTD (installation partner)
Once your data is shared with Ewan McLean LTD, they become an independent data controller. They use your data to:
- Provide you with a boiler installation quote and carry out the installation
- Arrange finance on your behalf (as an FCA-authorised credit broker, FRN: 767734) via Shermin Finance
- Contact you regarding your booking, installation, and aftercare
- Comply with legal and regulatory obligations
Ewan McLean LTD's use of your data is governed by their own privacy practices. For queries about how they handle your data, contact them directly at [EWAN MCLEAN CONTACT DETAILS].
4. AI-specific data handling
Our site uses AI assistants to help you get a boiler quote and recommendation. You should be aware of the following:
Chat transcripts — All text conversations with our AI assistants are recorded and stored. These transcripts are used to provide the quote service, improve our AI systems, and for quality assurance.
Voice recordings — If you use our voice assistant, your conversation is recorded and stored. Recordings are used to deliver the service, improve voice recognition and AI responses, and for quality assurance.
AI processing — Your conversations are processed by third-party AI services (see section 6) in order to generate responses. The content of your conversations may be used to improve our AI assistants, but it is not used to train third-party AI models.
You can request deletion of your chat transcripts and voice recordings at any time by contacting us (see section 10).
5. Who we share your data with
We share your personal data with the following categories of third parties:
Installation partners
- Ewan McLean LTD — to fulfil your boiler quote, installation, and (where applicable) finance arrangement. They become an independent data controller for this data.
Payment processors
- Stripe — to securely process payments. Stripe acts as an independent data controller for payment data. See Stripe's privacy policy.
Finance providers
- Shermin Finance — if you apply for finance, your data is shared by Ewan McLean LTD with Shermin Finance to arrange credit. This is handled under Ewan McLean LTD's data controllership.
Analytics and marketing
- PostHog — product analytics (data processor)
- Google Analytics — website analytics (data processor / independent controller — see Google's privacy policy)
- Meta (Facebook) Pixel — advertising measurement and retargeting (independent controller — see Meta's privacy policy)
AI and infrastructure
- Anthropic — AI language model provider used to power our chat and voice assistants (data processor)
- LiveKit — real-time voice infrastructure for our voice assistant (data processor)
Monitoring and quality
- LangFuse — AI interaction monitoring and quality assurance (data processor)
We do not sell your personal data to any third party.
6. Cookies and tracking
We use cookies and similar technologies on our site. For full details, see our Cookie Policy.
In summary:
- Essential cookies are required for the site to function and cannot be disabled.
- Analytics cookies (PostHog, Google Analytics) help us understand how visitors use the site. These are set based on your consent preferences.
- Marketing cookies (Meta Pixel) are used for advertising measurement and retargeting. These are only set with your consent.
You can manage your cookie preferences at any time via the cookie banner or by adjusting your browser settings.
7. Data retention
We retain your personal data for as long as necessary for the purposes set out in this policy:
| Data type | Retention period |
|---|---|
| Browsing and analytics data | 26 months |
| Quote enquiry data (name, contact details, property info) | 3 years from last interaction |
| Chat transcripts | 2 years |
| Voice recordings | 12 months |
| Payment records | 7 years (legal/tax requirement) |
| Cookie consent records | 2 years |
After these periods, data is securely deleted or anonymised. Ewan McLean LTD applies their own retention periods to data held under their controllership.
8. Data transfers
Some of the third-party services listed in section 5 are based outside the UK. Where your data is transferred outside the UK, we ensure appropriate safeguards are in place, including:
- UK International Data Transfer Agreements (IDTAs)
- Standard Contractual Clauses (SCCs)
- Transfers to countries with an adequacy decision from the UK Secretary of State
9. Your rights
Under UK GDPR, you have the following rights:
- Access — request a copy of the personal data we hold about you
- Rectification — ask us to correct inaccurate data
- Erasure — ask us to delete your data (subject to legal obligations)
- Restriction — ask us to limit how we use your data
- Portability — request your data in a portable format
- Object — object to processing based on legitimate interest
- Withdraw consent — where processing is based on consent (e.g. marketing cookies), you can withdraw it at any time
To exercise any of these rights, contact us at legal@carpe-lab.com.
We aim to respond to all requests within one month. If your request is complex, we may extend this by a further two months, and we will let you know.
10. Contact us
If you have any questions about this privacy policy or how we handle your data:
Carpe Lab LTD 124 City Road, London, England, EC1V 2NX Email: legal@carpe-lab.com
If your query relates to your boiler installation, finance arrangement, or the service provided by Ewan McLean LTD, please contact them directly at [EWAN MCLEAN CONTACT DETAILS].
11. Complaints
If you are unhappy with how we have handled your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
- Website: ico.org.uk
- Helpline: 0303 123 1113
We would appreciate the opportunity to address your concerns before you contact the ICO, so please reach out to us first.
12. Changes to this policy
We may update this privacy policy from time to time. Any changes will be posted on this page with an updated "Last updated" date. Where changes are significant, we will make reasonable efforts to notify you.