Privacy Policy
Last updated: {{EFFECTIVE_DATE}}
This Privacy Policy explains how {{COMPANY_LEGAL_NAME}} ("Estate Ops", "we", "us", "our") collects and uses personal data through the Estate Ops web portal at https://neal-gold.vercel.app and the Estate Ops mobile application for iOS and Android (together, the "Service").
Estate Ops is software provided to estates and similar organisations (each an "Estate") to manage operations including mapping, records, assets, jobs, hours, visitors and field-worker safety.
Our two roles
Data protection law (the UK GDPR and the Data Protection Act 2018) distinguishes between a "controller" (who decides why and how personal data is used) and a "processor" (who acts on a controller's instructions). Our role depends on the data:
- As a processor. When an Estate uses the Service, that Estate is the
controller of the personal data its staff, contractors and family contacts put into the Service (for example names, roles, locations, photos, records and safety events). We process that data on the Estate's behalf and on its instructions under our Data Processing Agreement. If you are a member of staff, a contractor or a family safety contact, your Estate is responsible for your data and you should read its own privacy notice first; ours explains what we do as its processor.
- As a controller. We are the controller of the personal data we decide how to
use ourselves: the account and contact details of the people who administer or buy the Service, billing information, support correspondence, website-visitor data, and the diagnostic data we collect to keep the Service secure and working.
This Policy covers both roles. Where we say "we collect" below, the legal basis table notes whether we act as controller or processor.
Who we are
- Controller: {{COMPANY_LEGAL_NAME}}, a company registered in England and Wales
(company number {{COMPANY_NUMBER}}).
- Registered office: {{REGISTERED_ADDRESS}}.
- ICO registration number: {{ICO_REGISTRATION_NUMBER}}.
- Privacy contact: {{PRIVACY_EMAIL}}.
- Data protection point of contact: {{DPO_CONTACT}}.
The personal data we handle
The Service is designed to capture only what an Estate needs to operate. Depending on how your Estate configures it, the Service may handle:
- Account and identity data — display name, username, email address, role,
department, the Estate you belong to, and an encrypted (hashed) password held by our authentication provider.
- Contact data — phone numbers and names recorded as safety contacts, and the
email addresses we send invitations to.
- Location data — GPS coordinates captured when a user places a map pin
(collected on demand, not continuously), the location history attached to pins, the location associated with an active lone-worker session, and the location included in an SOS alert (latitude, longitude and accuracy).
- Safety and incident data — SOS events, lone-worker check-in status, and
alerts generated by the in-app fall-detection feature. The fall-detection feature analyses motion-sensor readings on your device to decide whether to raise an alert; the raw sensor stream is not transmitted to or stored by us. We treat safety and incident data as sensitive and protect it accordingly.
- Photos and media — photographs you capture or attach to pins, assets,
vehicles, visitor records and similar features.
- Device and technical data — a push-notification token for your device,
app version, device type, IP address, and log and diagnostic data.
- Usage data — actions taken in the Service and timestamps such as when an
account was last active, used to operate features and keep audit records.
We do not use the Service to run advertising, and we do not sell personal data.
Why we use it, and our lawful bases
| Purpose | Lawful basis (UK GDPR) | Our role |
|---|---|---|
| Providing the Service to an Estate and its users | Processing on behalf of the Estate; the Estate relies on contract / legitimate interests | Processor |
| Creating and administering accounts; billing the Estate | Contract; legitimate interests (running our business) | Controller |
| Field-worker safety: lone-worker monitoring, SOS dispatch, fall alerts | The Estate's lawful basis (commonly legitimate interests in worker safety; vital interests in a genuine emergency) | Processor |
| Sending an SOS alert to safety contacts in an emergency | Vital interests (protecting someone's life) | Processor |
| Securing the Service, preventing abuse, diagnosing faults | Legitimate interests (security and reliability) | Controller |
| Responding to support requests | Legitimate interests; contract | Controller |
| Meeting our legal and regulatory obligations | Legal obligation | Controller |
Where we rely on legitimate interests, we have weighed those interests against your rights and freedoms. You can ask us for our assessment using the contact details above.
Special category and safety-critical data
Some safety data (for example an SOS event combined with location, or a fall alert) may reveal information about a person's health or wellbeing. We process this only to deliver the safety features the Estate has enabled, and only as the Estate's processor. Estates are responsible for ensuring they have a valid condition for processing this data under UK GDPR Article 9 and for informing their people; we assist them through our Data Processing Agreement.
How we share data
We share personal data only as needed to run the Service:
- Within your Estate — for example, an SOS alert is sent to the safety
contacts and managers your Estate has configured, and a worker's last known location may be visible to authorised managers.
- With our sub-processors — service providers that host and operate parts of
the Service under contract and on our instructions. The current list, what each does and where it is located is published at Sub-processors.
- For legal reasons — where we must comply with the law, a court order or a
regulator, or to protect our rights, users or the public.
- On a business transfer — if we reorganise, merge or sell the business, in
which case personal data may transfer subject to this Policy.
We do not share personal data with third parties for their own marketing.
International transfers
We aim to keep personal data in the UK or European Economic Area wherever possible. Some of our sub-processors are based outside the UK (for example in the United States). Where personal data is transferred outside the UK, we rely on a transfer mechanism recognised by UK law — typically the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, together with any additional safeguards needed. Details are noted on the Sub-processors page.
How long we keep it
We keep personal data only as long as needed for the purposes above:
- Account and operational data is retained while the Estate's subscription is
active and for a limited period afterwards, then deleted or anonymised, unless we must keep it longer to meet a legal obligation.
- Safety, incident and audit records are retained for the period the Estate
sets in line with its own obligations.
- Invitations expire automatically after a short, fixed period if unused.
- Diagnostic data is retained for a short period for security and debugging.
Our detailed schedule is set out in our internal Data Retention Policy and in the Data Processing Agreement with each Estate.
Your rights
Under UK data protection law you have the right to: be informed; access a copy of your data; have inaccurate data corrected; have data erased; restrict or object to processing; and data portability. You also have the right not to be subject to a decision based solely on automated processing that has a legal or similarly significant effect — the Service does not make such decisions.
Because much of the data in the Service belongs to your Estate (we are the processor), the quickest route is usually to contact your Estate. If you contact us directly, we will help and, where appropriate, pass your request to the relevant Estate. To exercise a right, contact {{PRIVACY_EMAIL}}. We respond within one month.
You can also ask us to delete your account: see Account deletion.
If you are unhappy with how we handle your data, you can complain to the Information Commissioner's Office (ICO) at https://ico.org.uk, by calling 0303 123 1113, or by writing to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would appreciate the chance to address your concern first.
Security
We use technical and organisational measures appropriate to the risk, including encryption of data in transit, row-level access controls so users only see data for their Estate and role, encrypted storage of credentials on devices, and access controls and logging on our systems. No system is perfectly secure, but we work to protect your data and to detect and respond to incidents.
Children
The Service is intended for use by adults (aged 18 or over) in a workplace or estate-management setting. It is not directed at children, and we do not knowingly collect data from children. If you believe a child's data has been provided to us, contact {{PRIVACY_EMAIL}} and we will act with the relevant Estate.
Cookies and diagnostics
The web portal uses a small number of strictly necessary cookies to keep you signed in, and stores limited preferences on your device. We use a diagnostics provider to detect and fix errors. See our Cookie Policy for details and your choices.
Changes to this Policy
We may update this Policy from time to time. We will change the "Last updated" date above and, for significant changes, take reasonable steps to let affected Estates know.
Contact us
Questions about this Policy or your data: {{PRIVACY_EMAIL}}, or write to us at {{REGISTERED_ADDRESS}}.