Draft for legal review. Not yet in force. Text in [square brackets] must be completed before launch.
Who we are
BH Case Manager is run by [legal entity name], [registered address] ("we", "us"). We are the controller of the personal data described here. Our ICO registration number is [number]. Contact us about privacy at [privacy@example.com].
What this service does
BH Case Manager is a place to keep a record of your own complaints and disputes with businesses: notes, tasks, contacts, documents and emails you choose to add. You decide what goes in. We don't read your cases, and we don't use their contents for advertising, profiling or training AI models.
What we collect and why
| Data | Why | Lawful basis |
|---|---|---|
| Your name, email address and password (stored as a hash by our sign-in provider) | To create and secure your account | Contract |
| Two-step verification settings | To protect your account | Contract; legitimate interests (security) |
| Case content you add: notes, tasks, people and organisations, documents, imported emails | To provide the service you've asked for | Contract |
| Information about other people that you put in your cases (for example a company's staff, or someone helping you) | To provide the service to you | Our legitimate interest in providing a service that lets you keep records of your own disputes; see "Other people's information" |
| Gmail messages you choose to import, and an encrypted token for your mailbox connection | To copy chosen emails into a case | Contract; you can disconnect at any time |
| Billing details (handled by Stripe; we see your plan, billing country and the last four digits of your card) | To take payment and keep tax records | Contract; legal obligation |
| Support requests | To help you | Contract; legitimate interests |
| Technical logs (time, IP address, browser, the page requested, errors) | To keep the service running and secure | Legitimate interests |
| An activity record of important changes in shared workspaces | So workspace owners can see what changed | Legitimate interests |
We use only cookies that are strictly necessary to sign you in and remember which workspace you were using. We don't use advertising or analytics cookies.
Other people's information
Your cases will often mention other people. You are responsible for adding only what you need for your dispute. If someone asks us about information a customer holds about them, we'll pass the request to that customer where we can, because they decide what their case file contains.
Gmail
If you connect a Google mailbox, we ask Google for read-only access. We only fetch messages when you search or import, and we only store the messages you choose to import. Our use of information received from Google APIs follows the Google API Services User Data Policy, including the Limited Use requirements. We don't use Gmail data for advertising, we don't sell it, we don't let people read it except where you ask us to help with a specific problem and give permission, where it's needed for security, or where the law requires it, and we don't use it to train AI models. You can disconnect in your account settings or at myaccount.google.com/permissions.
Who we share data with
We use these suppliers to run the service. Each acts on our instructions under a data processing agreement.
The current list, with what each one handles and where, is on our sub-processors page.
Some of these suppliers process data outside the UK, including in the United States and the European Economic Area. Where they do, we rely on UK adequacy regulations or the UK International Data Transfer Addendum, as appropriate. We don't claim that all data stays in the UK.
We never sell your data. We may disclose information if the law requires it.
Support access
Our staff can't see your cases by default. If fixing a problem in a shared workspace needs us to look, access is read-only, time-limited (usually one hour), every owner is told by email, and it's shown in that workspace's activity record. Owners can end it at any time.
How long we keep data
- Your account and cases: while your account is open. Documents you delete go to a bin and are removed after 30 days. When a workspace is closed, it's kept for the period its owner chose (30 days unless they chose longer), then deleted.
- When you delete your account: removed from the live service straight away, and from our encrypted backups within 35 days.
- Billing records: six years, for tax purposes.
- Technical logs: up to 30 days.
- Support requests: two years after they're closed.
Security
Data is encrypted in transit and at rest. Mailbox tokens are encrypted again with our own keys. Uploaded files are checked for malware. Shared workspaces require two-step verification for owners and administrators. No system is perfectly secure; tell us at [security@example.com] if you find a problem.
Your rights
You have the right to access, correct, delete and receive a copy of your data, to object to or restrict some processing, and to complain. Most of this you can do yourself: edit your profile, download your data, or delete your account in your account settings. For anything else, email [privacy@example.com]. We'll respond within one month.
You can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We'd appreciate the chance to put things right first.
Changes
We'll tell you by email before any significant change to this notice takes effect.