Privacy Policy

1. Introduction

TradeAlly (“we”, “our”, or “us”) provides an AI-powered receptionist and business management service for trade businesses in the United Kingdom. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our service, including our website, mobile applications, and related features.

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Our Role: Controller vs Processor

2.1 When We Act as Data Controller

TradeAlly is the data controller for:

• Trade business account holders (our direct customers)
• Visitors to our website and landing pages
• Users of our demo widget and support assistant
• Users of our mobile applications

2.2 When We Act as Data Processor

TradeAlly acts as a data processor on behalf of trade businesses for:

• Customers who call the trade business
• Lead, appointment, and invoice data created during the course of business
• SMS messages sent to the trade business’s customers
• Expense and receipt data uploaded by the business

In these cases, the trade business is the data controller and is responsible for ensuring their customers are appropriately informed about data processing. We process this data only as instructed by the trade business under our Data Processing Agreement.

3. Information We Collect

3.1 Information You Provide Directly (Trade Businesses)

• Account information: Business name, owner name, email address, phone number, trade type, service area
• Payment information: Billing details and payment card information (processed securely via Stripe — we do not store card numbers)
• Business profile: Service areas, business hours, pricing, and service types offered
• Financial records: Receipt images, expense details, mileage logs, and invoice data

3.2 Information Collected During Calls (Caller Data)

When someone calls a trade business using our service, our AI assistant may collect:

• Caller’s phone number
• Name (if provided)
• Service requirements and job details
• Location or postcode
• Availability preferences

After the call, we retain a structured summary and any relevant data extracted from the conversation. See Section 4 for full details on how call audio and transcripts are handled.

3.3 Information Collected Automatically

• Call metadata: Call duration, timestamps, and outcome
• Usage data: Features used, login times, and dashboard interactions
• Device information: IP address, browser type, operating system, and mobile device identifiers
• Cookies: Session cookies for authentication and preference cookies for settings

3.4 Sales Demo Widget

Our website features an AI voice assistant that allows you to have a live conversation to learn about TradeAlly. Before the conversation begins, you are asked to agree to terms and conditions. When you use this widget:

• The conversation audio is recorded and stored by our AI voice provider for service improvement
• A text transcript of the conversation is generated
• Any details you voluntarily provide during the conversation may be retained
• Your IP address is used for rate limiting only

Legal basis: Explicit consent, obtained before the conversation starts.
Retention: Recordings, transcripts, and personally identifiable information are automatically deleted after 30 days.

3.5 Technical Support Calls

When you contact our AI support assistant:

• A text transcript of the conversation is generated and stored to help resolve your issue
• Your query details and resolution status are recorded
• No audio recording is stored

You are informed at the start of the call that the conversation will be transcribed.

Legal basis: Contract performance and legitimate interests (improving support quality).
Retention: Support transcripts are automatically deleted after 90 days.

4. How We Handle Calls

4.1 AI Call Processing

When a call is answered by our AI assistant, the caller is informed that they are speaking with a digital assistant and that the call may be recorded. The conversation is processed in real time using conversational AI technology to understand the caller’s needs and provide helpful responses.

4.2 Default Mode: Zero Audio Retention

By default, we operate with zero audio retention:

• Call audio is processed in real time and discarded immediately — no audio recordings are made or stored
• Only a text transcript and structured data extracted from the conversation are retained
• A temporary copy of the conversation transcript is stored for up to 30 days for quality assurance, then permanently deleted

4.3 Call Intelligence (Optional)

Call Intelligence is available on specific plans and must be explicitly enabled by the business owner. It provides deeper insights into calls:

• Call recording: The call audio is recorded and securely stored
• Transcription: The recording is transcribed to text
• Data extraction: The transcript is analysed to extract structured business insights such as service type, customer needs, and outcomes
• Owner control: Business owners can delete individual recordings at any time

4.4 Call Screening

When a business owner is available to take calls directly, our call screening feature notifies them of incoming calls. If the owner accepts, the call is connected directly. If the owner does not answer within approximately 30 seconds, the call is automatically transferred to the AI assistant.

4.5 Service Analytics

To improve our service, we create anonymised analytical records derived from call content. Personal identifiers (names, phone numbers, full addresses, and email addresses) are stripped before storage. Only aggregated or pseudonymised data — such as the type of service requested and the postcode area — is retained. These records are subject to erasure requests.

5. Mobile App and Push Notifications

5.1 Mobile Application

TradeAlly is available on iOS and Android. The mobile app collects the following additional data:

• Device identifiers: A unique identifier stored locally on your device, associated with your account
• Platform information: Your operating system type, used to optimise the experience
• Notification tokens: A device token registered when you enable push notifications

5.2 Push Notifications

We send push notifications for incoming call alerts, new leads, appointment reminders, and important service updates. You can disable push notifications at any time through your device settings.

5.3 Biometric Authentication

The mobile app offers optional biometric authentication (Face ID, Touch ID, or fingerprint) for faster login:

• Your biometric data (fingerprint, face scan) never leaves your device and is never transmitted to our servers
• A cryptographic token is stored securely on your device and a one-way hash of that token is stored on our servers to verify your identity
• Biometric login is linked to one device at a time

Legal basis: Explicit consent, obtained when you enable biometric login. You can disable it at any time through the app settings, which deletes all related data from our servers.

6. How We Use Your Information

6.1 To Provide Our Services

• Operating the AI receptionist to answer business calls
• Creating and managing leads, appointments, quotes, and invoices
• Sending SMS messages on behalf of the business
• Processing payments and managing subscriptions
• Delivering push notifications
• Providing call recordings and transcriptions when Call Intelligence is enabled

6.2 To Maintain and Improve Our Services

• Monitoring system reliability and performance
• Identifying and resolving technical issues
• Improving AI accuracy and conversation quality
• Developing new features based on usage patterns
• Analysing anonymised data to improve service classification and matching

6.3 For Communications

• Sending service updates and important notices
• Responding to support requests
• Billing and payment notifications
• Marketing communications (only with your consent)

7. Legal Basis for Processing (UK GDPR)

We process personal data on the following legal grounds:

• Contract performance (Article 6(1)(b)): Processing necessary to deliver our services, including operating the AI receptionist, managing leads, and processing payments
• Legitimate interests (Article 6(1)(f)): Service reliability, quality improvement, fraud prevention, security, and creating pseudonymised analytical records to improve our service. We have conducted Legitimate Interest Assessments for these purposes
• Explicit consent (Article 6(1)(a)): For marketing communications, the demo widget, and biometric authentication. Consent can be withdrawn at any time
• Legal obligations (Article 6(1)(c)): Compliance with tax, accounting, and regulatory requirements

8. Data Sharing and Service Providers

8.1 Where Your Primary Data Is Stored

Your TradeAlly account data — customer records, jobs, quotes, invoices, expenses, VAT returns, and authentication tokens — is stored on Heroku Common Runtime, EU region. Heroku's EU region runs in AWS data centres in Dublin, Republic of Ireland (eu-west-1). The primary database, all backups, and all application servers handling your data remain in that region. Customer data is not replicated outside the European Economic Area.

8.2 Service Providers

We share specific data types with trusted third-party service providers who assist in operating our service. The table below lists each provider's role and the country in which they process the data we send them.

• Heroku (Salesforce): Cloud hosting and infrastructure — Republic of Ireland (EU region, AWS Dublin)
• Telnyx: Telephony, SMS delivery, and call recording — United States (UK numbers route via Telnyx UK PoPs; account/billing data held by Telnyx Inc., USA)
• ElevenLabs: Conversational AI voice technology (zero-retention mode — no audio stored) — United States
• Deepgram: Speech-to-text transcription (when Call Intelligence is enabled) — United States
• OpenAI: Natural language processing for lead enrichment, data extraction, and receipt analysis — United States (with zero-retention enterprise commitment)
• Stripe: Payment processing (we do not store card numbers) — Stripe Payments UK Ltd (UK) with parent processing in Ireland and the United States
• Cloudflare: Secure file storage — global network with primary storage in EU region
• OneSignal: Push notification delivery — United States

All service providers are bound by data processing agreements and process data only as instructed. Where data crosses borders to a non-adequacy country (United States), transfers are protected by the safeguards listed in §12 below.

8.3 HMRC — Making Tax Digital (MTD)

If you connect TradeAlly to HMRC for direct VAT filing under Making Tax Digital, we share information with HMRC each time we transmit a return or fetch your VAT obligations. The data shared falls into two categories:

• Your VAT return data — the nine VAT boxes you confirm before submission, your VAT registration number, and the period being filed.
• Fraud prevention headers — technical and device information that HMRC requires us to send under the MTD Fraud Prevention Headers regulations. This includes: the IP address of our server making the request, a stable per-tenant device identifier we generate (UUID), the timezone we declare (Europe/London), our application version, and — when filing is initiated from your browser — your browser user-agent, screen and window dimensions, colour depth, and Do-Not-Track preference. HMRC uses this information solely to detect fraudulent submissions; it is not used for marketing or shared with other third parties.

This sharing is a legal requirement under MTD — HMRC may revoke our API access if these headers are not provided. Disconnecting your HMRC connection at any time stops all further sharing; previously submitted returns remain on HMRC's records as required by tax law.

8.4 Legal Requirements

We may disclose information when required by law, court order, or to protect our rights and safety.

8.5 Business Transfers

In the event of a merger, acquisition, or sale, your information may be transferred to the successor entity with equivalent privacy protections.

8.6 With Your Consent

We will share your information with other parties only with your explicit consent.

9. Data Retention

9.1 Account and Business Data

• Account data: Retained for the duration of your subscription plus 90 days
• Financial records: Retained for up to 7 years as required by HMRC regulations
• Sandbox/trial data: Deleted 30 days after trial expiry

9.2 Call Data

• Call audio (default): Not retained — processed in real time and discarded
• Call audio (Call Intelligence): Retained for 90 days, then automatically deleted. Business owners may delete recordings at any time
• AI conversation transcripts: Retained for up to 30 days, then permanently deleted
• Call Intelligence transcripts: Retained for up to 2 years, then anonymised or deleted

9.3 Customer and Lead Data

• Lead data: Retained for 2 years after last interaction, then anonymised or deleted
• SMS and message data: Retained for 2 years, then anonymised. Message content and phone numbers are removed; metadata is retained for analytics

9.4 Other Data

• Demo widget data: Automatically deleted after 30 days
• Support transcripts: Automatically deleted after 90 days
• Anonymised analytical records: Retained indefinitely in pseudonymised form with personal identifiers stripped. Subject to erasure requests
• Operational metrics: Retained indefinitely in anonymised form containing no personal data
• Push notification tokens: Retained while your account is active; deleted when you uninstall the app or disable notifications
• Biometric enrolment data: Deleted when you disable biometric login, uninstall the app, or close your account
• Marketing data: Retained until you withdraw consent

10. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Access: Request a copy of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data (“right to be forgotten”)
• Restriction: Request limited processing of your data
• Portability: Receive your data in a machine-readable format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, email us at dpo@tradeally.co.uk. We will respond within one month, as required by UK GDPR.

For callers to trade businesses: If you called a trade business and wish to exercise your rights regarding data collected during that call, please contact the trade business directly as they are the data controller. They may then instruct us to action your request.

11. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

• Encryption in transit and at rest
• Secure cloud infrastructure with enterprise-grade security
• Access controls and authentication
• Regular security monitoring and updates
• Incident response procedures

12. International Data Transfers

Your primary account data (customer records, jobs, quotes, invoices, expenses, VAT returns, authentication tokens) is stored in the European Economic Area — Heroku Common Runtime EU region, Dublin, Republic of Ireland (see §8.1).

Specific data types are processed by sub-processors located outside the EEA — primarily in the United States (see the per-provider list in §8.2). For these transfers we rely on:

• Standard Contractual Clauses (SCCs) approved by the UK ICO, incorporated by reference into each provider's data processing agreement
• The UK–US Data Bridge framework for providers certified under it (Stripe, OpenAI, OneSignal at time of writing)
• Adequacy decisions where applicable (e.g. Republic of Ireland, included in the EU–UK Adequacy Decision)

We do not transfer your primary account database outside the EEA. We hold no plans to migrate primary storage to a non-adequacy country.

13. Children's Privacy

Our services are intended for businesses and are not directed at individuals under 18 years of age. We do not knowingly collect personal information from children under 18.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by email or through our dashboard. The “Last Updated” date at the top indicates when the policy was last revised.

15. Contact Information