Legal
Privacy Policy
Last updated: [DATE]
This policy explains how [COMPANY NAME] (“Peppercorn One”, “we”) handles personal data. For account data we are the data controller. For the building, leaseholder and seller information you enter on behalf of your building, we act as a data processor on your instructions. We are registered with the Information Commissioner’s Office (registration number [ICO NUMBER]).
1. Who we are
[COMPANY NAME], company number [COMPANY NUMBER], registered office [REGISTERED OFFICE]. For any privacy matter contact [SUPPORT EMAIL].
2. The data we collect
- Account data: your name, email address, optional phone number, and your role at the building.
- Building data: information about the building and its management that you enter or upload, which may include personal data of leaseholders and sellers.
- Documents: the files you upload, such as insurance schedules, accounts and fire risk assessments.
- Usage and technical data: limited information needed to operate and secure the service, including sign-in events and a hashed record of access to shared packs.
- Payment data: handled by our payment processor; we do not store full card details.
3. How we use it and our lawful bases
- To provide the service to you — lawful basis: performance of a contract.
- To secure the service, prevent abuse and keep records — lawful basis: our legitimate interests in running a safe, reliable service.
- To send service and transactional messages (verification, receipts, pack notifications) — lawful basis: performance of a contract and legitimate interests.
- To send optional product updates — lawful basis: consent, which you may withdraw at any time.
- To meet legal and accounting obligations — lawful basis: legal obligation.
4. Automated document reading (AI)
When you ask Peppercorn One to suggest answers from a document, the document’s content is sent to our extraction provider, Anthropic, to produce suggestions. Anthropic’s API does not use customer content to train its models by default. Suggestions are never issued without human confirmation. You can disable automated extraction for your account in settings.
5. Who we share data with (processors)
We use a small number of carefully chosen processors to run the service. Each is bound by contract to protect your data and use it only on our instructions:
- Supabase — database, authentication and file storage.
- Anthropic — automated document reading (only when you request extraction).
- Stripe — payment processing.
- [EMAIL PROVIDER] — transactional email delivery.
- Vercel — application hosting.
- [ANALYTICS PROVIDER] — privacy-respecting usage analytics.
We do not sell personal data. We may disclose data where required by law.
6. International transfers
We aim to keep data within the UK or European Economic Area where possible. Where a processor transfers data outside the UK/EEA, that transfer is protected by an appropriate safeguard such as the UK International Data Transfer Addendum or Standard Contractual Clauses.
7. How long we keep it
We keep account data for as long as your account is open, and a building’s record for as long as that building exists in Peppercorn One — including after a single-pack purchase, with no automatic deletion after a set period. A building’s record is reused to pre-fill future packs, which is the point of keeping it; it is removed only when you delete the building or your account. On account deletion we remove data from our live systems within 30 days, subject to any limited retention required for legal, accounting or security reasons. Backups are rotated on a defined schedule.
8. Your rights
Under UK data protection law you have the right to:
- access a copy of your personal data;
- have inaccurate data corrected;
- have data erased in certain circumstances;
- restrict or object to certain processing;
- data portability;
- withdraw consent where we rely on it.
You can export a building or your account, and delete your account, from within the app. To exercise any other right, contact [SUPPORT EMAIL]. If you are a leaseholder whose data a building holds in Peppercorn One, the building is the controller of that data; we will pass your request to them.
9. Security
We protect data with encryption in transit and at rest, per-user access controls enforced in the database, audit logging and signed, short-lived links for document access. More detail is on our Security page.
10. Complaints
If you have a concern we have not resolved, you can complain to the Information Commissioner’s Office at ico.org.uk. We would welcome the chance to address your concern first.