Privacy Policy

1. Who We Are

Data Controller (for most purposes):
Hooftec Online Ltd
Email: [email protected]
Website: https://hooftec.app

"Hooftec", "we", "us", "our" means Hooftec Online Ltd, a company incorporated in England and Wales (company number [insert]), whose registered office is at [insert registered office address].

For personal data processed within customer accounts (e.g. farmers' clients, herd records), Hooftec acts as a Data Processor and the subscribing business is the Data Controller.

2. Scope of This Policy

This Policy applies to:

• Account holders
• Website visitors
• Business contacts
• Prospective customers
• Individuals whose data is processed when interacting directly with Hooftec

It does not replace the customer's own privacy obligations where they act as controller of their own client data.

3. Categories of Personal Data We Collect

3.1 Account Information

• Name
• Email address
• Telephone number
• Business name
• Billing address
• Professional role

3.2 Payment Information

Payments are processed by a third-party payment provider (e.g., Stripe). We do not store full card details.

We may process:

• Billing contact details
• Payment status
• Subscription tier
• Transaction references

3.3 Usage Data

• Log data
• Device information
• IP address
• Browser type
• App usage metrics
• Crash diagnostics

3.4 Communications Data

• Support enquiries
• Email correspondence
• Feedback submissions

3.5 Customer-Submitted Data (Processor Role)

When customers use the Service to record herd or business data, we process personal data such as:

• Customer contact details
• Business records
• Agricultural service records

In this context, we act solely as a Data Processor on the instructions of the subscribing business.

3.6 Location Data

The Hooftec mobile application requests access to the device's location (approximate and/or precise, via the ACCESS_COARSE_LOCATION and ACCESS_FINE_LOCATION permissions on Android, and the equivalent core location permissions on iOS). Location access is used solely to enrich trim and lameness scoring records with geographic metadata and is not used for advertising, tracking your movements, or sold to third parties.

Specifically, when you start a trim or scoring session the app performs a single, one-off device location lookup and reverse geocodes the coordinates to derive the following approximate values, which are stored as metadata on the records created during that session:

• Country (ISO country code)
• County / region / administrative area
• Postcode
• An approximate full address string derived from the reverse geocoded placemark

This geographic metadata is used for:

• Tagging trim and scoring records with the location at which the work was carried out
• Geographic reporting and herd-pattern analysis across regions
• Aggregated, anonymised analytics about where the service is used

Important behaviour of the location feature:

• The app does not display a system permission prompt itself. It only reads location if you have already granted location permission to the app at the operating-system level. If permission has not been granted, or has been denied permanently, the lookup is skipped and no location data is collected.
• The lookup uses low accuracy positioning to minimise battery use, and is bounded by a 5-second timeout.
• The lookup is performed once per session and the result is reused for all records created during that session. It is not continuous background tracking.
• If the device is offline, location services are disabled, the lookup times out, or reverse geocoding fails, the app fails silently and stores no location data for that session. In that case the app falls back to the address recorded on the relevant customer or user profile.
• Raw GPS coordinates are used only transiently to perform the reverse geocode and are not retained or transmitted to us; only the derived address components above are stored with the record.

You can prevent the app from accessing location data at any time by revoking location permission in your device's settings (Settings → Apps → Hooftec → Permissions → Location → Deny). The app will continue to function fully without location permission; the only effect is that records will not carry automatically derived location metadata.

Where Hooftec acts as Data Processor for customer-submitted records, any location metadata attached to those records is processed on the instructions of the subscribing business, which acts as Data Controller for that data.

4. Lawful Bases for Processing

We rely on the following lawful bases under UK GDPR:

Where consent is required (e.g., optional analytics cookies), it will be obtained separately.

5. How We Use Personal Data

We use personal data to:

• Provide and maintain the Service
• Process subscription payments
• Provide customer support
• Improve and develop the platform
• Maintain system security
• Comply with legal obligations
• Communicate service updates
• Attach approximate location metadata to trim and scoring records, where location permission has been granted at the device level, for record context and geographic reporting

We do not sell personal data.

6. Data Sharing

We share personal data only where necessary with trusted service providers, including:

• Cloud hosting providers
• Payment processors
• Analytics providers
• Email delivery services

All third-party processors are contractually required to implement appropriate safeguards.

We may also disclose data:

• Where required by law
• To regulators
• In connection with a business sale or restructuring

7. International Transfers

Where personal data is transferred outside the UK, we implement appropriate safeguards such as:

• UK International Data Transfer Agreement (IDTA)
• UK Addendum to EU Standard Contractual Clauses
• Transfers to jurisdictions subject to adequacy decisions

8. Data Retention

We retain personal data:

• For the duration of the subscription
• For up to 6 years after termination for legal and accounting purposes
• As required by tax law
• For security logging purposes for a limited period

Customer account data will be deleted or anonymised upon request, subject to legal retention obligations.

Backups are overwritten in accordance with our standard retention cycle.

9. Data Security

We implement appropriate technical and organisational measures including:

• Encryption in transit
• Encryption at rest
• Access controls
• Role-based permissions
• Secure cloud infrastructure
• Regular security monitoring

No system can guarantee absolute security.

10. Data Subject Rights

Individuals have the following rights under UK GDPR:

• Right of access
• Right to rectification
• Right to erasure
• Right to restriction
• Right to data portability
• Right to object
• Right to lodge a complaint

Requests can be submitted to: [email protected]

We will respond within one month, subject to statutory extensions.

Where we act as Data Processor, requests relating to customer-managed data will be referred to the relevant business controller.

11. Marketing Communications

We may send B2B service communications based on legitimate interests.

You may opt out at any time using the unsubscribe link or by contacting us.

We do not conduct automated decision-making or profiling with legal or similarly significant effects.

12. Cookies and Analytics

Our website and application may use:

• Essential cookies
• Performance and analytics tools

Where legally required, consent will be obtained via a cookie banner. Further details are provided in our Cookie Policy.

13. Children's Data

The Service is not intended for individuals under 18 years of age. We do not knowingly collect data relating to children.

14. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via email or in-app notification.

15. Complaints

If you believe we have not handled your data correctly, you may contact us first.

You also have the right to lodge a complaint with:

This Privacy Policy does not form part of any contractual agreement except where expressly referenced in our Terms & Conditions.