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1. Who We Are and Our Role

EHO App is operated by EHOapp ("we", "us", "our").

Under UK GDPR, our role depends on the type of data:

• Data Controller: We are the controller for venue owner account data, email addresses, and payment information — data we collect directly to provide the service.
• Data Processor: For data entered by the venue into the app (staff names, compliance records, fitness-to-work logs, equipment details), the food business is the Data Controller and EHOapp acts as Data Processor, processing this data on the venue's behalf and according to their instructions.

Our obligations as a Data Processor are set out in the Data Processing section of our Terms of Service.

Contact: hello@ehoapp.com

2. What Data We Collect

We collect only the data necessary to operate the service:

Data	Purpose	Basis
Email address	Account creation, authentication, transactional emails	Contract
Venue/business name	Identifying your premises within the app	Contract
Staff names	Attributing compliance records to individuals	Contract
Compliance records	Core service — food safety record keeping	Contract
Equipment details	Temperature monitoring (fridge/freezer/hot-hold names)	Contract
Supplier and dish names	Allergen and delivery record keeping	Contract
Bank account details (via GoCardless)	Direct Debit payment processing	Contract
Optional website analytics	Understanding which pages and actions lead to free trials	Consent

We do not collect:

• Analytics data unless you actively accept optional analytics
• Precise location data
• Advertising IDs, or account, venue, or user identifiers supplied by us to Google Analytics

Firebase Authentication uses necessary browser storage for session tokens, and the app may cache compliance data locally for offline functionality. This storage is required for the service to work and is separate from optional analytics.

3. Optional Analytics and Cookies

We use Google Analytics only after you select Accept analytics. Until you accept, the Google Analytics tag is not loaded and no analytics request or analytics cookie is sent. Declining does not affect the app.

If accepted, we record page views and journey events for selecting a free-trial link, starting and completing account registration, and server confirmation that a trial was created. Google Analytics also creates automatic technical events such as first_visit, session_start, and user_engagement. Depending on the Analytics property settings, it may measure standard website interactions such as scrolling, outbound-link clicks, file downloads, video engagement, site searches, and form interactions. We may also receive general browser, device, referrer, and approximate location information. For visitors in the UK, EU, or Switzerland, Google uses the IP address only to derive coarse location before immediately discarding it; Google Analytics does not log or store the address. For visitors elsewhere, Google may use the IP address for spam detection, geographic reporting, and data-centre routing before discarding it. Google Analytics sets first-party _ga cookies containing a pseudonymous client ID used to distinguish a browser and its sessions. We do not send form contents, email addresses, business names, venue IDs, user IDs, compliance records, or payment information to Google Analytics.

We use first-party local storage to remember your choice and, after consent, prevent the same trial event from being counted twice. The consent preference remains until you change it or clear this site's data. The one-time analytics markers contain no direct account, user, or venue IDs and are removed when you withdraw consent. Session-storage markers carry a fixed trial-link location to the destination page and link a consented registration start to a confirmed trial. They are removed after tracking, withdrawal, sign-out where applicable, or the end of the browser session.

Analytics is not used for advertising or ad personalisation. You can withdraw or change your choice at any time by selecting Analytics settings. Withdrawing consent prevents further analytics collection and removes Google Analytics cookies set on this domain where the browser permits it.

4. How We Use Your Data

We use account, venue, compliance, payment, and transactional-email data only as needed to provide and operate the EHO App service. Separately, where you consent, we use optional analytics data only to measure the landing-page-to-free-trial journey:

• Creating and managing your account
• Storing and displaying your compliance records
• Processing subscription payments
• Sending transactional emails (verification, password reset, staff invitations)
• Measuring the landing-page-to-free-trial journey where you have consented to optional analytics

We do not use your data for marketing, profiling, or automated decision-making. We will never send unsolicited marketing emails.

5. Legal Basis for Processing

Under UK GDPR, we process your personal data on the following bases:

• Contract performance (Article 6(1)(b)) — processing necessary to deliver the service you signed up for
• Legal obligation (Article 6(1)(c)) — where required by law (e.g. tax records for payment transactions)
• Legitimate interest (Article 6(1)(f)) — service security, fraud prevention, and responding to support requests
• Consent (Article 6(1)(a)) — optional Google Analytics, which you can withdraw at any time

6. Special Category Data (Health Data)

EHO App includes a "fitness to work" check that may involve recording whether staff members have symptoms of illness (e.g. vomiting, diarrhoea). Under UK GDPR Article 9, health data is classified as Special Category Data and is subject to stricter processing rules.

As Data Processor, EHOapp hosts this data on behalf of the venue. The venue (as Data Controller) is solely responsible for:

• Ensuring they have a lawful basis to record staff health data (typically "necessary for reasons of public interest in the area of public health" under Article 9(2)(i), or "necessary for carrying out obligations in the field of employment" under Article 9(2)(b))
• Informing their staff about what health data is being recorded and why
• Handling any data subject access requests from their staff relating to this data

EHOapp does not access, analyse, or share fitness-to-work data beyond securely storing it on the venue's behalf.

7. Third-Party Services

We share service data with Google Firebase, GoCardless, and Resend only as necessary to operate the app. Google Analytics receives the optional data described below only after you consent:

Service	Purpose	Data Shared	Location
Google Firebase (Authentication & Firestore)	User authentication and data storage	Email, venue data, compliance records	EU (europe-west)
GoCardless	Direct Debit payment processing	Bank details (collected directly by GoCardless)	UK/EU
Resend	Transactional email delivery	Email address, email content	US (EU-US Data Privacy Framework)
Google Analytics (consent only)	Website and free-trial journey measurement	Page, session, engagement, and interaction data; general browser/device information; approximate location derived through transient IP processing; and a Google-generated pseudonymous client ID. We do not supply account, email, user, or venue identifiers.	Google processing locations with applicable transfer safeguards

We do not sell, rent, or trade your personal data to any third party. We do not share data with advertisers, data brokers, or social media platforms.

8. Data Storage and Security

Your data is stored in Google Cloud Firestore with the following protections:

• Encryption in transit (TLS) and at rest
• Firestore security rules restrict access — users can only read/write their own venue data
• Firebase Authentication manages credentials (passwords are hashed, never stored in plain text)
• Cloud Functions run in a secured environment with secret management for API keys

9. Data Retention

• Free plan: The app shows compliance records from the last 30 days. Older records are not deleted; they are retained and become viewable again if the venue moves to Pro. Open corrective actions are always shown regardless of age.
• Pro plan: You can access retained compliance records beyond the last 30 days.
• After cancellation: Cancelling Pro does not delete your compliance records. On the Free plan, the app shows the last 30 days; older records remain retained.
• Account deletion: Upon request, we will permanently delete your account and all associated data within 30 days. This action is irreversible.
• Optional analytics: Google Analytics cookies normally remain for up to two years, subject to browser and property limits; withdrawing consent removes those cookies from this domain where the browser permits it. Non-aggregated user-level and event-level data is governed by the Analytics property's retention controls. Google may reset a returning user's retention period on new activity, and these controls do not apply to standard aggregated reports. We keep analytics only for as long as needed to measure the landing-page-to-free-trial journey.

10. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Access — request a copy of the personal data we hold about you
• Rectification — request correction of inaccurate data
• Erasure — request deletion of your data ("right to be forgotten")
• Portability — receive your data in a structured, machine-readable format (CSV export is available on the Pro plan)
• Restriction — request that we limit processing of your data
• Objection — object to processing based on legitimate interest

To exercise any of these rights, contact us at hello@ehoapp.com. We will respond within 30 days.

11. Young Workers

EHO App is designed for food business operators and their staff. We do not directly collect data from children.

In the UK hospitality industry, individuals under 16 may be employed for light duties and could use the app to log compliance tasks. Where an employer provisions a staff account for an individual under 16, the employer (as Data Controller) is responsible for ensuring they have appropriate lawful basis and any necessary parental or guardian consent for that individual's use of the service.

12. International Transfers

Your core data is stored in Firebase's EU region (europe-west). Transactional emails are processed by Resend, which operates under the EU-US Data Privacy Framework. GoCardless processes payments within the UK/EU.

Optional analytics data may be processed by Google outside the UK. Where data is transferred outside the UK, we require appropriate safeguards as required by UK GDPR.

13. Data Breaches

In the event of a personal data breach that poses a risk to your rights and freedoms, we will:

• Notify the Information Commissioner's Office (ICO) within 72 hours
• Notify affected users without undue delay
• Document the breach and remedial actions taken

14. Complaints

If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office:

ICO: ico.org.uk/make-a-complaint
Helpline: 0303 123 1113

15. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated via the app or email. The effective date at the top of this page indicates when the policy was last updated.

16. Contact

For privacy-related questions or to exercise your data rights:

Email: hello@ehoapp.com
Website: ehoapp.com