1. Introduction
Welcome to Cleaner Pal Ltd. ("we," "our," "us," or "CleanerPal"). We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and platform (collectively, the "Platform") that connects independent cleaning service providers ("Cleaners") with clients seeking cleaning services ("Clients").
By using our Platform, you consent to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use our Platform.
This Privacy Policy should be read in conjunction with our Terms and Conditions, Cookie Policy, and GDPR Compliance page.
2. Data Controller and Contact Information
Data Controller: Cleaner Pal Ltd., a company registered in Northern Ireland
Registered Office: Ground Floor, Gallery Building, 65-69 Dublin Rd, Belfast, BT2 7HG, Northern Ireland
ICO Registration: Registered as a data controller with the Information Commissioner's Office (ICO)
ICO Registration Number: [To be added when registered]
For questions about this Privacy Policy or our data practices, please contact us:
3. Information We Collect
We collect information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Data"). Under UK GDPR, Personal Data means any information relating to an identified or identifiable natural person.
3.1 Information You Provide Directly
Account Registration and Profile Information
- Name (first name and last name)
- Email address
- Phone number
- Date of birth
- Profile photograph
- Password (encrypted and stored securely)
- Account preferences and settings
Cleaner-Specific Information
- Business name and description
- Years of experience
- Languages spoken
- Service areas (postcodes)
- Services offered and pricing
- Availability schedule
- Maximum hours per day
- Hourly rate
- Insurance documentation and details
- Right-to-work documentation (e.g., passport details, Home Office share codes) – required by law for immigration compliance
- Identity verification documents (passport, driving licence, national ID)
- AccessNI (Disclosure and Barring Service) check results and certificate numbers
- Bank account details or PayPal account information for payments
- Tax information (for self-employed cleaners)
- References and testimonials
Client-Specific Information
- Property addresses where cleaning services are requested
- Cleaning preferences and requirements
- Special instructions for cleaners
- Access codes or keys information (stored securely)
- Property type and size
- Preferred cleaning times and frequency
Booking and Transaction Information
- Booking details (date, time, duration, services requested)
- Payment information (processed securely through third-party payment processors)
- Billing address
- Transaction history
- Invoices and receipts
- Cancellation and refund requests
Communication Information
- Messages sent through the Platform
- Support requests and correspondence
- Feedback, reviews, and ratings
- Dispute reports and resolutions
Marketing and Preferences
- Marketing communication preferences
- Newsletter subscriptions
- Promotional code usage
- Survey responses
3.2 Information Collected Automatically
Device and Technical Information
- Device type (mobile, tablet, desktop)
- Operating system and version
- Browser type and version
- IP address
- Device identifiers (UDID, IMEI, MAC address)
- Screen resolution and display settings
- Time zone and language settings
Usage and Analytics Information
- Pages visited and features used
- Time spent on pages
- Click patterns and navigation paths
- Search queries
- Date and time of access
- Referring website addresses
- Error logs and crash reports
- Performance metrics
Location Information
- Geographic location (if location services are enabled)
- GPS coordinates (for service area matching)
- IP-based location estimates
- Location history (if enabled)
Cookies and Tracking Technologies
We use cookies, web beacons, pixel tags, and similar tracking technologies. For detailed information, please see our Cookie Policy.
3.3 Information from Third Parties
We may receive information about you from third parties:
- Verification Services: Background check results, identity verification, right-to-work status from uCheck and other verification providers
- Payment Processors: Payment confirmation, transaction status, and fraud detection information from Stripe, PayPal, and other payment providers
- Government Agencies: Right-to-work verification from the Home Office, tax information from HMRC (where legally required)
- Social Media Platforms: If you choose to connect your account (currently not available, but may be added in future)
- Analytics Providers: Usage statistics and analytics from Google Analytics, Firebase Analytics, and similar services
- Cloud Service Providers: Infrastructure and hosting information from Google Cloud Platform and Firebase
- Referral Partners: If you were referred by a partner organization
4. How We Use Your Information
We use the information we collect for the following purposes, based on different legal bases under UK GDPR:
4.1 To Provide and Operate the Platform (Contract)
- Create and manage your account
- Process and facilitate bookings between Cleaners and Clients
- Process payments and manage financial transactions
- Enable communication between Users
- Provide customer support and respond to inquiries
- Send booking confirmations, reminders, and updates
- Manage subscriptions and service tiers
- Generate invoices and receipts
- Handle cancellations and refunds
- Facilitate dispute resolution
4.2 Legal Obligations
- Verify right-to-work status as required by UK immigration law
- Conduct AccessNI checks for safety and compliance
- Comply with tax and accounting obligations
- Respond to legal requests and court orders
- Comply with regulatory requirements
- Maintain records as required by law
- Report suspicious activity to relevant authorities
4.3 Legitimate Interests
We process your data based on our legitimate interests, balanced against your rights and freedoms:
- Safety and Security: Verify identities, conduct background checks, prevent fraud, detect and prevent illegal activity, ensure platform safety
- Platform Improvement: Analyze usage patterns, improve features, develop new services, conduct research and analytics
- User Experience: Personalize content, recommend cleaners or services, optimize matching algorithms
- Business Operations: Manage operations, ensure quality, handle disputes, enforce terms and policies
- Communication: Send important service updates, security alerts, policy changes
- Legal Protection: Defend legal claims, protect our rights and property, enforce agreements
4.4 With Your Consent
- Send marketing communications and promotional offers
- Share data with third parties for marketing purposes (where explicitly consented)
- Use cookies and tracking technologies (where consent is required)
- Conduct surveys and research
- Send SMS notifications (beyond operational messages)
- Use location data for enhanced features
You can withdraw your consent at any time by updating your preferences in your account settings or contacting us. Withdrawing consent does not affect the lawfulness of processing before withdrawal.
5. How We Share Your Information
We do not sell your personal data. We share your information only as described below:
5.1 With Other Users
When you use the Platform, certain information is shared with other Users:
- Cleaner Profiles: Name, profile photo, ratings, reviews, service areas, availability, and business information are visible to Clients
- Booking Information: When a booking is made, Cleaners receive Client contact information, property address, and service requirements. Clients receive Cleaner contact information and profile details
- Reviews and Ratings: Reviews and ratings are publicly visible on Cleaner profiles
- Messages: Messages sent through the Platform are visible to the recipient
5.2 Service Providers and Processors
We share information with third-party service providers who process data on our behalf:
- Payment Processors: Stripe, PayPal for payment processing (they collect payment card information directly)
- Cloud and Hosting: Google Cloud Platform, Firebase for data storage and hosting
- Verification Services: uCheck and other providers for background checks and identity verification
- Analytics: Google Analytics, Firebase Analytics for usage analytics
- Communication: Email service providers, SMS service providers (Twilio) for sending communications
- Customer Support: Support platform providers for managing customer inquiries
- Security: Security service providers for fraud detection and prevention
All service providers are contractually obligated to protect your data and use it only for specified purposes.
5.3 Government and Regulatory Authorities
- Home Office for right-to-work verification
- HMRC for earnings data as required by digital platform reporting rules
- Police and law enforcement agencies (when required by law or court order)
- Information Commissioner's Office (ICO) for data protection compliance
- Other regulatory bodies as required by law
5.4 Business Transfers
If we are involved in a merger, acquisition, asset sale, or similar transaction, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal data.
5.5 Legal Requirements
We may disclose your information if required by law, court order, or government regulation, or if we believe disclosure is necessary to:
- Comply with legal obligations
- Protect our rights, property, or safety
- Protect the rights, property, or safety of Users or others
- Prevent or investigate fraud or illegal activity
- Respond to legal claims
6. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:
- Encryption: Data in transit is encrypted using TLS/SSL. Sensitive data at rest is encrypted using industry-standard encryption
- Access Controls: Strict access controls limit who can access personal data. Access is granted on a need-to-know basis and logged
- Authentication: Multi-factor authentication (2FA) is available and encouraged for all accounts
- Secure Infrastructure: Data is stored in secure data centers with physical and logical security measures
- Regular Security Assessments: We conduct regular security audits, vulnerability assessments, and penetration testing
- Staff Training: All staff receive regular training on data protection and security
- Incident Response: We have procedures in place to detect, respond to, and recover from security incidents
- Data Minimization: We collect and retain only the data necessary for our purposes
- Secure Development: We follow secure coding practices and conduct code reviews
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law:
- Account Data: Retained while your account is active. After account closure, retained for 2 years for legal and business purposes, then securely deleted
- Right-to-Work Records: Retained for at least 2 years after the end of the relationship (legal requirement under UK immigration law)
- AccessNI Check Results: Retained as required by law and our policies. AccessNI certificates are retained for the duration of the cleaner's active account plus 2 years
- Transaction and Financial Data: Retained for 7 years for tax and accounting purposes (legal requirement)
- Booking Records: Retained for 7 years for legal and business purposes
- Communication Records: Retained for 2 years after the last communication
- Marketing Data: Retained until consent is withdrawn or you opt out, then deleted within 30 days
- Analytics Data: Aggregated and anonymized data may be retained indefinitely
- Legal Claims: Data relevant to legal claims may be retained until claims are resolved
After the retention period expires, we securely delete or anonymize your personal data. Some data may be retained in backup systems for a limited period before permanent deletion.
8. Your Rights Under UK GDPR
Under UK GDPR and the Data Protection Act 2018, you have the following rights regarding your personal data:
8.1 Right of Access (Article 15)
You have the right to request copies of your personal data. You can access much of your data through your account settings, or request a complete data export by contacting us or using the data export feature in your account.
8.2 Right to Rectification (Article 16)
You have the right to request correction of inaccurate or incomplete personal data. Most information can be updated directly through your account settings. We will respond to rectification requests within one month.
8.3 Right to Erasure / "Right to be Forgotten" (Article 17)
You have the right to request deletion of your personal data, subject to certain exceptions:
- We may retain data where required by law (e.g., tax records for 7 years)
- We may retain data necessary for legal claims or disputes
- We may retain data necessary for legitimate business interests
You can request account deletion through your account settings or by contacting us. We will process deletion requests within one month, subject to legal requirements.
8.4 Right to Restrict Processing (Article 18)
You have the right to request that we limit how we process your data in certain circumstances, such as when you contest the accuracy of data or object to processing.
8.5 Right to Data Portability (Article 20)
You have the right to receive your personal data in a structured, commonly used, and machine-readable format. You can use the data export feature in your account settings to download your data in JSON format.
8.6 Right to Object (Article 21)
You have the right to object to processing based on legitimate interests. You can opt out of marketing communications at any time through your account settings or by contacting us.
8.7 Rights Related to Automated Decision-Making (Article 22)
You have the right not to be subject to decisions based solely on automated processing that significantly affect you. We use automated decision-making for:
- Cleaner-client matching based on location and preferences
- Risk assessment for new cleaner applications
- Dynamic pricing algorithms
- Fraud detection
You can request human review of any automated decisions that significantly affect you by contacting us.
8.8 Right to Withdraw Consent
Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawing consent does not affect the lawfulness of processing before withdrawal.
9. Exercising Your Rights
To exercise your rights, you can:
- Use self-service options in your account settings (for data access, export, and deletion)
- Email us at privacy@cleanerpal.com
- Contact our Data Protection Officer at dpo@cleanerpal.com
- Write to us at our registered office address
We will respond to your request within one month. If your request is complex or we receive multiple requests, we may extend this by up to two months, and we will inform you of this extension and the reasons.
We may request proof of identity before processing certain requests to ensure we are responding to the correct person.
In most cases, exercising your rights is free of charge. However, we may charge a reasonable fee if requests are manifestly unfounded, excessive, or repetitive.
10. International Data Transfers
Some of our service providers may process data outside the UK. When we transfer data internationally, we ensure appropriate safeguards are in place:
We use UK ICO-approved Standard Contractual Clauses (SCCs) and adequacy decisions for transfers outside the UK/EEA.
For more information about international transfers and safeguards, please contact our Data Protection Officer.
11. Data Breach Notification
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will:
- Notify the Information Commissioner's Office (ICO) without undue delay, and in any event within 72 hours of becoming aware of the breach (where feasible)
- Notify affected individuals without undue delay if the breach is likely to result in a high risk to their rights and freedoms
- Provide clear information about the nature of the breach, likely consequences, and measures taken or proposed to address it
We have procedures in place to detect, assess, and respond to data breaches promptly.
12. Children's Privacy
Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child under 18, we will take steps to delete that information. If you believe we have collected information from a child, please contact us immediately.
13. Marketing Communications
We may send you marketing communications if you have consented or if we have a legitimate interest (for existing customers). You can opt out at any time by:
- Clicking the unsubscribe link in marketing emails
- Updating your preferences in your account settings
- Contacting us at privacy@cleanerpal.com
We will continue to send important service-related communications (e.g., booking confirmations, security alerts) even if you opt out of marketing communications.
14. SMS and Text Messages
By providing your phone number, you consent to receive SMS messages from CleanerPal. You should expect to receive a maximum of ten (10) SMS messages per month. These messages include:
- Booking confirmations and reminders
- Payment notifications
- Dispute alerts
- Important account security information (e.g., 2FA codes)
- Service updates
Message and data rates may apply. Reply STOP to opt out at any time. For help, reply HELP. Opting out of SMS messages may affect your ability to receive important account notifications.
15. Cookies and Tracking Technologies
We use cookies and similar tracking technologies. For detailed information about our use of cookies, please see our Cookie Policy.
16. Third-Party Links
Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of significant changes by:
- Posting the updated Privacy Policy on our website with a new "Last updated" date
- Sending an email notification to registered users
- Displaying a notice on the Platform
Your continued use of the Platform after changes become effective constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, you should stop using the Platform and may request deletion of your account.
18. Complaints
If you have concerns about how we handle your personal data, you can:
- Contact us at privacy@cleanerpal.com or our Data Protection Officer at dpo@cleanerpal.com
- Submit a formal complaint to the Information Commissioner's Office (ICO):
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Website: ico.org.uk
19. Contact Information