Privacy Policy

2. Scope of this Policy

This Policy applies to customers, prospective customers, website visitors, business contacts, Cleaners and people whose information is supplied as part of a booking (for example a neighbour providing a key). It applies to information collected through our website, booking forms, telephone, email, WhatsApp, payment flows and customer-support channels.

4. Information about other people

If you give us information about another person, such as a neighbour who will provide a key, you must have a lawful basis and, where appropriate, their permission to do so. Please tell them that their information will be used for the booking and direct them to this Privacy Policy. Do not provide more information than is necessary.

5A. How we assess "legitimate interests"

Before relying on legitimate interests as a lawful basis, we ask three questions required by ICO guidance: (1) purpose — is there a genuine business reason for the processing; (2) necessity — is the processing a reasonably targeted way of achieving that purpose, with no less intrusive alternative; and (3) balancing — do your interests, rights and freedoms override our interest, taking into account whether you would reasonably expect the processing and any potential impact on you. We keep a record of this assessment for each purpose listed in section 5, and you can ask us for a copy using the contact details in section 19.

5B. Automated decision-making and profiling

We do not currently use fully automated decision-making (that is, a decision made without any human involvement) that produces a legal or similarly significant effect on you, such as automatically refusing a Booking or a Cleaner application without human review. Limited automated processing may be used to support fraud checks or to suggest an available Cleaner or time slot, but a person reviews any outcome that meaningfully affects your access to the service. If this changes, we will update this Policy and provide the information required by UK GDPR Article 22, including your right to request human review.

6. Special-category information

We do not normally need information about health, ethnicity, religion, sexual orientation or other special-category data to provide cleaning services. Please avoid placing such information in free-text notes unless it is genuinely necessary. If you voluntarily provide health or accessibility information that is necessary for safe service delivery (for example, a note that a resident has limited mobility so the Cleaner can plan safe access), our primary basis for using it is your explicit consent (UK GDPR Article 9(2)(a)), which you give by choosing to provide that information to us for that purpose. We will only rely on a different Article 9(2) condition and the matching Schedule 1 Data Protection Act 2018 condition — maintaining the Appropriate Policy Document that condition requires — where we have specifically identified that a more suitable condition applies to the circumstances. In every case, we minimise who can access this information and keep it only as long as necessary for the purpose it was given.

7. Who we share information with

• The assigned self-employed Cleaner, but only information reasonably needed to perform and support the Booking.
• Payment processors, banks and fraud-prevention providers.
• Hosting, website, cloud, CRM, email, SMS, telephone and WhatsApp/business-messaging providers.
• Professional advisers, accountants, insurers and claims handlers where necessary.
• Verification, screening or insurance-validation providers used for Cleaner onboarding where applicable.
• Police, courts, regulators, HMRC or other authorities where disclosure is required or permitted by law, including annual digital-platform reporting to HMRC where section 13C applies.
• A purchaser, investor or successor in a corporate transaction, subject to appropriate confidentiality and data-protection safeguards.

We do not sell personal information to advertisers or data brokers. Where a third party processes personal information on our behalf, we have a written contract with them that meets UK GDPR Article 28 requirements.

11. How long we keep information

We keep personal information only for as long as necessary for the purposes it was collected. Typical retention periods are:

12. Security

We use appropriate technical and organisational measures proportionate to risk, including access controls, account/security logging, restricted access to booking and key information, supplier controls, secure payment providers and procedures for responding to suspected personal-data breaches. No internet service can guarantee absolute security, so customers should use secure channels and avoid sending unnecessary sensitive information.

13A. What this means for you in practice

13B. Cleaner-specific processing

If you are a Cleaner or Cleaner applicant, we process the onboarding and compliance data described in section 3 to assess suitability, verify identity and insurance, administer payments due to you under the Cleaner Agreement, and maintain records required for insurance, tax and safeguarding purposes. Where we carry out a background or identity check through a third-party verification provider, that provider acts as our processor for that specific check, and we only use the result for the onboarding and ongoing-compliance purposes described in section 5. Cleaners have the same rights described in section 13, exercised in the same way.

13C. HMRC digital-platform reporting (Cleaners)

Digital platforms that connect self-employed individuals with customers for services such as cleaning, and that know or can reasonably determine what is paid to those individuals, may be a "Reporting Platform Operator" under the Platform Operators (Due Diligence and Reporting Requirements) Regulations 2023. [Business to confirm with its accountant or tax adviser whether Indeed-Clean falls within this regime.] If it does, we are legally required to collect and verify additional information about Cleaners (including full name, address, date of birth, and National Insurance number or Tax Identification Number), and to report Cleaners' identity and the amounts paid to them to HMRC annually. Where this applies, that processing is carried out under the legal obligation basis in section 5, using the Cleaner tax-reporting data described in section 3, and Cleaners will be notified in accordance with the Regulations before the first report is made.

14. Marketing communications

We send electronic marketing only where permitted by UK GDPR and the Privacy and Electronic Communications Regulations (PECR), including any applicable consent or "soft opt-in" requirements. Every marketing message will provide a clear way to opt out where required. Service messages about an active booking are not marketing and may still be sent when necessary to perform the booking.

15. Cookies and similar technologies

Our website uses cookies and other storage/access technologies. Some are necessary for security, booking and preference functions. Others may be used for statistics, analytics or marketing depending on configuration. Where consent is legally required, non-exempt technologies are kept off until valid consent is obtained. See our Cookie Policy and Cookie Settings for details.

16. Children

Indeed-Clean is a service for adults arranging cleaning and is not directed at children. A person making a Booking must be at least 18. If we learn that we have collected a child's information unnecessarily, we will take reasonable steps to delete it.