Privacy Policy

1. Contact details

Spire Trade Advisors Ltd, company number 16562883, 9 Soapworks House, Carrack Mews, London, England, E16 2EN. Email: support@easycoshh.co.uk. We are the controller of the personal data described here.

2. What we collect

• Assessment information: what you enter (company name, site, assessor name, task details, answers) and the information we read from the Safety Data Sheet you upload. The PDF itself is processed in memory to extract text and is not stored.
• Order information: your email address, what you bought, the Terms version you accepted and the time, and payment status from Stripe. We do not receive your full card number.
• Account: your email address, free-assessment and credit balance and a list of your assessments; one-time sign-in codes (stored as a hash) and a session cookie.
• Logo branding: the company name and logo image you upload, stored with your account and used only to brand your assessments; remove it any time in My account.
• Max plan: your Stripe customer and subscription IDs, plan status, billing period dates and how many assessments you have used this period.
• Free-offer checks: a hash of your normalised email address (ignoring “+” tags and Gmail dots) and a hashed IP address, so the free allowance can only be claimed once.
• Marketing preference: whether you ticked the optional box to receive product news and offers, with the wording and time.
• Technical data: a hashed IP address used for rate limiting, and standard hosting logs.

3. Why we use it and our lawful bases

• To create, deliver and email your assessments and run your credit balance: performance of a contract.
• To keep order records and meet accounting and tax obligations: legal obligation.
• To prevent abuse of the free offer and keep the Service secure: legitimate interests.
• To send occasional product news and offers, only if you ticked the optional box: consent. You can withdraw it at any time by replying to any email or contacting us, and every marketing email will include an unsubscribe link.

We do not use analytics or advertising cookies.

4. Who we share it with

• Stripe (payments): independent controller for some processing.
• Netlify, Inc. (hosting, serverless functions and data storage): processor.
• Resend (sending your assessments and sign-in codes): processor.

5. International transfers

Some providers may process data in the United States. Where they do, we rely on the UK data bridge / adequacy regulations or appropriate safeguards such as the UK International Data Transfer Addendum. [TO CONFIRM per provider.]

6. How long we keep it

• Unpaid draft assessments: up to 30 days.
• Paid and free assessments (so you can download them again): 12 months from creation, or longer while you hold credit.
• Order records: 6 years for accounting and legal claims.
• Sign-in codes: 10 minutes. Sign-in sessions: 30 days.
• Free-offer records (hashed email and IP): while the offer runs plus 2 years, to stop repeat claims.
• Marketing preference: until you withdraw consent, plus a minimal suppression record so we don’t email you again.
• Accounts with no activity: deleted after 24 months.

7. Your rights

You can ask to access, correct or delete your data, restrict or object to processing, and for data portability. Contact support@easycoshh.co.uk. You can complain to the Information Commissioner’s Office (ico.org.uk).

8. Cookies

We use one strictly necessary cookie (cx_acct) to keep you signed in. With your consent only, we also use Google Analytics, Google Ads to understand site use and measure our ads (lawful basis: consent; withdraw it any time via Cookie settings). See our Cookie Policy.