This Privacy Policy explains how DuoApp Limited ("we", "us") collects, uses, shares and protects personal data. We are the data controller for personal data collected through our website and the data processor for personal data you upload to the platform as a customer.
1. What we collect
Account information
Name, work email address, company name, phone number, billing address, and Direct Debit details for your DuoApp subscription (handled by GoCardless - we don't store your bank account details).
Signing up
When you register your company on our sign-up pages, we collect your name, phone number, email address, company name, accounts email address, company address, your signature on our agreement and any referral or promotional code you enter. What you type on the first page is saved as you type it, before you press Continue, so if you get stuck or leave before finishing, our team can get in touch to help. Each later page is saved when you press Continue. Either way, we keep what you have entered even if you don't finish signing up.
We also record how the sign-up pages are used, so we can see where people get stuck: which pages were opened, which form fields were filled in (not what was typed into them), buttons pressed, errors shown, the type of device, and the website page, advert or campaign that linked to the sign-up page. These records do not include your name, contact details or IP address, and the sign-up pages do not store anything on your device to make them.
We may also record your visit to the sign-up pages, so we can replay it and see where the process is confusing or slow. A recording captures the pages you see, how you move the mouse or pointer, scroll, tap and click, and how long you spend on each step. It is not a video of your screen and only covers our sign-up pages. Anything you type is hidden in your browser before the recording is sent to us, so recordings never contain what you type. They also never include your signature or the list of addresses found for your postcode. Recordings are linked to your sign-up, are stored on DuoApp's own systems (Microsoft Azure, UK South), can only be watched by DuoApp staff, are never sent to an analytics or advertising company, and are deleted automatically after 30 days. Making them does not store anything on your device. You can object at any time by emailing privacy@duoapp.co.uk, and we will delete your recording.
Usage data
Pages visited, features used, IP address, browser and device information, timestamps.
Customer data
Whatever you upload to the platform - projects, files, contacts, invoices. We process this on your behalf as a data processor. If your employer uses Site attendance, this also includes location data captured when you clock in or out - see Site attendance location data. If your employer has also turned on the optional Live location tracking feature, it includes your location during your working hours - see Live location tracking.
Signatures on compliance documents
If your employer uses Compliance & Certificates and you sign a certificate or health & safety document, your name, the signature you draw, the time and - if your device allows it - the device's location at that moment are recorded with the document as evidence of who signed it, when and where. Location is captured once, at signing, never in the background. Signed documents form part of the building's safety record, so they are kept for as long as your employer keeps that record. As with other customer data, your employer is the data controller.
2. How we use it
- To provide and improve the Service
- To process billing and handle support requests
- To send essential service communications
- If you start signing up but don't finish, to contact you about completing your registration
- To understand where our sign-up process puts people off, and improve it, including by replaying recordings of the sign-up pages
- With your consent, to send product updates and marketing
- To detect and prevent fraud or abuse
- To comply with legal obligations
3. Legal basis
We process personal data under the following bases (UK GDPR Art. 6): performance of a contract (account and billing), steps you ask us to take before entering a contract (processing your sign-up), legitimate interests (service improvement, security, measuring and improving our sign-up process, including recording the sign-up pages, and following up a sign-up you started but didn't finish), legal obligation (tax records), and consent (marketing).
4. Sharing
We share data with:
- Service providers who run parts of the Service for us:
- Hosting, databases, file storage and service monitoring - Microsoft Azure (UK South region, including Azure Application Insights)
- Mobile push notifications - Azure Notification Hubs, which delivers them through Apple and Google's notification services
- Subscription payments by Direct Debit - GoCardless
- Email delivery - Twilio SendGrid
- Creating PDFs of invoices, timesheets and reports - Pdfcrowd
- Address lookup and maps - getAddress.io, Ideal Postcodes and Google Maps Platform
- Spam and bot protection on our forms - Google reCAPTCHA
- Website analytics, only if you accept analytics cookies - Google (through Google Tag Manager)
- Services you choose to connect - if your administrators connect accounting software (Xero, QuickBooks or Sage) or a cloud drive (Dropbox or Google Drive), we send the relevant data to that service on your instructions. See Cloud drive integrations.
- Legal authorities - when required by law
- Acquirers - in the event of a sale of the business, subject to equivalent protections
We do not sell personal data.
5. Cloud drive integrations (Dropbox and Google Drive)
Cloud Drives is an optional feature. It only runs when an administrator of your DuoApp account connects your company's own Dropbox or Google Drive account under Admin → Cloud Drives. You sign in on Dropbox's or Google's own website; DuoApp never sees your Dropbox or Google password.
What DuoApp can access
- Dropbox - DuoApp uses Dropbox's "App folder" permission. It can only see and change files inside its own folder in your Dropbox (under Apps), and nothing else in your Dropbox.
- Google Drive - DuoApp uses Google's
drive.filepermission. It can only see and change the files and folders that DuoApp itself creates in your Google Drive (in a folder called DuoApp). It cannot see, open or change any other files in your Google Drive. - Your Dropbox or Google account's name and email address, so we can show your administrators which account is connected.
How DuoApp uses it
We use this access only to keep that folder in step with your DuoApp account:
- copying your DuoApp documents into it (project files, Quality Control and Aftercare reports and photos, approved invoices and timesheets, and your DuoApp invoices), and
- if your administrator has turned on two-way sync, bringing changes made to project files in that folder (new, edited, renamed, moved or deleted files) back into your DuoApp account.
We do not use data from your Dropbox or Google Drive for any other purpose. In particular, we do not sell it, we do not use it for advertising or marketing, and we do not use it to develop, improve or train artificial intelligence or machine-learning models. Our staff do not read it, except where you ask us to for support, where it's needed for security, or where the law requires it.
Storage and sharing
Files brought in from your drive are stored in your DuoApp account in the same way as files you upload yourself. The access tokens that let DuoApp reach your drive are encrypted (AES-256) and stored with your account. To avoid copying the same file twice, we keep a record of which documents have been copied and where they are in the folder. We do not share data from your Dropbox or Google Drive with anyone else, except the service providers who host DuoApp on our behalf, or where the law requires it.
Disconnecting
Your administrators can disconnect at any time under Admin → Cloud Drives. When they do, we ask Dropbox or Google to revoke DuoApp's access and delete the stored access tokens, and nothing more is copied in either direction. Files already in your drive stay there - they are yours. You can also remove DuoApp's access yourself from your Dropbox account's connected apps or your Google Account's third-party access page (myaccount.google.com/permissions). Our records of which documents were copied are deleted along with your other Customer Data (see Retention).
Google API Services User Data Policy
DuoApp's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
6. Site attendance location data
Site attendance is an optional feature. It only runs when a DuoApp customer company switches it on and its administrators choose which of their people use it. If you are not one of those people, the feature does not appear in your app and no location data is collected from you.
What is collected, and when
- Your device's location (latitude and longitude), how accurate the device reports that position to be, and the time - captured only at the moment you clock in or clock out of a project.
- The result of comparing that position with the project's site boundary (on site or outside the site), any reason you give for clocking in outside the boundary, and any clock-in or clock-out that an administrator adds or corrects on your behalf, with their reason.
Clock-in and clock-out on their own do not track your location continuously or in the background, and do not collect location between clock events. For this, the mobile app asks for "While using the app" location permission only. Background location is only collected if your employer has turned on the separate, optional Live location tracking feature and you have acknowledged its notice - see Live location tracking. If you clock in without a signal, the time and position are stored on your phone and sent to DuoApp automatically when a signal returns.
Why it is used
To record attendance on your employer's projects: showing who is on site now, producing a fire roll for emergency evacuation, attendance reports and timesheet records, and flagging clock-ins made outside the site boundary.
Who can see it
Administrators and managers of the company you work for (or work on behalf of), according to the permissions that company sets up. You can view your own clock history in the app. Before you first use the feature, you are shown a privacy notice and asked to acknowledge it.
Retention
Raw location coordinates are deleted automatically after a retention period set by your employer (90 days unless they choose otherwise). The on-site or off-site result and the clock-in and clock-out times are kept as part of your employer's attendance and timesheet records, for as long as your employer's attendance retention period allows (indefinitely unless they choose otherwise).
Our role, and your rights
For Site attendance data, the customer company you work for is the data controller and DuoApp acts as its data processor, processing the data only on its instructions. To access, correct or delete this data, or to object to its use, please contact your employer first. If you contact us at privacy@duoapp.co.uk, we will pass your request to them and help them respond.
7. Live location tracking (optional Site Attendance feature)
Live location tracking is an optional part of Site attendance. It is switched off by default. A customer company can only turn it on after it has completed a data protection impact assessment (DPIA) and DuoApp has reviewed it. If your employer has not turned it on, or has not included you, none of the data below is collected from you.
Our role
Your employer (the DuoApp customer company you work for, or work on behalf of) is the data controller. It decides whether to use Live location tracking, why, and for whom, and it must have a lawful basis for doing so - usually its legitimate interests, which it records in its DPIA. DuoApp is its data processor and processes this data only on your employer's instructions.
Before tracking starts
Before any tracking starts, the DuoApp mobile app shows you a clear notice. It explains what is collected, your employer's core hours and working days, and how to withdraw. You are asked to acknowledge that you have read it. You also need to give your phone's "Always" location permission. If you do not acknowledge the notice, or do not give that permission, you are not tracked. If your employer later widens your hours or changes the notice, you are asked to acknowledge it again before the new hours are tracked. Your employer keeps a register of who has acknowledged and who has declined.
What is collected
- Your device's location (latitude and longitude), how accurate the device reports that position to be, and the time it was recorded.
- Your device platform (iOS or Android).
- Your acknowledgement records (which version of the notice you acknowledged or declined, and when) and whether your phone's location permission is granted.
When it is collected
- Only during core hours. Location is only collected during the core hours and working days your employer has set. This is enforced both on your phone and on our servers: any location received outside those hours is thrown away.
- Paused on approved leave. Unless your employer chooses otherwise, nothing is collected on days when you have approved leave booked in DuoApp.
- Background updates. During core hours, your phone sends a battery-friendly location update roughly every 10 to 30 minutes, at the interval your employer sets.
- On-demand precise location. An authorised manager can ask for a precise, up-to-date location ("Locate everyone"). This only works during core hours. Every request is logged with who made it and when.
Whenever tracking is running, your phone shows it: a notification on Android, and the location indicator on iPhone.
Why it is used
To help your employer know where its people are during working hours - for example to coordinate work across sites, respond to safety incidents and support lone working. It must not be used to monitor you outside your working hours.
Who can see it
Administrators and managers of your employer who have been given permission to view it. Viewing location trails, using "Locate everyone" and exporting the acknowledgement register are all recorded in an audit log. You can see your own location trail in the app.
How long it is kept
Location updates are deleted automatically after a retention period your employer sets, between 7 and 90 days (30 days unless they choose otherwise). Acknowledgement records and DPIA records are kept so your employer can show it informed you and assessed the risks.
Sub-processors
- Microsoft Azure (UK South region) - hosting, databases and storage, and Azure Notification Hubs for sending location requests to your phone
- Apple Push Notification service - delivers those requests to iPhones
- Google Firebase Cloud Messaging - delivers those requests to Android phones
- Google Maps Platform - displays locations on a map for authorised managers
Your rights, and withdrawing
You can withdraw at any time in the DuoApp mobile app, or by turning off the app's location permission on your phone. Withdrawing stops tracking straight away and is recorded in the register. Any consequences of withdrawing for your work are a matter between you and your employer. You also have the right to access, correct or delete this data, to restrict its use, and to object to it. Please contact your employer first. If you contact us at privacy@duoapp.co.uk, we will pass your request to them and help them respond. You can also complain to the ICO at ico.org.uk.
8. International transfers
Customer Data is hosted in the UK (Microsoft Azure, UK South region). Some service providers listed above are based outside the UK, in the EU or the US; in those cases we rely on UK International Data Transfer Agreements or adequacy decisions.
9. Retention
Account data is retained for the lifetime of your account plus 30 days. Customer Data is deleted within 30 days of account termination unless you request earlier deletion. Billing records are retained for 7 years for UK tax compliance.
The details you enter on our sign-up pages are kept for 90 days after you last used them, whether or not you finished signing up, and are then deleted automatically. If you finish, the details you need for your account are copied into it and kept as account data. During those 90 days you can return to your sign-up using the link to it; after 14 days the link no longer shows your details, and you will need to enter them again. You can ask us to delete your sign-up details sooner at any time. Details you type on the first page but never submit are deleted after 30 days. Recordings of the sign-up pages are deleted after 30 days. Our records of how the sign-up pages are used contain no personal details and are kept so that we can compare how sign-up performs over time.
While an account is active, each customer company sets its own retention periods for categories of personal data in the Service: detailed location evidence, attendance records, audit and security logs, device and network details (such as IP addresses), email delivery logs, and the details of users it has deleted. When a period ends, the Service removes that data automatically: it deletes the records, removes the personal details from them, or replaces a deleted user's name and contact details with "Former user" while keeping the business records (such as invoices and timesheets) that the company must retain. Unless the company chooses otherwise, detailed location evidence is kept for 90 days and the other categories are kept for the life of the account. A company can pause automatic removal, for example during a legal claim.
10. Your rights
Under UK GDPR you have the right to access, correct, delete, or restrict processing of your personal data, plus the right to data portability and to object to processing - including asking us not to contact you about a sign-up you didn't finish, and asking us to delete a recording of your sign-up. Contact privacy@duoapp.co.uk to exercise these rights. You can also complain to the ICO at ico.org.uk.
11. Security
We use TLS 1.3 in transit, AES-256 at rest, role-based access and audit logging. Audit logs are kept for the retention period the customer company sets (see section 9).
12. Cookies
See our cookies policy.
13. Contact
Data Protection Lead, DuoApp Limited, King Arthurs Court, Maidstone Road, Charing, Ashford, England, TN27 0JS. Email privacy@duoapp.co.uk.