Data processing

1. Who this is between

This agreement is between your business, the one whose name is on the PickUp account, and Squire Holdings Ltd, the company registered at the foot of this page. It forms part of our terms of service, you accept it when you accept them at sign-up, and it starts the day your account does. It lasts for as long as we hold any of your callers' details, which can be a little after your account ends.

Where this page says you it means your business. Where it says we, us or Squire it means ours. Data protection law means the UK GDPR and the Data Protection Act 2018, as amended from time to time.

2. Which of us is responsible for what

Two different sets of personal details pass through PickUp and they are not ours in the same way.

• Your callers' details. What they said, the number they rang from, the job, where they live. That is your customer information. You decide what PickUp does with it, so you are the controller and we are your processor. This agreement is about that set.
• Your own details. Your account, your plan, your payment. We decide what happens to those, so for those we are the controller and our privacy policy is the document that applies, not this one.

Being the controller means the decisions about your callers' details are yours to make and yours to answer for. Being your processor means we do not make our own decisions about them.

3. The work we do with it

We process your callers' details only to run PickUp for you. In practice that is: answering the call, turning what the caller says into text, working out what the job is, quoting from your own price list, booking it into your diary, texting the caller a confirmation, texting and emailing you about it, and showing the whole thing back to you in your dashboard.

The full list of what is processed, whose details they are, and how long it lasts is in Annex 1.

4. We act on your instructions

We process your callers' details only on your documented instructions. This agreement, our terms and the settings you choose in your dashboard are those instructions.

• We do not sell your customer information, and we do not use it to advertise to anyone.
• We do not use it to work out who rings you so we can sell to them ourselves.
• We do not use it, and we do not let any supplier use it, to train or improve an AI model. Where a supplier's standard terms would allow that, we have switched it off or instructed them not to, as Annex 3 records.
• If the law forces us to process it some other way, we tell you before we do, unless that same law forbids us from telling you.
• If we think an instruction of yours breaks data protection law, we tell you instead of quietly carrying it out.

5. Your side of it

As the controller, you are responsible for having a lawful reason to hold your callers' details and for telling them what you do with them. In practice PickUp does most of that for you: your PickUp tells any caller who asks that it is an AI assistant, says when a call is recorded, and our privacy policy has a section written for your callers. You are responsible for the rest, including any notice your own business gives, and for only diverting a number you are entitled to divert.

If you need a written assessment before using PickUp, this page and the privacy policy are written to be the material for it, and we will answer any question it leaves.

6. The people who can see it

Only the people who need it to run the service, and only as much of it as the job in front of them needs. Everyone who can is under a duty of confidence that carries on after they stop working with us.

7. Keeping it safe

We keep the technical and organisational measures in Annex 2 in place. They are the same ones on our privacy policy, written out there because this agreement is where you can hold us to them.

We can change them for measures that are at least as good. We will not change them for weaker ones.

8. The suppliers behind us

You give us general permission to use the sub-processors in Annex 3 to run PickUp. Each is bound by a written contract that puts the same duties on them that this agreement puts on us, and we stay answerable to you for what they do.

If we want to add one or swap one, we update Annex 3 and email you at least 15 days before it starts handling your callers' details. You can object in writing within those 15 days on reasonable data protection grounds. If you do, we try to find another way. If we cannot, either of us can end the plan, and you pay nothing for the part you did not get.

Stripe is on the privacy policy and not here, because it handles your payment rather than your callers' details.

9. Sending it out of the country

Some of the suppliers in Annex 3 are outside the United Kingdom. We do not send your callers' details out of the UK except to those suppliers, and each transfer is covered in one of the three ways the law allows: the country has been found adequate, the supplier is certified under the UK extension to the EU-US Data Privacy Framework, or the supplier has signed the standard contractual clauses with the UK addendum. Annex 3 says which applies to each.

Where the safeguard is the standard contractual clauses, we have carried out and recorded a transfer risk assessment, and you can ask us for it and for a copy of the clauses. You authorise these transfers by accepting this agreement.

10. When one of your callers asks

Someone who rang you can ask for a copy of what is held about them, ask for it to be corrected, or ask for it to be deleted. That is yours to answer, because they are your customer.

• Your dashboard shows you every call, lead, booking and customer under your account, so most of an answer is already in front of you.
• If a request reaches us instead of you, we pass it to you within five working days and do not answer it ourselves.
• If you need something the dashboard does not show, ask us and we get it for you in time for you to answer within the month the law gives you.

We help with your side of the law in the same way: telling people their details are held, keeping them safe, reporting a breach, and any assessment you have to do before using PickUp.

11. If something goes wrong

If your callers' details are lost, exposed or reached by someone who should not have them, we tell you without undue delay and in any case within 72 hours of becoming aware of it.

We tell you what happened, whose details are involved and roughly how many, what it is likely to mean, and what we have done about it, and we keep you updated as we learn more. You then decide whether the Information Commissioner or the people involved need telling, because that call belongs to the controller, and we give you what you need to make it inside the 72 hours the law gives you.

12. Showing you we are doing it

We give you what you reasonably need to see that we are keeping to this agreement. That starts with this page, the privacy policy and written answers to your questions.

If you need more, ask and we give you a written summary of our security measures and answer your written questions, once in any twelve months. An inspection on our premises or systems is only where a regulator requires one of you, or a breach has happened, or the written answers cannot meet a legal obligation you have. It is on 30 days written notice, during working hours, at your cost, by you or an independent auditor bound by confidentiality, and without it stopping the service for everybody else.

13. Getting it back, and it being erased

You can take your calls, leads, bookings and customers out of your dashboard at any time while your account is open, as a file you can open in a spreadsheet. Do it before the account closes.

Transcripts and call recordings go sooner than the rest: twelve months from the call, whatever happens to your account. Your account and everything else under it stays for six months after your plan ends, then it is erased. If you tell us in that window to erase it sooner, we do it within 30 days. Backups are overwritten within 30 days after that.

We keep nothing after that except where the law makes us, which in practice means invoices and payment records and not your callers' details. We confirm the erasure in writing if you ask.

14. Liability, and which document wins

Each of us is responsible for our own compliance with data protection law. The limits on what we owe each other are in section 14 of the terms, and they apply to this agreement too, except that nothing limits either side's liability for a fine or a claim that the law says cannot be limited.

If anything in this agreement disagrees with the terms about your callers' details, this agreement wins. Sections 1 and 16 of the terms apply to it: it is governed by the law of England and Wales, and its courts deal with any dispute.

15. Changes

If the law changes or the way PickUp works changes, we update this page and move the version and date at the top, and we keep every earlier version. If a change matters to you, we email you rather than leaving you to find it, and a change that adds a supplier follows section 8.

Annex 1: what is processed

This is the detail data protection law asks a processing agreement to set out.

Subject matter

Running Squire PickUp, the AI receptionist that answers calls your business cannot.

How long it lasts

While your account is open, then the six months in section 13. Transcripts and recordings go at twelve months from the call, whichever comes first.

What is done with it

Recording a call where you have turned recording on, turning speech into text, understanding the job, quoting from your prices, booking into your diary, texting the caller and you, emailing you, storing it and showing it back to you.

Why

So you do not lose the job, and so you can ring the person back knowing what they wanted.

Whose details

People who ring your business, and people you add as customers yourself.

What kind of details

Name, the number they rang from, postcode or area, what they said was wrong, the job, when they want it, the price quoted, the time booked, a written record of the call, and the recording where recording is on.

Special category details

None asked for. A caller can say anything on the phone, so we do not promise none is ever spoken, and nothing in PickUp is built to collect it or act on it.

Annex 2: security measures

• Everything travels over an encrypted connection, and the database, its backups and uploaded documents are encrypted where they are stored.
• Database rows are reachable only by our own software using its own secret key. There is no public path to them, and the keys are rotated when anyone who has seen one stops working with us.
• Access to the systems behind PickUp is limited to the people who run it, each with their own sign in, and it is removed when they leave.
• Nothing about your account is reachable without signing in, and sign in is by a code sent to your email rather than a password that could be reused from somewhere else.
• Card details never reach our servers. They go straight from the browser to Stripe.
• Call recordings are not public. The play button in your dashboard makes a signed address that stops working after five minutes.
• If you connect Google Calendar, the keys to your diary are encrypted before they are stored, so a copy of the database on its own is worth nothing.
• Callers' numbers are kept out of our server logs, and your own number is never shown to a caller.
• The database is backed up daily, and a backup is overwritten within 30 days.
• Errors are monitored and the service is watched around the clock, so a fault is seen when it happens rather than when someone reports it.
• Transcripts and recordings are deleted by a nightly job at twelve months, and accounts are erased six months after a plan ends.

Annex 3: suppliers and transfers

Every company that handles your callers' details on our behalf, what it does, where it processes, and what makes the transfer lawful.

Twilio

Your PickUp number, the calls themselves, the texts, and the call recordings. United States. UK extension to the EU-US Data Privacy Framework.

Deepgram

Turns what the caller says into text while the call is running. United States. Standard contractual clauses with the UK addendum. Instructed on every request not to use the audio to improve its models.

OpenAI

Decides what your PickUp says next. United States. Standard contractual clauses with the UK addendum. Does not train on API content.

ElevenLabs

Speaks the reply in the voice you chose. United States. UK extension to the EU-US Data Privacy Framework. Training on our account's content is switched off.

Anthropic

Reads a price list you upload, and writes the summary after a call. United States. Standard contractual clauses with the UK addendum. Does not train on API content.

Supabase

The database everything is stored in, and the private storage for uploaded price lists. Switzerland, which the UK has found adequate.

Railway

Runs the software and the servers behind it. United States. Standard contractual clauses with the UK addendum.

Resend

Sends the emails about your calls to you. A caller's name and job appear in them. United States, sending from servers in Ireland. Standard contractual clauses with the UK addendum.

Sentry

Collects error reports. A report names your account and the request, never a caller. A United States company, but our project is held in its European Union region in Germany, and standard contractual clauses with the UK addendum cover any support access from the United States.

Google

Only if you connect a calendar. Busy times out, booked jobs in, so a caller's name and address can appear in a diary entry. United States. UK extension to the EU-US Data Privacy Framework.