Applies to: personal data processed by HANDLET LIMITED through handlet.ai, app.handlet.ai, communications, onboarding, integrations, AI-assisted features, and related services.
This Privacy Policy explains how HANDLET LIMITED collects, uses, stores, and protects personal data when you use Handlet.
ABOUT THIS POLICY
This policy is written to be clear, UK GDPR-aligned, and user-readable. It will continue to be reviewed and updated as the product and our processing activities evolve.
1. Who We Are
HANDLET LIMITED (trading as Handlet) is a company incorporated in England and Wales on 14 January 2026 under company number 16962053.
In this policy, Handlet, we, us, and our mean HANDLET LIMITED.
Under UK GDPR, Handlet acts as:
Data controller for account registration data, platform usage data, operational logs, support communications, and billing-related customer data.
Data processor where business customers use Handlet to manage communications with their own customers.
AI Assistance: Handlet uses AI for intent recognition and, where enabled, drafts, summaries, quote support, social content and call assistance. AI output can be wrong and should be checked before use. Learn More
ICO registration: Registered organisation name HANDLET LIMITED, registration reference ZC104918.
1a. Service Scope
Handlet is currently offered to businesses established in the United Kingdom. We do not intentionally offer the service to, or monitor, individuals located in the EEA, and account registration is limited accordingly. If our scope changes, we will appoint an EU representative under Article 27 EU GDPR and update this policy before offering the service in the EEA.
2. Relationship to Terms
This Privacy Policy should be read together with our Terms of Service.
Where the Terms explain how the service works, this policy explains how personal data is handled.
Where Handlet acts as a processor for customer communication data, our Data Processing Addendum also applies.
Section 3.6 explains how we use the data in your workspace, and that cross-customer benchmarking is opt-in and off by default.
3. Data We Process
Handlet processes data primarily so it can act as a digital office assistant for trades.
Personal data may also be processed on behalf of Handlet customers where they use the platform to manage communications with their own customers.
3.1 Data You Provide Directly
Account information (name, email address)
Business details (business name, trade type)
Login and authentication details
Billing and subscription information, where you become a paying customer
Support, onboarding, and account communications you send to us
3.2 Customer and Communication Data (Provided by You)
When you connect inboxes or messaging channels, we may process:
Attachments or files included in connected conversations, where supported
Job, quote, booking, complaint, review, and follow-up details contained in messages
Call transcripts, call recordings, call summaries, call outcomes, and call metadata where call-agent features are enabled
This data belongs to you and your business. In relation to customer communication data processed through the platform, the business user is typically the data controller, and Handlet acts as a data processor on their behalf.
3.2a Copies of Records From Systems You Connect
Where you connect a third-party business system, for example a job-management or CRM system, Handlet may keep its own durable copy of records from that system inside your Handlet workspace, rather than reading them from the third party each time they are shown.
We do this so that your history, reporting, and assistant features keep working when the third-party system is slow, offline, disconnected, or has removed the record under its own retention rules.
For job records, the copy may include:
the job's status and its scheduled, completed, or cancelled dates;
the service or job type;
a job value and currency, where the connected system holds one;
a link to the customer record, property, and conversation the job relates to;
free-text job notes, where the connected system holds them;
typed commercial notes about the customer, for example general, service, billing, risk, or owner notes, where the connected system holds them; and
provenance details recording which system the record came from, its identifier in that system, and whether the record was copied from a connected system or asserted by one of your own users.
Handlet also creates job records of its own when one of your users confirms in Handlet that a job happened. Each record is labelled with where it came from, so a copied record is never presented as if Handlet or your team had confirmed it directly.
What this means for retention. Once a copy exists in Handlet, it is retained under Handlet's retention rules and your deletion controls, set out in section 10, not the retention rules of the system it was copied from. Deleting a record in the third-party system does not automatically delete Handlet's copy. Deleting your workspace, or deleting the customer profile the record is attached to, does remove it.
Where Handlet holds copies of your records, we act as your processor. You remain responsible for your own lawful basis for holding that information, for complying with the terms of the system you connected, and for telling your own customers how their information is used. Handlet provides a notice template you can give to your customers, and you can request deletion at any time using the contact route in section 13.
3.3 AI-Processed Data
To provide AI assistance, we process:
Message content and metadata for intent and confidence classification
Approved media, captions, hashtags, and social post context where social post support is enabled
Call transcripts, recordings, summaries, outcomes, and metadata where call-agent or voice-assistant features are enabled
Short microphone recordings and returned text when an account user chooses voice-to-text dictation in the inbox composer
Business profile, service, opening-hours, and call-handling settings used to configure AI-assisted voice features
Message drafts, quote text, complaint or review responses, conversation summaries, and recommendations where those features are enabled
AI outputs are generated per request and are not treated as independent data sources.
3.3.1 Call Agent caller notices
Where a workspace enables Call Agent call recording retention, Handlet delivers an automated verbal disclosure at the start of the call before the AI assistant continues the conversation. The disclosure text is configured by the workspace or, if left blank, uses a Handlet default template that identifies the AI assistant and states that calls may be recorded.
The business customer remains responsible for its lawful basis for recording, sector-specific obligations, and privacy notices to its callers. Handlet acts as a processor for caller data handled on the customer's behalf.
3.3.2 Inbox voice dictation
Where enabled, an account user may choose to record up to 90 seconds of speech to enter text into an inbox reply. The recording is sent securely to Handlet's configured transcription provider only after the user finishes recording. Handlet does not retain the audio as a recording, log the audio or returned transcript, or send the reply automatically. The returned text is inserted into the existing composer, where the user can review, edit, delete, or send it through the normal inbox controls. If sent, it is retained as ordinary customer message content under the message-retention rules below. The external provider may retain request data only as allowed by the applicable business terms, account settings, and DPA.
3.4 Data Minimisation Before AI Processing
Before certain AI processing, personal data is minimised or redacted on Handlet's own infrastructure. Where practical, we remove or mask direct identifiers, such as names and contact details, before message content is used for AI processing.
Original messages are still stored securely in Handlet so the service can work, for example to show your inbox and conversation history.
3.5 Technical and Usage Data
Technical and usage data may include IP address, device information, log records, and cookies used to maintain sessions or preferences. It may also include minimised error and performance events and feature usage signals (non-content). Handlet's current Sentry configuration does not enable session replay, browser or server profiling, console-log capture, Sentry log ingestion, or default collection of personal data.
3.5a Acquisition, Advertising, and Search Data
Where a workspace enables lead-source measurement or connects an advertising, search, or analytics platform, Handlet processes data about how an enquiry reached the business.
Captured with an enquiry. When someone submits an enquiry through a Handlet quote widget, starts a chat from a landing page, or uses a click-to-message link, Handlet may record:
click identifiers passed in the link the person followed, for example Google's gclid, gbraid, and wbraid, or Meta's fbclid;
campaign labels: the advertising platform, advertising account, campaign, ad group, ad, and creative identifiers;
UTM parameters: utm_source, utm_medium, utm_campaign, utm_term, utm_content, and utm_id;
page context: the landing page host and path, and the referring website's host. Handlet does not store the full query string of the page address;
consent state: whether consent for this measurement was recorded as granted, denied, not required, or is not known; and
attribution details: the time zone used, when the attribution lookback window expires, and whether the enquiry could be attributed, could not be attributed, conflicted with another signal, expired, or has been erased.
These identifiers are collected server-side from the link that was followed. Handlet does not set advertising or cross-site tracking cookies on your website or on Handlet, and does not build a cross-site identity profile. Where a landing page hands a visitor to a Handlet chat, this uses a short-lived, single-use token; Handlet stores only a hashed form of that token, never the token itself.
A click identifier does not name a person on its own. Once it is attached to an enquiry it can connect that person's advertising click to their later enquiry with you, so we treat it as personal data and retain it only for the limited period in section 10.
Retrieved from platforms you connect. Where a workspace manager connects a platform using their own account, Handlet retrieves reporting data using that authorisation:
Google Ads: campaign, ad group, keyword, and creative performance metrics for the advertising accounts you select. Where you enable conversion measurement, Handlet may also upload offline conversions back to your own Google Ads account. Those uploads contain a click identifier, a conversion action, a timestamp, a time zone, an order reference, and a value. Handlet does not send hashed emails, phone numbers, names, or addresses to advertising platforms, and does not use customer-matching or enhanced-conversion features.
Google Search Console: a short-lived snapshot of search performance for your verified site, including top search queries, top pages, clicks, impressions, click-through rate, and average position. Search queries can be free text. Google withholds rare and sensitive queries at source before Handlet receives them.
Google Analytics 4: aggregated report data for the property you select. Connecting GA4 does not add Google Analytics scripts or cookies to your website or to Handlet. Google Analytics collects and processes data as described in How Google uses information from sites or apps that use our services.
Handlet asks these platforms only for reporting data, and does not request or store personally identifying fields from them. Where a connected platform's own terms prohibit sending it personally identifying information, as Google Analytics does, Handlet does not send any.
Restrictions we accept. Data Handlet obtains from Google APIs, and anything aggregated or derived from it, is used only to provide or improve the Handlet features you see in your own workspace. It is not used to serve, retarget, or personalise advertising; it is not transferred to advertising platforms, data brokers, or information resellers; it is not used to train generalised artificial-intelligence or machine-learning models; and it is not used for any cross-customer benchmark or insight product. See section 8a.
Your responsibilities. You are the controller of measurement carried out on your own website and of your own accounts on these platforms. You are responsible for the consent your own site collects before advertising and analytics identifiers are set or read on a visitor's device, for the notice you give visitors, and for complying with the terms of each platform you connect. Handlet records the consent state it is given; it does not collect that consent on your behalf. Where a consent state is unknown, that is shown in your attribution reporting rather than assumed to be consent.
3.5b Where early-access visitors came from
If you accepted optional cookies on our website and then join the early-access waitlist, we save where you first arrived from alongside your waitlist entry: the campaign tags in the link you followed, the kind of site that referred you and its host name, the name of the first Handlet page you saw, the plan you looked at on the pricing page, and roughly when you first arrived. We do not save the full web address, the page you came from beyond its host name, or anything you typed.
We use it to understand which campaigns and sites bring customers who go on to use Handlet, so that we can spend our effort in the right places. It is not used to make decisions about you individually. Our lawful basis is your consent to optional cookies (section 6); if you do not accept them, none of it is collected. It is kept for as long as your waitlist entry and is deleted with it. Withdrawing consent through Cookie settings removes it from your browser, though it does not remove what was already saved with a waitlist entry: ask us to delete your entry (section 13) and it goes with it.
3.5c How we measure use of the product while you are signed in
When you use Handlet, our servers keep a record of how your workspace is doing so we can run and improve the service: whether a channel has been connected, whether replies are being sent, how often, whether your subscription is active, and a broad status for the account (for example "active", "quiet" or "at risk"), updated daily. We also use it to see which parts of the product customers use and where people get stuck. These records contain counts, dates and categories. They do not contain the text of your messages or your customers' details.
This is done on the basis of our legitimate interests in running, securing and improving the service and in supporting customers who are having trouble (section 6), and it does not depend on cookies. It is used at account level, not to make decisions about you individually.
If you also accepted optional cookies, a few of these milestones (first reply sent, subscription checkout completed, the broad account status, and whether an AI-assisted reply was sent as written or edited) are sent to Google Analytics, linked to the same identifier as the rest of your visit. If you do not accept optional cookies, nothing is sent to Google Analytics. Withdrawing consent through Cookie settings, or signing out, stops further sending.
These records are deleted when your account is deleted. Payment event records are the exception: we keep them, without the link to your workspace, for as long as the law requires us to keep financial records.
3.6 How We Use the Data in Your Workspace
Unless you opt in to benchmarking (below), we use the messages, contacts, customer records and other data in your workspace only to run your own workspace. This includes keeping the service secure, giving you support you ask for, and meeting our legal duties.
Handlet never sells your messages, your contacts or your CRM records.
Cross-customer benchmarking and learning are opt-in and off by default. They only start if you switch them on in Settings, Intelligence Network, and you can switch them off at any time. If you opt in:
your data is only used after it has been combined with data from other workspaces that have also opted in, so that the results do not identify you, your customers or anyone else;
combined results may be shown as benchmarks and insight reports, including reports for partners, but these never include raw messages, contact details, call recordings or CRM records; and
data from Google APIs and records copied from a connected CRM are never used, even if you opt in.
Where you opt in, Handlet is the controller for that benchmarking. We tell your customers about it through this policy rather than contacting each of them, because that would involve disproportionate effort and only combined, de-identified data is used. Your customers can contact [email protected] with questions.
3.7 Data Sources
We collect personal data from:
you and users you invite to your Handlet account;
connected channels you authorise, such as email or messaging providers;
your customers and contacts where their messages are imported into Handlet;
third-party business systems you connect, such as a job-management or CRM system, where Handlet keeps a copy of records held there (section 3.2a);
advertising, search, and analytics platforms you connect using your own account, and the links your customers follow to reach you (section 3.5a);
service providers that support authentication, billing, hosting, messaging, analytics, support, or security; and
technical logs generated when the service is used.
4. Purposes of Processing
We process personal data to:
Provide and operate the Handlet service
Deliver inbox, quote, and review assistance
Classify message intent and confidence
Support AI-assisted social post content generation where enabled
Support AI-assisted drafts, summaries, quote text, complaint-response preparation, or recommendations where those features are enabled
Keep a durable record of jobs, payments, and customer history in your workspace, including copies of records from systems you connect
Show you where your enquiries came from, and measure the cost and return of the marketing channels you use
Maintain security and prevent misuse
Improve reliability and performance
Communicate with you about the service
We do not sell personal data.
Cross-customer benchmarking only happens if you opt in, as explained in section 3.6.
Handlet only processes personal data that is necessary to provide the service and avoids collecting unnecessary personal information.
Handlet is not intended for use by children under the age of 16, and we do not knowingly collect personal data from children.
6. Legal Bases
Depending on the context, we rely on:
Contractual necessity: to provide the service you signed up for
Legitimate interests: to operate, secure, diagnose, and improve the reliability of Handlet, subject to documented balancing assessments where required
Consent: where required for optional analytics, storage, or non-essential electronic marketing
Legal obligation: where required by law
When you authorise Handlet to connect with a third-party provider, that authorisation is a technical permission. It does not by itself mean that UK GDPR consent is our lawful basis for the underlying processing.
Special category data. Handlet does not ask for special category data (such as health information). Customer messages and call transcripts are free text and may incidentally contain it. Where Handlet acts as a processor, the business customer (controller) is responsible for establishing an Article 9 condition for any special category data in its customers' communications, and our Data Processing Addendum reflects this. Where Handlet acts as a controller, we rely on Article 9(2)(g)/(2)(e) as applicable and our data minimisation step reduces the likelihood of such data being sent to external providers.
7. AI Processing, Profiling, and Automated Decisions
Handlet uses AI to assist, not replace, human decision-making.
AI assistance and transparency. AI outputs are suggestions only, generated per request. Where our AI voice assistant (Call Agent) speaks with your customers, it identifies itself as an AI assistant at the start of the call and never claims to be a human. AI-assisted drafts (messages, quotes, review and complaint responses, social posts) require human review by default. You remain responsible for content you approve, publish, or send.
Profiling. To provide its features, Handlet analyses message and conversation data to derive structured signals, for example message intent, confidence scores, sentiment and urgency, response/lead-quality signals, quote and outcome patterns, and tone/preference ("Brain") memory. This analysis is profiling under data-protection law. It is used to assist you in running your business and does not produce decisions with legal or similarly significant effects on individuals.
Automated sending (optional). By default, AI-assisted replies are held for your review. Some workspaces may enable automated sending for narrowly-scoped, high-confidence message types. Where enabled, an AI-drafted reply may be sent to a customer without a human reviewing that specific message. You can disable this at any time, and recipients can ask to deal with a human; contact [email protected] to request human review of, or to object to, automated sending that affects you.
Cross-customer learning is opt-in and off by default, as explained in section 3.6.
8. Data Processors
Handlet uses trusted processors to deliver the service.
These may include:
Hosting and databases (e.g. Supabase)
Authentication providers (for example Google OAuth)
AI service providers
Email and messaging infrastructure
Voice and telephony providers
Monitoring, analytics, and support providers
Property lookup providers
Security and abuse-prevention providers
We aim to have suitable data protection terms in place with each provider, and we limit what each provider receives to what it needs for its service.
8a. Platforms You Connect, and Google API Limited Use
Some providers are not Handlet's processors at all. Where you authorise Handlet to connect to a platform using your own account, for example a CRM, Google Ads, Google Search Console, or Google Analytics, Handlet accesses that platform on your instruction. Your relationship with that platform, and its own privacy terms, continue to apply to it. The connected platforms in use are listed in our Subprocessors page under connected services.
Google API Services User Data Policy. Handlet's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically, data obtained from Google APIs, and any data aggregated, anonymised, or derived from it:
is used only to provide or improve user-facing features that are prominent in the Handlet interface for the workspace that granted access;
is not transferred to or sold to third parties for advertising, market research, credit assessment, or similar purposes, and is not transferred to data brokers or information resellers;
is not used for serving, retargeting, or personalising advertisements;
is not used to develop, train, or improve generalised artificial-intelligence or machine-learning models, and is not shared with any third party for that purpose; and
is not read by humans unless we have your explicit consent for specific data, it is necessary for security purposes or to comply with applicable law, or the data is aggregated and anonymised for internal operations.
We do not transfer information received from Google APIs to another Handlet workspace, and we do not include it in any cross-customer benchmark, insight product, or external example.
9. International Transfers
Some providers process personal data outside the UK. Where they do, UK GDPR requires the transfer to be covered by a safeguard, such as UK adequacy regulations (which cover the EEA), the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses.
Our Subprocessors page shows where each provider is based. To ask about the safeguard for a particular provider, email [email protected].
10. Data Retention
We retain data only as long as necessary to provide the service and meet legal obligations.
Current retention criteria are:
Data category
Typical retention
Account and workspace data
While the account is active, then deleted or anonymised after account deletion unless retention is required for legal, security, tax, accounting, or dispute purposes.
Customer messages, conversations, drafts, attachments, quotes, and related message metadata
While the workspace uses the service or until deletion is requested and completed, subject to backup, audit, legal, security, and provider retention limits.
Inbox voice-dictation audio
Transient request processing only; Handlet does not persist the recording. Returned text follows the ordinary draft/message retention rule only if it remains in the composer or is sent. Provider-side handling remains subject to the applicable business terms, account settings, and DPA.
Call recordings
Controlled by the workspace recording policy where call-agent features are enabled. Callers hear an automated verbal disclosure at call start when recording retention is enabled. The default recording retention period is 90 days unless the workspace configures another valid period, keeps a specific recording, or disables recording.
Call transcripts, call summaries, call outcomes, and related call metadata
Controlled by the workspace recording policy where call-agent features are enabled. The default transcript retention period is 24 months (730 days) unless the workspace configures another valid period or keeps a specific transcript. After the retention period, Handlet automatically redacts transcript text and related call insights from primary storage; recording audio may already have been removed under the separate recording retention period above. Subject to legal, security, backup, and provider retention limits.
Technical, diagnostic, and security logs
Retained for limited operational and security periods. Security or incident records may be retained longer where needed to investigate abuse, fraud, reliability, or legal claims.
CRM connection secrets
Deleted immediately when credentials are revoked or the connection is removed.
CRM import rows and external reference data
Typically retained for 30 days after relevant cleanup triggers.
CRM matching and participant index metadata
Typically retained for 90 days after relevant cleanup triggers.
CRM connection and mapping metadata
Typically retained for up to 365 days after relevant cleanup triggers.
CRM audit and manual-resolution records
Typically retained for up to 730 days for accountability and dispute handling.
Job records in your workspace, whether copied from a system you connect or confirmed by one of your own users, including status, dates, service type, value, and job notes
Retained for the life of the workspace, or until the workspace or the linked customer profile is deleted, or until you request deletion. Not governed by the retention rules of the system the record was copied from; deleting a record in that system does not delete Handlet's copy.
Payments your customers made against a job or quote, recorded in your workspace
Retained for the life of the workspace, or until you request deletion. Deleting a conversation removes the link to that conversation but preserves the financial record. Retained where required for your tax, accounting, legal, and dispute purposes.
Advertising click identifiers (such as gclid, gbraid, wbraid, fbclid), free-text UTM values (utm_term, utm_content), and the landing page path
Retained only until the attribution lookback window for the enquiry expires, or until erasure is requested, whichever is first. On erasure the identifiers are removed and the touchpoint is marked as erased.
Landing-page handoff tokens
Only a hashed form of the token is stored. Expires and is emptied on use or on token expiry; identifiers are removed on erasure.
Non-identifying campaign, ad, creative, and UTM labels, and advertising performance metrics
Retained while the platform connection exists, then purged when you disconnect the platform or delete the workspace.
Google Search Console snapshot (top queries, top pages, clicks, impressions, position)
A short-lived cache only. Overwritten approximately every hour, capped at 10 queries and 10 pages, and deleted when the connection or website is removed.
Google Analytics 4 report cache
A bounded cache per connection and period, overwritten on refresh and deleted when the connection is removed.
Advertising, search, and analytics connection credentials
Deleted immediately when the connection is revoked or removed.
Billing, invoice, dispute, tax, and accounting records
Retained where required for tax, accounting, legal, and dispute purposes.
Data subject request, privacy, security, and audit records
Retained as needed for accountability, legal claims, security, and compliance.
Privacy complaints
Normally retained for six years after closure where needed to demonstrate complaint handling, resolve disputes, establish or defend legal claims, and meet accountability obligations. Information that is no longer needed is deleted or minimised earlier where appropriate.
Primary-store deletion or redaction of call recordings and transcripts is applied in Handlet's database when the applicable retention period expires or when deletion is requested. Copies may remain recoverable from infrastructure backups (including Supabase point-in-time recovery and daily backups) until those backup windows expire, as described in our Data Processing Addendum and operational retention records.
You can complain about Handlet's handling of personal data using our privacy complaint form, by emailing [email protected], or by writing to our registered office.
We will:
acknowledge your complaint promptly and no later than 30 days after receipt;
take appropriate steps to investigate it without undue delay;
tell you the outcome once our investigation is complete; and
keep you informed of progress where an investigation is not completed promptly.
You may complain to the ICO at any time. You do not have to complete Handlet's complaint process first.
13. Exercising Rights
During MVP, requests for your data (including access, correction or deletion) are handled manually.
To make a request, email [email protected]. We may need to verify your identity and, where a request relates to your customers' data, confirm whether we should handle it directly or support you as the controller.
We aim to respond within one month, as required by UK GDPR. If a request is complex or you make multiple requests, UK GDPR may allow extra time and we will tell you if that applies.
14. Security
We take reasonable technical and organisational measures to protect personal data. These may include secure hosting, access controls, encrypted connections (HTTPS), and monitoring systems.
However, no system is completely secure, and we cannot guarantee absolute security.
15. Changes
We may update this Privacy Policy from time to time.
If changes are material, we will notify users via email or in-app notice. The "Last updated" date at the top of this page will be revised when we make changes.
16. Cookies
We use strictly necessary cookies to maintain login sessions and remember interface preferences. We do not use cookies for advertising or to track you across other websites.
The advertising identifiers described in section 3.5a are read server-side from the link a visitor followed. They are not collected using Handlet advertising cookies, and Handlet does not place advertising or cross-site tracking cookies on a customer's website. Where a business's own website sets advertising or analytics cookies, that business is responsible for the consent and notice required for them.
For detailed information about the cookies we use, please see our Cookie Policy.