Privacy notice — customers
Privacy notice — customers (APPROVED 2026-08-27, was v1)
APPROVED BY DAN, 27 August 2026 (869eqx27v): "I have read the complete GDPR pack, I approve all of it." The draft banner is lifted on every document in this pack at once, which is what he asked for. What his approval is not: it is not legal advice, no solicitor has read any of it (his decision of 2026-08-19, 869ef85a2), and it did not create the DPIA that §12.6 of the LIA says is needed before the first bulk-file sale — that DPIA was written on 2026-08-29 at his instruction (869eqy933 Q2) and is at docs/gdpr/DPIA-BULK-DATA-FILE.md; it is drafted and awaiting his sign-off, which is a different thing from approved. The history below is kept as written.
History — status was: DRAFT v1 (2026-08-24). Written by Claude for ticket 869enj3v8. Not legal advice, and not approved. No solicitor has read it: on 2026-08-19 (ticket 869ef85a2) Dan decided not to commission a formal review at this stage, having discussed the business model and this documentation with a solicitor in detail. Dan reviews, amends and approves before this binds anyone; until he sets KESTREL_LEGAL_APPROVED=1 every page on this site carries a draft banner saying so.
Why it exists. Everything published before it was written for planning applicants — the people whose details we take from public registers. Nothing covered the people who subscribe. This notice is that half, and it was written by reading the database models rather than from memory: every category below is a real column in a real table, and the sections say which part of the service creates it.
The contact address is now hello@justgranted.co.uk, on Dan's instruction (869ee2apd, 2026-08-27). The trading name changed from Plan & Post to Just Granted on 2026-08-20 (869em1n5x), the website moved on 2026-08-24 (869em1nqu) and the mailbox followed on 2026-08-25 (869em1ny7), proved by a real message delivered each way. hello@planandpost.co.uk is an alias on the same mailbox and is kept receiving indefinitely, so an email sent to the address this notice used to print still reaches us.
Who we are
Just Granted is a trading name of Blueworkz Ltd (company number 13258077), registered at 39 Crispin Field, Pitstone, Leighton Buzzard, LU7 9BG, United Kingdom. Blueworkz Ltd is the data controller for the personal data described here.
Contact us at hello@justgranted.co.uk, or by post at the registered address above. We have not appointed a data protection officer; we are not required to.
Who this notice is for
This one is about you, our customer — the people at a subscribing business. That means:
- anyone who creates or is invited into a Just Granted account;
- anyone whose email address is on a Just Granted account, including colleagues invited by an account admin and people named as the recipients of spend alerts;
- anyone who joins the waiting list or begins a signup, whether or not they ever pay us anything.
It is not about the planning applicants our subscribers write to. They have their own notice, because the two relationships have different lawful bases, different rights and different retention, and one page covering both is a page nobody reads. The applicant notice is at justgranted.co.uk/legal/privacy/.
Most of what we hold about you is business-contact information about a person acting for a business. Some of it is not so tidy: a sole trader's business address is often a home address, and a one-person company's records are records about one person. We treat it all as personal data.
What we do not do, first
It is shorter than the list of what we do, and it is the part people usually want to know.
- No analytics running today — and consent before any is. There is no Google Analytics, no Plausible, no Matomo, no Hotjar, no advertising pixel and no third-party tag of any kind anywhere on this site right now, and our browser test suite asserts that the public pages — the front page, the search preview, the council and area pages and the guides — make no external request at all, so today this is a property the code has to keep rather than a promise we remember to keep. We do intend to add website analytics (Google Analytics, and possibly a tool such as Hotjar that records how pages are used). When we do, four things happen together: this notice is updated to name the tool and what it collects before it is switched on; the analytics cookies are set only if you agree, asked with a banner where refusing is as easy as accepting; refusing costs you nothing on the site; and it stays measurement of how the site is used rather than a profile of you. Nothing of the sort touches the people we write letters to — analytics is about visitors to our website, and a planning applicant is not one.
- No profiling of visitors. An anonymous visitor gets no cookie, no session and no identifier of any kind, and is not followed from one page to the next. Two rows can nevertheless be written by a stranger who uses the free postcode preview, and neither is about a person: an anti-abuse counter held against a salted, irreversible hash of the caller's network address for two days, and a postcode's map coordinates added to a lookup table of places. Both are set out under "Our server logs, and the free preview" below, because a notice that said "no row" would be tidier and would not be true. If we turn analytics on as described above, the only cookie you get is one you agreed to — and the first record we write about you is still written when you hand us an email address.
- No profiling and no automated decision-making that produces legal effects or anything similarly significant for you.
- No selling, no sharing for advertising, no list rental. We do not sell personal data, we do not buy marketing lists, and we do not pass your details to data brokers or ad networks.
- We never see your card. Card numbers are entered on pages hosted by Stripe and never touch our servers. What we hold is Stripe's identifiers and the amounts on invoices.
- We do not read your letters to sell you something else. Letter text is stored so that we can show you what was sent and answer a complaint about it; that is all it is for.
What we hold, why, and on what basis
Your login
Email address, first and last name, your role on the account (admin or subscriber), the date you joined, the time you last logged in, and the time of your current and previous visit — the last pair is what makes the "new since your last visit" list on the applications screen work.
Your password is never stored. What is stored is a one-way hash (PBKDF2-SHA256 with a per-password salt), which cannot be turned back into your password by us or by anybody who steals the file. Nobody at Just Granted can tell you what your password is, only reset it.
Email verification links, invitation links and unsubscribe links are signed rather than stored — the link proves itself, so there is no table of live tokens to leak.
Lawful basis: contract (UK GDPR Article 6(1)(b)) — we cannot give you an account without them.
Your business
Company name, address, town, postcode, phone number and logo; the plan you are on and the date it is paid until; which councils you subscribe to and which are your defaults; whether you hide applications with no published applicant name; and how you want letters addressed when a council publishes no name.
Some of this is printed on paper and posted to strangers. Your business name, address, phone number and logo appear on the letters you send, because a letter has to say who it is from. Once posted, that is out of our hands and in a recipient's letterbox. Everything else in this section stays inside the service.
Lawful basis: contract.
Colleagues you invite
An invitation stores the email address you typed, the role you chose, who sent it, when it was sent and accepted, and which account it was for. We email that person because you asked us to. If they do not accept, the invitation stays as an unaccepted row until the account is deleted; tell us and we will delete it sooner.
Lawful basis: contract with the subscribing business, and our legitimate interests in letting a business run a team account.
How you use the service
- Saved searches — the name you gave a filter and the filter itself.
- Applicant reveals — which applicants your account has been shown in the clear, so an allowance can be counted.
- Exports — an audit row every time applicant data leaves the platform: which user, when, what was asked for, how many rows came back, how many were withheld as suppressed, the file format, and whether the export hit its cap. This exists because personal data leaving a system is a thing a controller has to be able to account for, and it names the person who did it.
- Council subscriptions — which councils, from when to when, and who added them.
Lawful basis: contract for the features themselves; legal obligation and our legitimate interests in accountability for the export audit log (Article 5(2)).
The letters you send
Templates you write, including the body text, images, watermark, fonts, QR link and who created them. Batches, including who built them, when they were dispatched, and how many recipients were skipped and why. Individual letters, including the delivery status, the printer's own reference, what it cost, what you were charged, any error, and a snapshot of the body as it was actually sent.
Alongside those, an append-only send audit: every attempt to spend your money, whether it succeeded or was refused, the reason, who authorised it, and whether it was a test. It is written whether the attempt worked or not, and it cannot be edited afterwards. If you use automated workflows, we also keep each run: what it matched, what it skipped, what it would cost, and who approved it or whether it was approved automatically when the window closed.
Lawful basis: contract for sending at all; legal obligation for keeping records of what was sent; and our legitimate interests in being able to answer a complaint about a letter, and in stopping money being spent that nobody authorised.
Money
Your Stripe customer and subscription identifiers, your subscription status, and whether the account is live or test. Paid invoices as Stripe reports them: the invoice number and identifier, the date, the currency, what was charged for subscription and for postage, and the processing fee. Movements of prepaid letter credit, including any note and who recorded it. Your monthly spend cap and who set it, the threshold at which spend alerts go out, the email addresses those alerts go to, and a record of each alert actually sent.
We hold no card number, no expiry date and no security code. Payment is taken on Stripe's own hosted pages, and cancellation happens in Stripe's own customer portal.
Lawful basis: contract, and legal obligation for the accounting records — which is why they outlive the account. See retention, below.
Emails we send you
Two different things, and the difference matters.
Transactional email — email verification, invitations, password resets, receipts, dispatch confirmations, spend-cap warnings — is part of the service. It cannot be switched off while you have an account, because it is not marketing and there is nothing to consent to. Lawful basis: contract.
Optional email — the weekly lead alert, a newsletter, and tips and how-tos — is sent only if you have said yes. Lawful basis: consent (Article 6(1)(a)), and you can withdraw it at any time from your email preferences or from the unsubscribe link in any of them. Three details worth stating, because they are properties of the code rather than intentions:
- No record means no. Consent is stored per person and per category, and the absence of a row is a refusal, so a new category is off for everybody until they turn it on. Consent is personal, not corporate: two people at the same firm can want different things.
- We keep the history, not just the answer. Every decision is recorded in the order it was taken — what you chose, when, and by which act of ours. The "act" is a closed list of our own words (
settings,unsubscribe-link,registration,staff,trade-preset); it is never a URL, an IP address or a user agent. - We keep the words you were shown, not just the answer. Added 2026-08-26 (ticket
869ephc5a, v0.396.0). Alongside each decision we store the sentence that was printed beside the box at the time — for example, the sign-up form's "Email me the free weekly lead alert — one email a week listing the new planning applications that match my saved searches…". It is stored once and never edited or back-filled, so if we reword the form your record keeps the wording you actually read. You can see it yourself: it is printed in the "Your consent record" table on your email preferences page. Where the wording was a whole page rather than a label — an unsubscribe page, or a change you asked us to make by email — that field is blank rather than filled in with a reconstruction. - The sign-up form asks, and it asks separately. Since 2026-08-26 the registration page carries one optional, unticked box for the weekly lead alert. It is not bundled into creating the account or into accepting the terms, it is never pre-ticked, and leaving it alone does not stop you registering — nor does it record anything at all, because no record means no.
- For the weekly lead alert we also record that it was attempted: the date, the period it covered, how many applications matched, how many searches it ran, and whether it was delivered. Lawful basis for that record: our legitimate interests in being able to see whether the thing we promised is arriving.
The funnel — five rows, and this is all of them
We record whether the money we spend on marketing actually produces customers. It is the smallest measurement that answers the question, and it is worth writing out in full because it is the section people expect to be the worst.
We record five milestones per account, once each, ever: signed up, first search, first letter drafted, first letter posted, first payment. Each row carries the account, which of the five it is, the campaign and source that won the account, and the time. A uniqueness rule in the database makes "first" mean first, so the table grows with customers rather than with traffic — five rows per account is the maximum, not an average.
What a row does not carry: not your name, not your email address, not your IP address, not your user agent, not the URL you were on, not your search terms, not a session identifier, not a cookie, and never a planning applicant's name, address or postcode. Nothing about it makes a request to anybody outside our own server. It is not analytics and it is not permitted to become analytics.
Alongside it, your account carries the campaign and source it arrived with — for example a utm_source on a link, or the referring site, or "direct" — captured once at signup. An account created before 22 August 2026 carries "unattributed", because we never asked.
Lawful basis: our legitimate interests in knowing whether our marketing works before spending more on it. The impact on you is minimal by construction: five rows, about a business rather than a person, never combined with anything else.
The waiting list
If you asked to be told when we open, we hold your email address, which box on the site you used, which campaign brought you, and when. Nothing else — no name, no IP address, no cookie.
Lawful basis: consent. We use it for one email when we open, and you can tell us to delete it at any time.
When our staff look at your account
Our support staff can, when there is a reason to, open the service as your account in order to see what you are seeing. Every start and every stop is recorded: who did it, whose account, the reason given, the time, and the operator's own IP address. The audit row is written before the switch happens, so a failure halfway leaves evidence rather than silence. The IP address recorded is our operator's, not yours.
Lawful basis: our legitimate interests in supporting the service and in being able to account for staff access to customer data.
If you use the AI letter drafter
Drafting a letter with AI sends the brief you typed and your company name to Anthropic, our processor for that feature, and sends back letter text. We do not send your customer list, your applicant data, or anything else about your account.
We keep a log of each attempt: which account and which user, the provider and model, how many tokens went in and out, what it cost, and whether it succeeded or was refused and why. We do not store the brief and we do not store the prompt. Because the brief goes to a third party, do not type other people's personal details into it.
Lawful basis: contract for the feature; legitimate interests for the usage log, which exists to enforce a fair-use quota and to know what the feature costs.
Cookies
Two, both strictly necessary, both first-party:
- a session cookie, which is what keeps you logged in;
- a CSRF cookie, which stops another site submitting a form as you.
Both are marked HttpOnly or SameSite as appropriate and are sent only over HTTPS in production. Strictly necessary cookies do not need your consent, and these two are the only cookies there are today: no analytics cookies, no advertising cookies, no third-party cookies. That is why you have not been asked to agree to anything — there is nothing to ask about — and an anonymous visitor is not given a session at all.
If that changes, the banner arrives with the cookie, not after it. We intend to add website analytics (see "What we do not do, first"). A non-essential cookie may only be set with consent under the Privacy and Electronic Communications Regulations, so on the day analytics is switched on there will be a consent banner that lets you refuse as easily as accept, refusing will leave the site fully usable, and this section will be rewritten to name the cookies, who sets them and how long they last — before they are set, not afterwards.
Our server logs, and the free preview
Our web server and application logs may contain IP addresses and requested URLs, as every web server's do. They are used for security and diagnosis and nothing else, and they are kept for 90 days.
The postcode you type into the free preview is inside one of those URLs. The preview asks our own server a question of the form /preview/nearby/?postcode=...&radius=..., so for those ninety days the access log holds the postcode you asked about next to the network address it came from. We say that out loud rather than leave it inside the words "requested URLs", because the postcode is the one thing on that page a visitor might mind.
One other organisation is sent the postcode, and only sometimes. To put your area on the map we need that postcode's coordinates. We keep our own lookup table of them, and if yours is not already in it our server asks postcodes.io — a free, key-less public service built on Ordnance Survey's open Code-Point data — for it. What is sent is the postcode on its own, from our server: never your name, never your network address, never anything about who asked or why, and nothing at all if the postcode is already in our table, which most are because they came from the planning registers. The answer is then kept for good, because a postcode's coordinates do not move and asking a free service the same question twice would be rude. That row is a place rather than a person — a postcode, two numbers and the date we asked, with nothing recording who wanted to know — which is also why we have not treated the lookup as a transfer of your personal data under "Where it goes" below.
The preview is also rate-limited without identifying anybody. It stores a salted, irreversible hash of the caller's address — never the address itself — and rows older than two days are deleted. Salting with our own deployment secret means the table cannot be worked backwards into a list of visitors.
Lawful basis: our legitimate interests in keeping the service available and free from abuse, and in answering a visitor who has asked us what we hold near them.
The map, and why OpenStreetMap never sees you
The map on the public site is drawn on OpenStreetMap imagery, and the ordinary way to do that would send your browser to tile.openstreetmap.org — twenty or so requests every time the map moves, each one carrying your IP address and the coordinates of what you are looking at, to an organisation you have no relationship with.
We do not do it that way. Your browser only ever talks to us. Our own server fetches each square of the map once, keeps a copy, and serves that copy to everyone afterwards. What OpenStreetMap sees is our server asking for a picture of a place; it is never told who asked, and after the first time it is not asked again for a month. Nothing about you — not your address, not your postcode, not the fact that you looked — reaches them, which is why they are not in the list of processors below. The postcode itself is a different question with a different answer, and it is answered above: that does go to postcodes.io, which is in the list.
The map imagery is © OpenStreetMap contributors and the credit is on the page beside it, as their licence requires.
The lawful bases, in one place
- Article 6(1)(b), contract — your account, your company record, sending your letters, taking your money, and the email that is part of the service.
- Article 6(1)(c), legal obligation — accounting and tax records, and records that let us account for personal data leaving the system.
- Article 6(1)(f), legitimate interests — security and abuse prevention, support, spend safety, complaint evidence, and measuring whether our marketing works. We have weighed these against your rights: they concern people acting in a business capacity, involve no profiling and no special category data, and none of them changes any decision that affects you.
- Article 6(1)(a), consent — optional marketing email, and the waiting list. Withdrawing it is one click and costs you nothing else.
We do not process special category data about customers (Article 9), and we do not knowingly hold data about children.
Who else sees it
Everyone on this list, and nobody else. Each is a processor acting on our instructions unless it says otherwise.
- Stripe — payments, subscriptions, invoices and the customer portal. Receives your business name, the account admin's email address and an account reference; takes and holds the card details we never see. Stripe is also a controller in its own right for its own fraud and regulatory purposes.
- Stannp Ltd — printing and posting. Receives each letter as artwork, which carries your business name, address, phone number and logo, together with the recipient's address. Acting under a written contract meeting Article 28 of the UK GDPR.
- Zoho — our mailbox and outgoing mail. Every email we send you, and every email you send us, passes through it. Zoho's EU data centre.
- Anthropic — only if you use the AI letter drafter, and only the brief and your company name. See above.
- DigitalOcean — the London server the service runs on, and the London object storage that holds our nightly backups. The backup is a complete copy of the database, so everything in this notice is in it.
- Backblaze — a second, independent copy of the same nightly backup, in their European (Amsterdam) data centre. It exists so that losing the London server does not lose your account, your letters, your invoices or the audit records that account for them. Storage only: Backblaze is never sent anything else and never reads it.
- postcodes.io — not a processor of ours, and under no contract with us: a free, key-less public lookup service, which our server asks for a postcode's map coordinates when the free preview is given a postcode our own table does not already hold. It receives that postcode and nothing else — not your name, not your address, not your network address, not the fact that it was you who typed it. It is named here because it is the only outside service a signed-out visitor's search touches at all.
- Organisations who purchase a bulk data file — named here because a privacy notice has to list categories of recipient, and this one is new (decided 2026-08-27; nothing has been sold). It is a licence of planning-application data — the public-register information described in the applicant privacy notice at justgranted.co.uk/legal/privacy/ — to an organisation that wants it for market research. Nothing about you or your account is in it: not your name, your email, your company record, your letters, your templates or your invoices. Our customer list is not for sale and is not licensed to anybody.
We are a small company, and the people with access to customer data are few. Staff access to an account is audited as described above.
Where it goes
Our database is on a server in the United Kingdom, in London, and the service reads and writes it there.
Three flows leave the UK. Our mail passes through a European data centre, so every email between us crosses it. Our second backup copy is held in a European (Amsterdam) data centre by Backblaze — the first copy stays in London. For both of those the UK recognises the EEA as providing an adequate level of protection. The AI drafting feature, if you use it, sends the brief to a provider in the United States. That transfer is made under the safeguards UK data protection law requires — an adequacy decision, or the ICO's International Data Transfer Agreement or Addendum.
Payment data is held by Stripe, which operates internationally under its own arrangements.
How long we keep it
The published retention policy at justgranted.co.uk/legal/retention/ is the approved timetable, and it is now the only one: the periods below were approved on 29 August 2026 and are in that policy, so what you read here and what you read there are the same thing said twice rather than two schedules that could drift apart. They are repeated here because a customer reading their own notice should not have to click through to find out how long we keep their invoices.
- Your account and billing records — life of the account plus 6 years, because tax and contract records have to survive the relationship.
- Letter send records — 6 years.
- Export audit log — 6 years.
- Send audit and spend-alert records — 6 years, matching the letters they account for.
- Staff impersonation records — 6 years, matching the other audit records. An audit trail deleted before the thing it audits is not an audit trail.
- Email consent and its history — for as long as the account exists, plus 6 years, because the evidence of a consent has to outlive the send it authorised.
- Funnel milestones and acquisition source — deleted with the account. They carry no personal identifier in themselves.
- Waiting-list entries — until we open and have written to you, or until you ask us to delete them, whichever is sooner.
- Server logs containing IP addresses — 90 days.
- Preview rate-limit hashes — 2 days, and they are not reversible into an address in any case.
- Postcode coordinates in our lookup table — indefinitely. A postcode, its two coordinates and the date we looked them up, with nothing recording who asked: a table of places, not of people. Deleting a row would achieve nothing except asking a free public service the same unchanging question again.
One honest caveat. Enforcement of the timetable is currently manual — no scheduled job prunes customer data on these dates yet, and the retention policy says the same about applicant data. When we delete, deletion is destruction rather than archival.
Your rights
You can:
- ask for a copy of the personal data we hold about you;
- ask us to correct anything wrong — most of it you can edit yourself in the service;
- ask us to delete your data. There is no self-service "delete my account" button yet: ask us and we do it by hand. We keep what the law requires us to keep — invoices, and the records of letters actually posted — and delete the rest;
- ask us to restrict processing while a dispute is sorted out;
- object to anything we do on the basis of legitimate interests. Tell us and we will stop unless we can show compelling grounds that override your rights;
- ask for your data in a portable form, for what we hold on the basis of contract or consent;
- withdraw consent to optional email at any time, without affecting anything done before you withdrew it.
Requests to hello@justgranted.co.uk. We respond within one month. There is no charge, and we do not ask for a reason.
You can also complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113). We would rather you told us first, but the route is yours and you do not have to come to us first.
Keeping it safe
The service is served only over HTTPS. Passwords are stored as salted one-way hashes. Session and CSRF cookies are marked HttpOnly and SameSite and are restricted to HTTPS in production. Access to customer data by our staff is limited to the people who need it, and acting as a customer's account is audited every time. Payment card data never reaches us at all.
Backups. The database and the files you upload are backed up every night, kept for a rolling fortnight, and copied to the two storage providers named above so that no single failure loses your record. The copies travel over HTTPS and are held in private buckets that only our server's keys can read. They are also encrypted by us, with our own keys, before they leave our server, so a copy taken out of either provider's storage is unreadable without a key neither provider holds. Backups are restored into a scratch copy and checked, so that "we have a backup" is something we have tested rather than something we assume.
No system is perfectly secure. If a breach ever puts your rights at risk, we will tell the ICO within 72 hours and tell you without undue delay.
Changes to this notice
We will change this notice when what we do changes — a new processor, a new category of data, a new purpose. Material changes are notified by email to account admins at least 14 days before they take effect. The date at the top of this document is the version you are reading.