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Draft for review. This document is an initial draft prepared for Headroom Technology Ltd and should be reviewed by a qualified solicitor before publication. Items in [square brackets] need to be confirmed.
Legal

Privacy Policy

Last updated: 23 July 2026

1. Who we are

This policy explains how Headroom Technology Ltd ("Headroom", "we", "us") collects and uses personal data when you use the Headroom platform, website and services. Headroom is the data controller. We are a company registered in England & Wales (company number [to be confirmed]), registered office [registered office address].

ICO registration. Headroom Technology Ltd is registered with the UK Information Commissioner's Office under registration number [ICO registration number to be confirmed]. Headroom is a separate legal entity and maintains its own registration.

2. Scope

Headroom is a business-to-business service for renewable-energy installers and developers. This policy covers personal data of our account holders, their staff, and individuals whose details are provided to us in connection with a grid connection application (for example a site owner or occupier).

3. The personal data we collect

CategoryExamples
Account & contactname, work email, company, login credentials, plan and billing status
Site & application datasite address and postcode, MPAN, asset type and system size, DNO, connection references
Site owner / occupierfull legal name, role, organisation, registered address and company number, and Letter of Authority details
Uploaded documentselectricity bills, designs or other files you upload, which we process (including by automated text extraction) to pre-fill applications
Usage & technicalIP address, device/browser information, and interactions with the Service (via essential cookies/logs)
Paymentbilling details processed by our payment provider (we do not store full card numbers)

4. How and why we use it

PurposeLawful basis (UK GDPR)
Provide the Service — screening, verdicts, document generationPerformance of a contract
Submit applications to DNOs on your instructionPerformance of a contract; the Letter of Authority evidences the site owner's authorisation
Account administration, billing and supportContract; legitimate interests
Securing, maintaining and improving the ServiceLegitimate interests
Service and, where relevant, marketing communicationsLegitimate interests, or consent where required
Meeting legal and accounting obligationsLegal obligation

Where we rely on legitimate interests, we balance those interests against your rights. You can object to processing based on legitimate interests (see section 8).

5. Who we share it with

  • Distribution Network Operators (DNOs) — where you instruct us to submit an application, we share the relevant application and site/owner details with the applicable DNO.
  • Service providers (processors) acting on our instructions, including cloud hosting, a payment processor, and an automated document/text-extraction provider used to read uploaded bills and designs. [Confirm named sub-processors and maintain a current list.]
  • Professional advisers and authorities where required by law or to protect our rights.

Published network datasets (such as UKPN capacity data, the ENA Embedded Capacity Register and PVGIS / EU JRC) are sources we read from; we do not send your personal data to them as part of screening.

6. International transfers

Our infrastructure is hosted within the European Economic Area. Where any provider processes personal data outside the UK or EEA, we put appropriate safeguards in place (such as UK approved transfer mechanisms). [Confirm once sub-processors are finalised.]

7. How long we keep it

We keep personal data for as long as needed to provide the Service and to meet legal, accounting and regulatory requirements. Application records are retained while your account is active and for a reasonable period afterwards; billing records are kept for the period required by law. [Confirm specific retention periods.]

8. Your rights

Under UK data protection law you have the right to access, correct, erase, restrict or object to the processing of your personal data, to data portability, and to withdraw consent where we rely on it. To exercise any of these, contact hello@headroom.technology. We will respond within the time limits set by law.

You also have the right to complain to the Information Commissioner's Office (ico.org.uk) — though we would welcome the chance to resolve any concern first.

9. Cookies

We use essential cookies and similar technologies needed to run the Service and keep it secure. If we introduce analytics or non-essential cookies, we will update this policy and seek consent where required.

10. Security

We use appropriate technical and organisational measures to protect personal data, including access controls and encryption in transit. No system is completely secure, and you are responsible for keeping your account credentials confidential.

11. Changes

We may update this policy from time to time. The current version is always posted here with its "last updated" date; material changes will be highlighted where appropriate.

12. Contact

Questions or requests about your personal data: hello@headroom.technology. [Consider a dedicated privacy@headroom.technology inbox.]

Headroom

The operating platform for UK renewable energy installers.

Headroom Technology Ltd · Company No. XXXXXXXX
Registered in England & Wales

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