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Privacy Policy

This Privacy Policy outlines how Sodium Software Ltd (“we”, “us”, or “our”) processes personal data on behalf of our users in connection with our SaaS platform, which facilitates the verification of subcontractors with HMRC and the exchange of invoices between contractors and subcontractors.

1. Who We Are

Sodium Software Ltd is a UK-based company acting as a data processor on behalf of our users, who are the data controllers.

Company Name: Sodium Software Ltd
Registered Address: Amelia House, Crescent Road, Worthing, West Sussex, United Kingdom, BN11 1RL
Email: chaitanya@bwproducts.co.uk

2. Role in Data Processing

As a data processor, we do not determine the purpose or means of processing personal data. Our users control the data and its use, and we act solely on their instructions.

3. Data We Process

We may process the following types of personal data on behalf of our users:

  • Names
  • Email addresses
  • Phone numbers
  • IP addresses
  • Billing details
  • Login credentials
  • Device and browser information

Data is collected through:

  • Account registration
  • User-submitted entries
  • Cookies and analytics tools

4. Legal Basis and Purpose for Processing

We process personal data strictly in accordance with the UK GDPR and only where there is a valid legal basis for doing so. The purposes for which we process data, and the corresponding legal bases, include:

a) Contractual Necessity

We process personal data to perform our contractual obligations and to provide the core functionality of the CIS Manager platform. This includes:

  • Creating and managing user accounts
  • Allowing users to verify subcontractors with HMRC
  • Facilitating invoicing between contractors and subcontractors

b) Legal Obligation

We may process certain personal data to comply with legal and regulatory requirements. This includes:

  • Retaining records for tax, accounting, and audit purposes
  • Supporting our users in fulfilling obligations under HMRC’s Construction Industry Scheme (CIS)

c) Consent

Where required, we will process personal data based on user consent. This applies to:

  • Sending marketing or promotional communications
  • Using non-essential cookies or similar tracking technologies

Users can withdraw their consent at any time via the settings or opt-out mechanisms provided.

d) Legitimate Interests

We may also process personal data when it is necessary for our legitimate interests, provided these are not overridden by the rights and freedoms of the data subject. Our legitimate interests include:

Understanding how the service is used to guide product development and support

Monitoring and improving the performance, security, and usability of the platform

Preventing misuse or fraudulent activity

5. Data Sharing

We may share data with third parties only as instructed by our users. Currently, data is shared with HMRC for the purpose of subcontractor verification.

We do not make any international data transfers.

6. Data Retention

We retain personal data for 7 years to comply with legal and contractual obligations. After this period, data is securely deleted or anonymised unless otherwise instructed by the data controller.

7. Data Subject Rights

Although we act as a data processor, we support our users in fulfilling data subject rights under GDPR, including:

  • Access to personal data
  • Correction of inaccurate data
  • Deletion requests
  • Objection to processing
  • Data portability
  • Restriction of processing

Users may opt out of marketing communications at any time.

8. Cookies and Tracking

We use cookies for session management and analytics. A cookie consent banner is shown to all users to obtain informed consent.

9. Security Measures

We implement robust security measures to protect personal data, including:

  • SSL encryption
  • Data encryption at rest and in transit
  • Access controls
  • Regular data backups

10. Children’s Data

Our platform is not intended for or directed at children under the age of 13 or 16. We do not knowingly process children’s data.

11. Contact

If you have any questions about this Privacy Policy or how we process data on behalf of our users, please contact us at:

Email: chaitanya@bwproducts.co.uk
Address: Amelia House, Crescent Road, Worthing, West Sussex, United Kingdom, BN11 1RL