Who we are
HoverFrame is a sole trader business run by Thomas Rupp. We provide an automated missed-call text-back service to local businesses, our clients. When someone rings your business and you don't answer, we text them a link to a short form, then send you their details.
This notice is for our clients. It explains what we hold about you and your business, and what we do with your callers' details on your behalf. For questions, contact us at HelloHoverFrame@gmail.com. Our ICO registration number is ZC281128.
What we collect
To set up and run the service for your business, we collect:
- Your business details: your business name, your name, and the email address and mobile number we send enquiries to.
- Your service set-up: the Twilio number we assign you, the number your calls are forwarded from, and the wording and settings for your account.
- Billing details: what you've signed up for and your payment records. Card payments are handled by Stripe; we don't see or store your full card number.
- Your messages to us when you contact us for support.
- Usage records: counts of missed calls and of texts sent and delivered, so we can run the service, fix problems and apply the fair-use limit.
Your callers' details. When a call to you goes unanswered and is forwarded to us, we also handle the caller's phone number, the time of the call, and the name, request and preferred time they type into the form. We handle these on your behalf (see below).
We don't record or listen to your calls, and we only see calls that go unanswered.
Why we use it, and our legal basis
We use your details only for these purposes:
- To provide the service: set up your number, text your callers, and send you their enquiries.
- To run our business: billing, support, keeping records, and telling you about changes to the service or this notice.
- To keep the service working and secure: fixing messages that don't arrive and spotting misuse.
Our legal basis for your details is contract (we need them to provide the service you signed up for) and legal obligation (keeping accounting records), and legitimate interests (keeping the service working and secure, and spotting misuse). We don't sell them, use them for marketing to others, or profile you.
Your callers' details are different. As the business they rang, you decide why those details are collected and what happens to them, so you are the controller and we act as your processor: we handle them only on your instructions. Your own privacy notice should therefore mention that people who ring and miss you get a text asking for their details. Our client agreement covers this in more detail.
Who sees your details
- Our service providers, who handle data for us under their own terms:
- Twilio carries the calls and sends the texts, so it handles your Twilio number and your callers' numbers.
- Render hosts our website and stores the records, including your account and your callers' enquiries.
- Google (Gmail) delivers the enquiry emails to you.
- Stripe takes your card payments.
- No one else, unless the law requires us to share it. We never share your details or your callers' details with other businesses.
Some of these providers are based in the United States or store data there. Where your details leave the UK, we rely on the safeguards those providers publish, such as the UK data transfer arrangements in their terms. Contact us if you'd like more detail.
How long we keep it
We keep your account and billing records while you're a client, and afterwards for as long as the law requires us to keep accounting records (usually around six years).
The form link we text your callers stops working after 7 days. We keep each caller's enquiry for up to 12 months, then delete it, or sooner if you ask. If you stop being a client, we delete your callers' enquiries and release your number within 30 days, unless the law requires us to keep something.
Your rights and how to complain
You can ask us to:
- tell you what details we hold about you and give you a copy, in a form you can move to another provider
- correct anything that's wrong
- delete your details
- stop using your details in a particular way, or object to how we use them
To do any of these, contact us at HelloHoverFrame@gmail.com. We'll reply within one month. If one of your callers asks us about their details, we'll pass the request to you, as you decide what happens to their enquiry.
If you're unhappy with how we've handled your details, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113. We'd welcome the chance to put things right first.