GDPR Policy

Effective Date: 09/09/2026

Company Name: GH Newco 1 Limited (trading as Ommatia)

Registered Office Address: 4 Greengate, Cardale Park, Harrogate, England, HG3 1GY

1. Introduction

At GH Newco 1 Limited (trading as Ommatia) (“we”, “us”, “our”), we are committed to protecting and respecting your privacy and ensuring transparency in how personal data is handled. This Policy outlines how we collect, use, process, and protect personal data through the Ommatia software platform—including our web browser platform and mobile application (collectively, the “App”)—in full compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Our software provides an end-to-end Quality Assurance (QA), property maintenance, and statutory compliance management platform designed for Public Housing Associations, Council Housing Associations, local authorities, contractors, site inspectors, and housing residents.

Depending on how you interact with the App:

Where Ommatia acts as a Data Processor: When housing association staff, contractors, site inspectors, or tenants submit data into the App under an enterprise contract, your Housing Association or Local Council acts as the primary Data Controller, and Ommatia processes your personal data strictly on their instructions.

Where Ommatia acts as a Data Controller: We control personal data collected directly through account management, system setup, administrative logins, client portal interactions, and customer support communications.

By using our App or interacting with our services, you acknowledge the data practices described in this policy.

2. What Personal Data We Collect

To deliver digital audit trails, real-time quality scoring, SLA tracking, and portfolio intelligence, we collect and process the following categories of personal and technical data:

Account & User Credentials: Name, work or residential email address, phone number, job title, trade specialisation, system user role, login passwords, and housing association or contractor organisation affiliation.

Property, Compliance & Inspection Media: Timestamped site photos, videos, audio notes, written descriptions, maintenance hazard reports, and digital sign-off records linked to specific property address logs.

Geospatial & Location Data: GPS location coordinates attached to uploaded photo evidence and contractor check-ins to verify on-site activity and map portfolio data.

AI Evaluation & Quality Metrics: Automated visual AI scores (e.g., quality ratings out of 100), defect classifications, and AI-driven statutory reasoning generated during site inspections.

Technical & System Telemetry: IP address, device model, operating system version, mobile browser type, unique device identifiers, login timestamps, session duration, app crash logs, and platform usage analytics.

Administrative & Transactional Data: Billing details, contract contact information, and account administration logs for enterprise accounts.

3. How We Use Your Personal Data

We process personal and technical data strictly for operational, statutory, and system performance purposes:

Digital Audit Trails & Compliance: Creating immutable, timestamped property history records including repair sign-offs, statutory reasoning logs, and audit histories for address records.

Automated Quality Assurance: Processing site photos using visual AI models to rank repair quality, identify defects, and enable real-time contractor corrections while on-site.

Workflow & SLA Management: Automatically routing logged maintenance hazards or tenant submissions directly to helpdesk workflows and tracking response times against statutory SLA deadlines.

Portfolio Intelligence: Aggregating defect history, trade performance, and historical quality scores across multi-year housing programmes displayed on interactive maps.

System Security & Monitoring: Authenticating users, maintaining platform stability, troubleshooting bugs, preventing unauthorised logins, and protecting against cyber threats.

4. Legal Basis for Processing Your Personal Data

Under the UK GDPR, we rely on the following legal bases for processing personal data:

Contractual Necessity: For fulfilling software enterprise agreements with Housing Associations, local councils, or contractors, or delivering App access to authorised users.

Legitimate Interests: To pursue our legitimate operational interests in maintaining software security, optimising platform performance, running visual AI model analysis, and compiling property audit trails.

Legal Obligation: To comply with statutory housing compliance standards, building safety regulations, or tax and accounting laws in the UK.

Consent: Where you explicitly authorise specific optional app permissions (e.g., camera access or location services) or opt-in communication channels.

5. Sharing Your Personal Data

We will never sell, rent, or trade personal data to third parties for commercial or marketing purposes. We share data only in the following controlled circumstances:

Your Housing Association or Local Council: All inspection media, audit trails, and quality scores linked to a property portfolio are accessible to the contracting Housing Association acting as the Data Controller.

Assigned Contractors & Helpdesk Teams: Maintenance requests, site photos, and quality scores are shared with authorised maintenance partners to facilitate repairs and SLA compliance.

Technical Infrastructure Partners (Sub-Processors): Trusted third-party vendors who assist us in operating our software infrastructure (e.g., secure cloud hosting, database management, AI image processing APIs, and system monitoring), governed by strict Data Processing Agreements (DPAs).

Legal & Regulatory Requirements: If required by law, regulation, or court order to disclose data to regulatory authorities or law enforcement.

6. Data Retention

We retain personal data stored within the App only for as long as necessary to fulfil the operational, statutory, and contractual requirements of the contracting Housing Association or local authority. Property audit trails and compliance records are retained according to the specific retention schedules specified by the contracting Housing Association or applicable building safety regulations.

7. Your Data Protection Rights

Under the UK GDPR, users have the following statutory rights regarding their personal data:

Right to Access: Request access to and a copy of the personal data we hold about you.

Right to Rectification: Request correction of any inaccurate or incomplete personal data.

Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data, subject to housing record retention laws and statutory audit requirements.

Right to Restrict Processing: Request that we limit how we process your personal data under specific conditions.

Right to Data Portability: Request a copy of your personal data in a structured, commonly used, and machine-readable format.

Right to Object: Object to the processing of your personal data based on legitimate interests.

Right to Withdraw Consent: Withdraw explicit consent at any time where processing was based on consent.

To exercise any of these rights, please contact us at Info@ommatia.co.uk. You also have the explicit right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk.

8. Security of Your Personal Data

We enforce robust technical and organisational security measures to protect personal data from unauthorised access, loss, alteration, or disclosure, including TLS/SSL transport encryption, AES-256 database encryption, and role-based access controls.

9. App Tracking and Session Cookies

The Ommatia App utilises essential security storage tokens and functional session cookies necessary to verify user identity, maintain active sessions, and secure platform access. We do not use third-party advertising tracking cookies or cross-app analytics for commercial advertising.

10. International Transfers of Personal Data

Personal data processed through the Ommatia App is stored and hosted on secure servers located within the United Kingdom or the European Economic Area (EEA). If personal data is transferred outside these regions, we ensure that appropriate UK GDPR safeguards are established.

11. Changes to This Privacy Policy

We may update this GDPR Policy periodically to reflect software enhancements, new feature releases, or changes in UK data protection legislation.

12. Contact Us

If you have any questions or concerns regarding this GDPR Policy, please contact us at:

GH Newco 1 Limited (trading as Ommatia)

4 Greengate, Cardale Park, Harrogate, England, HG3 1GY

Email: Info@ommatia.co.uk