This policy explains how Charged Services Ltd (“Charged”, “we”, “us”) collects, uses, shares and protects personal data through this website and through our Meta app ChargedGrokBot, which connects to WhatsApp, Facebook and Instagram. It is written to meet the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who we are
Charged Services Ltd is a UK company that installs electric gates and barriers, access control, CCTV, intercoms and balustrades across South Essex and East London. Our website is charged.services.
Charged Services Ltd
13 Fleming Road, Chafford Hundred, Grays RM16 6YA
Email: [email protected]
Phone: 01375 886299
We are registered with the Information Commissioner’s Office (ICO) and pay the data protection fee. ICO registration reference: ZC278103.
ChargedGrokBot is our app on the Meta platform. It uses the WhatsApp Business Cloud API, the Facebook Pages API and the Instagram API to:
- send and receive messages with customers and enquirers on WhatsApp, Facebook Messenger and Instagram;
- publish and manage posts, and read and reply to comments, on our Facebook Page and Instagram account;
- read Page and account insights (performance statistics);
- as a Meta Tech Provider, onboard other businesses’ WhatsApp numbers through Meta’s Embedded Signup so that we can send and receive WhatsApp messages on their behalf.
2. Controller and processor roles
When we are the controller
For our own customers, enquirers and followers (for example, when you fill in a form on this website, message Charged on WhatsApp, comment on our Facebook or Instagram posts, or ask us for a quote), Charged is the data controller. We decide why and how your data is used, and this policy applies in full.
When we are a processor
When a business connects its WhatsApp number to our app through Embedded Signup, that business is the data controller for the messages exchanged with its own customers, and Charged acts as its data processor. We process that data only on the business’s documented instructions, to provide the messaging service, and not for our own purposes. We keep it confidential and secure, and we help the business respond to requests from its customers.
If you are a customer of a business that uses our service, please contact that business first about your data; its own privacy policy applies. If you contact us instead, we will pass your request to the business and support it in responding.
For the business itself (for example, the contact details of the person who sets up the connection, and account and billing information), Charged is the controller.
3. Data we collect
We collect only what we need. Depending on how you interact with us, this may include:
| Source | Personal data |
|---|---|
| Website forms (contact and Remootio warranty registration) | Your name, email address, phone number, the service you are interested in and your message; for warranty registrations, the product, purchase date, where you bought it, order reference and any notes. |
| WhatsApp (WhatsApp Business Cloud API) | Your phone number; your WhatsApp profile name; the content of messages you send and that we send to you; photos, videos, voice notes, documents and other media you share; message timestamps and delivery/read status. |
| Facebook (Pages API, Messenger) | Your name and profile name; your page-scoped user ID; messages sent to our Page and any media in them; comments and reactions on our posts; Page IDs; Page insights. |
| Instagram (Instagram API) | Your Instagram username and profile name; your Instagram-scoped user ID; direct messages and media sent to our account; comments and mentions on our posts; account IDs; account and post insights. |
| Post, comment and insights data | Content of posts we publish, comments and replies, and insights such as reach, impressions and engagement. Insights are mostly aggregated and do not usually identify individuals. |
| Businesses onboarded via Embedded Signup | Business name, WhatsApp Business Account ID, phone number ID and display phone number, the name and contact details of the person who connects the account, and the access tokens Meta issues to let our app act for the business. We also process the business’s customer messages (as described under WhatsApp above) as its processor. |
| Information you give us directly | Anything you choose to share during a conversation, such as your address, site details, photos of your gate or property, and preferred appointment times, so we can quote for and carry out work. |
We do not ask for special category data (such as health information). Please do not send it to us through our forms or messaging channels.
4. How we use data and our lawful bases
| Purpose | Lawful basis (UK GDPR Article 6) |
|---|---|
| Replying to enquiries, giving quotes, booking surveys and installations, registering warranties, and providing service and support | Steps taken at your request before a contract, and performance of a contract (Art. 6(1)(b)) |
| Keeping records of jobs, quotes, invoices and customer communications | Contract (Art. 6(1)(b)); legal obligation for accounting and tax records (Art. 6(1)(c)); legitimate interests in keeping accurate records (Art. 6(1)(f)) |
| Publishing and managing our Facebook and Instagram posts, and replying to comments | Legitimate interests in promoting our business and responding to the public (Art. 6(1)(f)) |
| Reading insights to understand how our content performs | Legitimate interests in improving our marketing (Art. 6(1)(f)) |
| Using automation and AI tools to help triage, draft and route messages (always overseen by Charged) | Legitimate interests in responding quickly and efficiently (Art. 6(1)(f)); contract where it relates to your job (Art. 6(1)(b)) |
| Sending marketing or promotional messages on WhatsApp | Your consent (Art. 6(1)(a)), which you can withdraw at any time |
| Providing WhatsApp messaging to businesses we onboard as a Tech Provider | We act as processor on the business’s instructions; the business is responsible for its own lawful basis. For the business’s own account details: contract (Art. 6(1)(b)) |
| Keeping our website and systems secure, preventing spam and misuse, and complying with Meta’s platform terms | Legitimate interests (Art. 6(1)(f)); legal obligation where applicable (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have balanced our interests against your rights, and you can object at any time (see Your rights). We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
5. Who we share data with
We do not sell your personal data, and we do not share it with third parties for their own marketing. We share it only with:
- Meta Platforms (including WhatsApp, Facebook and Instagram), which provides the messaging and social media services our app uses. Messages and content pass through Meta’s systems. Meta’s own processing is covered by its policies: Meta Privacy Policy and WhatsApp legal information.
- Anysphere, Inc. (United States), which provides the cloud computer and AI assistant platform we use to run our business automations, including our WhatsApp and social media tools. It stores and processes messages and account details from WhatsApp, Facebook and Instagram so that we can receive, sort and draft replies to them, acting as our processor. It may use the data only to provide its service to us.
- Cloudflare, Inc., which hosts this website, keeps it secure (including spam protection on our forms with Cloudflare Turnstile) and runs the web endpoint that receives notifications from WhatsApp and Meta, such as new messages, acting as our processor.
- Brevo, which delivers website form submissions to us by email, acting as our processor. Brevo does not receive any data from WhatsApp, Facebook or Instagram.
- Professional advisers (such as accountants and insurers) where needed, under duties of confidentiality.
- Authorities such as law enforcement or regulators, where the law requires it.
- The business concerned, where we act as a processor for a business onboarded through Embedded Signup.
Anysphere and Cloudflare are the only service providers with access to the data we receive from Meta (WhatsApp, Facebook and Instagram). All our processors are bound by written contracts that require them to keep data secure and use it only on our instructions.
6. International transfers
Meta and some of our service providers may process data outside the UK, including in the European Economic Area and the United States. Where data is transferred outside the UK, we make sure appropriate safeguards are in place, such as UK adequacy regulations (including the UK–US Data Bridge for certified organisations), the ICO’s International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses. Contact us if you would like more information about these safeguards.
7. How long we keep data
We keep personal data only for as long as we need it for the purposes above:
- Messages and media (WhatsApp, Messenger, Instagram, and website enquiries): up to 24 months from the last message, unless they form part of a job record.
- Job records (quotes, invoices, job notes and the related messages): 6 years after the end of the financial year in which the job was completed, to meet accounting, tax and warranty needs.
- Comments and post data: for as long as the post is live on our Page or account. Copies we hold are deleted within 24 months.
- Insights: up to 24 months. We may keep aggregated statistics that do not identify anyone for longer.
- Data for businesses onboarded via Embedded Signup: for as long as the business uses our service. We delete it within 30 days after the business disconnects or ends the service, unless the business instructs otherwise. Access tokens are revoked and deleted when the connection ends.
- Marketing consent records and opt-outs: kept while we hold your number, so that we keep respecting your choice.
When data is no longer needed, we delete it securely or anonymise it.
8. Security
We use appropriate technical and organisational measures to protect personal data. These include encrypted connections (HTTPS/TLS), access limited to authorised people who need it, strong authentication on our accounts, secure storage of access tokens, and regular review of the services we use. WhatsApp messages are encrypted in transit. No system is completely secure, but if we become aware of a personal data breach we will act promptly and notify the ICO and affected people where the law requires.
9. Your rights
Under UK data protection law you have the right to:
- Access: get a copy of the personal data we hold about you;
- Rectification: have inaccurate or incomplete data corrected;
- Erasure: have your data deleted in certain circumstances;
- Restriction: ask us to limit how we use your data;
- Objection: object to processing based on legitimate interests, and to direct marketing at any time;
- Data portability: receive data you gave us in a commonly used, machine-readable format, or have it sent to another organisation;
- Withdraw consent at any time, where we rely on consent. This does not affect processing already carried out.
How to exercise your rights: email [email protected], call 01375 886299, or write to us at the address above. We may need to confirm your identity (for example, by asking you to message us from the same WhatsApp number). We will respond within one month, and there is normally no charge.
10. User data deletion
How to ask us to delete your data
- Email [email protected] with the subject line Data deletion request.
- Tell us how you contacted us (website, WhatsApp, Facebook or Instagram) and include the email address, phone number, profile name or username you used, so we can find your data.
- We will delete your personal data from our app and systems within 30 days and email you to confirm when it is done.
If we must keep some data for legal reasons (for example, invoices we are required to keep for tax purposes), we will tell you what we are keeping and why, and delete it once that period ends.
Removing the app from Facebook: if you have connected ChargedGrokBot to your Facebook account, you can also remove it at any time. Go to Facebook Settings & privacy → Settings → Apps and websites, select ChargedGrokBot and choose Remove. Then email us as above to have the data we already hold deleted.
Businesses onboarded via Embedded Signup: to disconnect your WhatsApp number and have your data deleted, email us with the subject Data deletion request. You can also remove our app’s access in Meta Business Settings. We will delete your data, including your customers’ messages, within 30 days and confirm in writing.
Deleting data from our systems does not delete messages from your own WhatsApp, Messenger or Instagram app, or data that Meta holds under its own policies.
11. Opting out of WhatsApp messages
You can stop receiving WhatsApp messages from us at any time by replying STOP to any of our messages. We will confirm and stop sending you marketing or non-essential messages. You can also block our number in WhatsApp, or contact us using the details above. If you have an active job with us, we may still need to contact you about it by another method, such as phone or email.
If you receive messages from another business that uses our service, replying STOP will opt you out of that business’s messages, and we will pass your choice on to that business.
12. Cookies
This website does not use advertising or analytics cookies or tracking scripts. Our forms are protected by Cloudflare Turnstile, which may use strictly necessary technologies to tell people from bots. Some pages include embedded YouTube videos; YouTube may set its own cookies when you play them, under Google’s privacy policy.
13. Complaints
If you are unhappy with how we have handled your data, please contact us first and we will try to resolve it. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator:
- Website: ico.org.uk (complaints: ico.org.uk/make-a-complaint)
- Helpline: 0303 123 1113
14. Changes to this policy
We may update this policy from time to time, for example when our services or the law change. We will post the updated version on this page with a new “last updated” date. If we make significant changes, we will take reasonable steps to let you know.
15. Contact us
Charged Services Ltd
13 Fleming Road, Chafford Hundred, Grays RM16 6YA
Email: [email protected] · Phone: 01375 886299
ICO registration reference: ZC278103