Legal
Privacy Policy
Effective date: 22 February 2026
1. Introduction
SubShare ("we", "us", "our") operates the SubShare platform — a service that enables General Contractors to share job-site documents with subcontractors via time-limited access links. We are committed to protecting your personal data and respecting your privacy.
This policy explains what data we collect, why we collect it, how we use it, and your rights under the General Data Protection Regulation (GDPR) and applicable European data protection law. It applies to all users of the SubShare web application.
By using SubShare you acknowledge that you have read and understood this policy.
2. Data We Collect
Account data (General Contractors)
- Email address — used for authentication and account communications
- Company name — displayed within the platform
- Encrypted password — managed by Supabase Auth; we never see your plaintext password
Project data
- Project name, description, and site access information (e.g. lockbox codes)
- Site address — entered manually or via Google Maps autocomplete
- GPS coordinates (latitude/longitude) — derived from the selected address for map display
Subcontractor data
- Name — entered by the General Contractor at invite creation
- Phone number — used solely to deliver the magic link SMS; stored in our database until the link is deleted
- First-visit timestamp — recorded the first time a subcontractor opens their magic link
Documents
- File name, type, and size
- File content — stored securely in Supabase Storage
- Converted PDF version (where applicable) — generated by CloudConvert and stored alongside the original
Payment data
- Billing is processed entirely by Stripe. We do not store or handle card numbers or banking details.
- We store only: your Stripe customer ID, subscription plan, subscription status, and billing period dates.
Usage and notification data
- In-app notifications (e.g. "link visited", "link expiring") including related metadata
- Read and dismissed timestamps for notifications
Browser-side cache (subcontractor devices)
- Project metadata is cached in IndexedDB on the subcontractor's device for offline access
- Document files are cached in the browser's Origin Private File System (OPFS)
- This data stays on the subcontractor's device and is managed by the browser; we have no access to it
3. Legal Basis for Processing
Under GDPR Article 6, we rely on the following legal bases:
- Performance of a contract (Art. 6(1)(b)) — processing necessary to provide the SubShare service, including storing projects, documents, and magic links
- Legitimate interests (Art. 6(1)(f)) — security monitoring, fraud prevention, expiry notifications, and improving the service
- Consent (Art. 6(1)(a)) — sending SMS messages to subcontractors; General Contractors confirm they have obtained the subcontractor's consent before creating an invite
- Legal obligation (Art. 6(1)(c)) — retaining payment records as required by financial regulations
4. Third-Party Processors
We share your data with the following processors solely to provide the SubShare service. Each processor is bound by a Data Processing Agreement.
| Processor | Purpose | Location |
|---|---|---|
| Supabase (supabase.com) | Database, authentication, file storage | EU (AWS EU-West) |
| Stripe (stripe.com) | Payment processing, billing management | US — SCCs apply |
| Twilio (twilio.com) | SMS delivery of magic links | US — SCCs apply |
| CloudConvert (cloudconvert.com) | Document-to-PDF conversion | Germany / EU |
| Google Maps Platform | Address autocomplete, geocoding | US — SCCs apply |
5. International Data Transfers
Some of our processors are based in the United States (Stripe, Twilio, Google Maps Platform). Transfers to these processors are safeguarded by Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring an equivalent level of data protection.
Supabase and CloudConvert operate EU-based infrastructure, so transfers to these processors do not leave the European Economic Area.
6. Data Retention
- Account data: retained for the lifetime of your account, plus 30 days following a deletion request to allow for recovery and finalise billing
- Projects and documents: retained until you delete them
- Magic links and subcontractor phone numbers: retained until the link is deleted by the General Contractor
- Payment records: retained for 7 years to comply with financial and tax legislation
- Browser cache (IndexedDB / OPFS): controlled entirely by the subcontractor's browser; we cannot access or delete it remotely
7. Your Rights Under GDPR
If you are located in the European Economic Area or United Kingdom, you have the following rights:
- Right of access — request a copy of the personal data we hold about you
- Right to rectification — request correction of inaccurate or incomplete data
- Right to erasure — request deletion of your personal data
- Right to data portability — receive your data in a structured, machine-readable format
- Right to restriction — request that we restrict processing of your data in certain circumstances
- Right to object — object to processing based on legitimate interests
- Right to withdraw consent — where processing is based on consent (e.g. SMS), you may withdraw at any time without affecting prior processing
- Right to lodge a complaint — with your national supervisory authority (e.g. the ICO in the UK, or your national DPA in the EU)
10. Changes to This Policy
We may update this policy from time to time. Material changes will be notified via email or an in-app notice at least 14 days before taking effect. Continued use of SubShare after the effective date constitutes acceptance of the updated policy. The current version is always available at this URL.