Privacy Notice
- Version
- v1.1
- Effective
- 20 Jul 2026
- Controller
- Copper Ocean Ltd
Beta text. This version has been reviewed for accuracy by the operator but has not yet had formal legal review. The final text will be published before full launch.
1. Who we are
Gift Recorder is provided by Copper Ocean Ltd, a company registered in England & Wales (company number 07468518), registered office 7 Granard Business Centre, Bunns Lane, Mill Hill, London NW7 2DQ. Copper Ocean Ltd is the data controller for the personal data described in this notice. Contact us about your data at support@giftrecorder.com.
2. The beta test environment
Gift Recorder is currently in an invited beta on a test environment. Data you enter during the beta is treated as test data: it will be deleted when the beta phase ends and is not carried over to the live service, so please avoid entering information you need us to keep.
The beta database and file storage are hosted on European Union (Ireland) infrastructure; the live service at launch will be hosted in the United Kingdom.
3. Data we hold
Account data: your name, email address, sign-in and security details (including multi-factor authentication where enabled). The records you choose to enter: gifts with their values and dates, the people and organisations connected to them, income and expenditure schedules, and notes. Evidence files you upload. Access grants: who you have invited and what they can see. Operational records: audit logs of significant actions, security logs, and support correspondence you send us.
4. How we use it
We use your data solely to provide the service: maintaining your records, deriving the indicative classifications and reports you ask for, operating the access you grant, keeping the service secure, and responding to your support requests. The lawful bases are performance of a contract (providing the service you signed up for) and our legitimate interests in security, auditability and improving the service during the beta.
We do not sell your data and we do not use it for advertising. Transactional emails are kept to a minimum and never contain gift values or details.
5. Who can see it
Only you, and the people and firms you actively grant read-only access to, can see your records. Operational access by us is restricted and audited, and used only where needed to run the service. We do not use third-party analytics or advertising cookies; the service sets only the essential cookies needed to keep you signed in.
6. Our service providers
We use a small number of specialist providers to run the service, each under data-processing terms: a cloud database, authentication and file-storage platform (hosting the beta environment in the EU (Ireland) region; the live service will use its UK (London) region), an application-hosting platform whose server functions run in the London region, an EU-hosted transactional email service, a malware-scanning service that checks uploaded evidence files, and a business email provider for our support mailbox.
7. Retention
Beta data is retained only for the beta: when the beta phase ends, or if your account is deleted earlier, your records and files are deleted. A minimal audit trail of system actions may be retained after deletion — it records that actions happened, kept for security and integrity purposes. If you want anything you entered during the beta, note it before the window closes.
8. Your rights
Under UK data-protection law you have rights over your personal data, including access, rectification, erasure, restriction, portability and objection. To exercise any of them, email support@giftrecorder.com. You also have the right to complain to the Information Commissioner's Office (ico.org.uk).
9. Security
Data is encrypted in transit and at rest. Access is controlled row-by-row in the database, so each signed-in person can only ever reach the records they own or have been granted. Multi-factor authentication is available on all accounts and required for professional advisers. Uploaded files are scanned for malware before they become accessible. No system is perfectly secure — if we become aware of an incident affecting your data, we will tell you without undue delay.
10. Changes and contact
This notice is versioned; each published version shows its version and effective date, and prior versions remain available in the update history. Questions about this notice or your data: support@giftrecorder.com.
Update history
- v1.1 · 20 Jul 2026 — Current (holding text)
- v1.0 · 12 Jun 2026 — Superseded (holding text)