At Graylark, we are committed to protecting the privacy and security of your personal data. This Privacy Policy outlines how we collect, use, and protect your information in accordance with the General Data Protection Regulation (GDPR) and other applicable laws.
Policy version: 24/03/2026
This Privacy Policy is provided by Graylark Technologies Limited, a company registered in England and Wales under company number: 15528848 (‘we’, ‘our’ or ‘us’) for use of our cloud-based collective labour relations platform and any other platform/websites we operate with the same domain name and different extensions (Platform). Our platform helps organisations manage and implement changes across their workforce.
We take data protection very seriously. Please read this privacy policy carefully as it contains important information on how we process personal data on behalf of our client organisations in the context of collective labour relations.
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We act as a data processor for the personal data obtained via the Platform, processing such data on behalf of our client organisations who are the data controllers. In certain limited circumstances, such as when processing data for our own business operations and marketing activities, we may act as a data controller. This means our client organisations are legally responsible for deciding how and for what purposes the personal data is used, while we process it according to their instructions.
In addition to our role as data processor for Platform data, we act as data controller for personal data processed in connection with billing and invoicing for our services. This means we are legally responsible for determining how and why billing data is processed. Section 2 below explains our role as data controller for billing data. The remainder of this policy addresses our role as data processor for Platform data.
While this privacy policy primarily addresses our role as a data processor for Platform data (where your organisation is the data controller), we also act as a data controller for certain personal data processed in connection with billing and invoicing for our services in case a billing agent (data processor) will process personal data for billing purposes on our behalf.
For billing and invoicing purposes, we collect and process the following personal data: name, registered address, company number, primary contact email, purchase order numbers and payment references.
This privacy policy relates to your use of the Platform and for accessing the services through the Platform.
The Platform may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with the service through the Platform. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
The personal data we process on behalf of your organisation depends on the particular activities carried out through the Platform. This includes personal data relating to worker representatives and workforce management activities. We will process the following personal data on behalf of your organisation:
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We may send service-related communications and platform updates to designated organisational contacts as necessary for the operation of the collective labour relations platform. These communications will be limited to essential service information, platform functionality updates, and relevant business communications regarding our collective labour relations services.
As a data processor, we will only send communications as instructed by the client organisation and in accordance with our data processing agreement.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on data subject rights and how they should be exercised through your organisation as the data controller, see ‘Your rights’ below.
We do not share personally identifiable information (PII) collected through the collective labour relations platform with third parties. For security purposes, we automatically collect and process user location data (limited to country/region) through IP address detection. We may engage service providers such as cloud storage providers and developers to help us operate our platform, but these providers only process data under strict confidentiality obligations and do not have access to PII related to worker representatives or other individuals involved in collective labour relations activities.
As a data processor, we only engage sub-processors who provide sufficient guarantees to implement appropriate technical and organisational measures that meet GDPR requirements and ensure the protection of data subject rights. All sub-processors are bound by written contracts that include specific data protection obligations and require them to only process personal data on documented instructions from us, acting on behalf of the data controller (your organisation). These contracts include confidentiality obligations, security requirements, and audit rights that are at least as protective as those in our agreement with the data controller.
We or the third parties mentioned above may occasionally also need to share your personal data with:
external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
We will retain and process your personal data in accordance with the instructions of your organisation (the data controller), our data processing agreement, and applicable data protection laws. However, we reserve the right to retain certain data as required by law or for legitimate business purposes, such as audit requirements, dispute resolution, and enforcement of agreements. By default, we will retain the data for as long as your organisation maintains an active account with us, plus any additional retention period specified in our data processing agreement with your organisation or as required by applicable laws governing collective labour relations records. When instructed by your organisation or upon contract termination, we will securely delete or return all personal data as specified in our data processing agreement.
Following the end of the aforementioned retention period, we will delete or anonymise your personal data in accordance with applicable technical standards and industry best practices, unless retention is required by law or for legitimate business purposes as outlined above.
While we primarily process and store your personal data within the UK, we may in the future need to transfer your personal data outside the UK to provide our services effectively. Any such transfers will only be made in compliance with UK data protection laws and with appropriate safeguards in place. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.
Furthermore, under UK data protection laws, as a data processor, we will only transfer personal data outside the UK under the explicit instruction of the data controller (your employer) and where permitted by our data processing agreement. Any such transfers would only occur where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) under Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or a specific exception applies under relevant data protection law. If international transfers were to be implemented, they would only be done with prior notification to and approval from the data controller. Accordingly, if we were to start transferring your personal data from the UK to:
The EEA: transfers would be conducted under the adequacy finding granted by the UK to the EU under the Withdrawal Agreement; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
For any transfers of personal data outside the UK/EEA, we will only process data according to the instructions of the data controller (your employer) and in compliance with appropriate safeguards under the UK GDPR and other applicable data protection laws, which may include the relevant Standard Contractual Clauses or other approved transfer mechanisms included in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
As a data processor, we will only process these rights requests when properly validated and formally instructed by your employer (the data controller). While you have the following rights under data protection law, please direct any requests to exercise these rights to your employer's data protection team. For more information regarding these rights, please visit the ICO website here.
For further information on each of those rights, including the circumstances in which they apply, please contact your employer's data protection team. You may find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR. While all data rights requests must be directed to your employer's data protection team, if you need to contact us about platform-specific technical issues unrelated to data protection rights, please:
provide sufficient information to verify your identity as an authorised platform user (including your full name, username, and any additional verification information we may reasonably request), and
clearly describe the technical platform issue you are experiencing or the support you need
As a data processor, we have implemented appropriate technical and organisational security measures to prevent personal data from being accidentally lost, used, or accessed unlawfully. We limit access to personal data to authorised personnel who have a genuine business need to access it for the purpose of providing our collective labour relations platform services to your employer, subject to appropriate confidentiality obligations.
We also have procedures in place to deal with any suspected data security breach. As a data processor, we will notify your employer (the data controller) without undue delay of any suspected data security breach, and they will be responsible for any required notifications to individuals or regulators.
For information about our platform security measures and how we protect data processed on behalf of your employer, please contact your employer's data protection team or refer to our security documentation. Technical documentation about our security controls is available to authorised organisational representatives subject to appropriate confidentiality agreements and security protocols.
If you have any queries or concerns about how your personal data is processed on our platform, please contact your employer's data protection team in the first instance. For technical platform issues unrelated to personal data processing, you may contact our support team (see 'How to contact us' below).
While you have the right to lodge a complaint with the Information Commissioner, we encourage you to first raise any concerns with your employer's data protection team so they can be addressed promptly.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
We may change this privacy policy from time to time. When we make significant changes, we will notify your employer (the data controller) with reasonable advance notice, who will be responsible for communicating these changes to you where appropriate. Changes will also be posted on our platform. Your continued use of our platform after such changes constitutes acceptance of the updated privacy policy.
You can contact us by email at privacy@graylarktechnologies.com, if you have any questions about this privacy policy or the information we process on behalf of your employer. To exercise your data protection rights or make a complaint, please contact your employer's data protection team in the first instance, as they are the data controller. We will cooperate with your employer to fulfil any valid data subject rights requests.
If you do not provide personal data we ask for where it is required, it may prevent us from providing service to you through the Platform.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ usage data (including information about how users interact with and use the Platform and place any request for accessing services through the Platform) to calculate the percentage of users accessing a specific feature of the Platform in order to analyse general trends in how users are interacting with the Platform to help improve the Platform and our offerings.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
If you submit special category data, we will process it solely on behalf of your organisation, and only where your organisation has determined and documented a lawful basis for such processing.
For security purposes, we automatically determine your location (limited to Country/Region) using your IP address. This information is used solely for security checks and does not affect Platform functionality.
The Platform's map features function independently of your location data. The location information we collect is used solely for security purposes.
Our map services are provided through Google Maps integration. When using theses service/data, data may be collected by Google in accordance with their Privacy Policy.
We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site - https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.
We use different methods to collect data from and about you including through:
Your interaction with us: We collect personal data from you when you are onboarded to the Platform by your organisation's administrators, browse the service listings available on the Platform, place any request for accessing the services or connecting with a service provider through the Platform, subscribe to our communications, request for marketing emails to be sent to you, contact us directly or reach out to us via social media, make submissions via the Platform when a forum element is available, or indirectly, such as your activity while using the Platform, participate in any feedback or survey.
Automated technologies or interactions: As you interact with the Platform, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.