Holetell

We look at the sock. Not your feet, not how you walk.

L-03

Privacy Policy

What we hold, why we hold it, how long for, and how to make us stop.

EFFECTIVE 2026-09-05

1.Who is responsible

1.1BULWELL HOSIERY LTD is the controller of the personal data described here. Our registration particulars are on the Legal Information page.

1.2For anything about your data, write to support@bulwellhosiery.shop with "Data" in the subject line. We answer within one month, and usually much sooner.

2.What we collect

2.1Account data: your email address, a hashed password, and the display name you choose. Lawful basis: performance of our contract with you.

2.2Content data: the two photographs of a sock you upload for each reading, the one line you write about whether it has happened before, and the reading we produce. Lawful basis: performance of our contract with you.

2.2.1We accept photographs of socks. We do not accept photographs of feet or of any part of a person, and no upload facility exists through which such a photograph could be submitted. There is no field in our data model in which a bodily characteristic could be recorded, and we do not derive one.

2.2.2It follows that we do not process health data, and we have no wish to. If you write something about your body in the free-text field, the analysis stops and you are pointed to a podiatrist instead; the text is kept only as part of that reading and is deleted with it.

2.3Billing data: your plan, your billing period, and the record of the two cancellation acknowledgements you gave at checkout. Card details are handled by the payment provider the operator has configured and never reach our servers. Lawful basis: performance of our contract, and our legal obligation to keep tax records.

2.4Technical data: IP address, browser and device type, and request logs. Lawful basis: our legitimate interest in keeping the service running and in preventing abuse.

2.5We do not use advertising cookies, we do not build profiles, and we do not sell or share personal data for anyone's marketing.

3.Model training

3.1Your photographs and the text you write are not used to train models — not ours, not a third party's, not a foundation model's. This is a property of how the service is built, not a setting.

3.2Where a model is used to locate damage on a sock, the image is sent for that single inference and is not retained by the provider for training. We contract for that, and we do not use a provider that will not agree to it.

3.3We do look at aggregate counts — how many readings landed in each position, how often each cause ranked first — to check that the reference table is behaving. Those counts contain no images, no text and nothing that identifies anyone.

4.How long we keep it

4.1Photographs and readings: until you delete the reading, or until you close your account, whichever is first. Deleting a reading deletes its images at the same time. Deletion is immediate in the application and completes in backups within 30 days.

4.2Account data: until you close the account, then 30 days, then deleted.

4.3Billing records: six years after the end of the tax year they relate to, because we are required to keep them.

4.4Request logs: 90 days.

4.5You do not have to close your account to delete your content. Every reading has a delete control next to it, and there is a delete-everything control on the billing page.

5.Who else sees it

5.1Our hosting provider, which runs the servers and the storage. Our model provider, for the single inference described in 3.2. The payment provider the operator has configured, for billing. Each is a processor acting on our written instructions, and none of them may use your data for their own purposes.

5.2We disclose data to a public authority only where we are legally required to, and we tell you unless we are prohibited from doing so.

5.3If the business is ever sold or merged, your data would transfer with it and you would be told beforehand.

6.Transfers out of the United Kingdom

6.1Some of our processors operate outside the United Kingdom. Where personal data is transferred to a country without UK adequacy regulations, we rely on the International Data Transfer Agreement, or on the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment.

6.2You can ask us for a copy of the safeguards in place for any particular transfer by writing to support@bulwellhosiery.shop.

7.Your rights

7.1You have the right to be told what we hold about you and to have a copy of it; to have it corrected; to have it erased; to restrict or object to how we use it; to receive it in a portable form; and to withdraw consent where we relied on consent.

7.2There is no charge, and we do not require you to explain why.

7.3You also have the right to complain to the Information Commissioner's Office, which is the United Kingdom's supervisory authority for data protection. You can do that at ico.org.uk, or by calling the ICO on 0303 123 1113. You do not have to raise it with us first, though we would rather you did so we can fix it.

7.4We do not make solely automated decisions that produce legal effects for you or similarly significantly affect you. A reading is information; it decides nothing about you.

8.Security

8.1Data is encrypted in transit and at rest. Access to production data is limited to the people who need it, and every access is logged.

8.2Workspace pages are served with no-store cache headers, because they contain your photographs and no intermediary should keep a copy.

8.3If a breach is likely to result in a risk to your rights, we will report it to the Information Commissioner's Office within 72 hours and tell you without undue delay where the risk is high.

9.Children

9.1The service is for adults. You must be 18 or over to hold an account, and we do not knowingly collect data from anyone younger. If you believe we have, tell us and we will delete it.

10.Changes

10.1We will tell registered users at least 14 days before a material change to this policy takes effect. The effective date at the head of this page always tells you which version you are reading.