Privacy policy

This policy explains what personal data Modyx collects, how we use it, who we share it with, and what your rights are. It covers both the electricians who use Modyx and the customers whose details those electricians share with us in the course of using the service.

The short version:to turn a dictation into a certificate, we send the audio to OpenAI and the transcript to Anthropic — and that dictation usually describes somebody else’s home and its electrical faults. Both are in the United States. Neither trains on it. The detail is here. Our application and database are hosted in the European Economic Area — not the UK. We have removed an earlier claim that Modyx was “UK-hosted”; it was not accurate.

Who we are

Foreman is operated by Luke Pledger, a sole trader trading as “Foreman” from the United Kingdom. We are the data controller for the personal data described below.

We are registered with the UK Information Commissioner’s Office (ICO) as a data controller. Our registration reference is ZC133369.

Contact / data protection enquiries: hello@modyx.co. As a sole trader we are not required to appoint a Data Protection Officer; data-protection enquiries are handled by Luke Pledger and answered from this address.

The two kinds of people in our data

Foreman handles two distinct groups, with different relationships to us:

• Electricians— our customers. They sign up, subscribe, and use Foreman to draft electrical documents. We are the data controller for their account and usage data.
• End customers— the homeowners and businesses whose names, addresses, and installation details appear in the documents the electrician dictates. The electrician is the data controller for those records; Foreman processes them as a data processor acting on the electrician’s instructions to produce the requested draft.

If you are an end customer and want to exercise rights over your data, your first point of contact is the electrician who instructed the work — they are the data controller and will be best placed to locate and act on your records. You may also contact us directly at hello@modyx.co and we will assist or pass the request to the electrician as appropriate.

What data we collect

From electricians (when you sign up and use Foreman):

• Mobile number and email address (your account identifiers)
• Business name, day rate, and VAT details (if provided during onboarding)
• Voice notes, photos, and text you capture in the Modyx app to dictate observations, test results, and other job details (for example, photos of consumer units or an installation)
• The draft documents Foreman produces for you: EICR observation schedules, EICs, Minor Works certificates, remedial quotes, and invoices
• What you enter when you sign a certificate: your signature image, your registration number, and your scheme membership number
• A record of each signature and each consent decision — the time, your IP address, your browser or device, and (for a signature) how long you spent reviewing and how many edits you made. See what we record when you sign.
• Billing data: Stripe customer ID and subscription status (your card details are held by Stripe, never by Foreman)
• Basic technical data: error reports, and usage events used for product improvement and debugging. Each usage event is stored with your IP address and your browser or device.

From end customers (indirectly, via content you share with Foreman):

• Names, addresses, and installation details that appear in the voice notes and photos you send — for example, the occupant’s name and the property address for an EICR, or the client and site address on a quote
• Any other personal data about your customers that you include when dictating a document: test results, fault descriptions, remedial observations

We do not independently collect data directly from your end customers. What we hold about them comes entirely from you.

How we use it

We use this data to:

• Provide the Foreman service — receiving your voice notes, photos, and typed notes, transcribing them, and producing draft documents
• Deliver drafted certificates to you in the Modyx app for review, and email the signed PDF to your customer when you choose to issue it
• Process your subscription payments through Stripe. Your card is stored when you sign up and is not charged that day: your first 5 certificates and 10 quotes/invoices are free. Modyx then costs £39/month, charged when you use that allowance up — not on a date — and renewing monthly. We email you before the first payment. You can cancel at any time. See clause 5 of the Terms of Service.
• Improve and debug the product (technical logs and limited product analytics, which you can switch off in Settings)
• Send service messages (billing receipts, subscription updates, policy change notices, and nudges if a certificate is left mid-dictation) — in the app, by email, or by SMS
• Comply with legal obligations (tax records, fraud prevention)

What we never do with your data:

• We do not sell personal data.
• We do not use your voice notes, photos, transcripts, or drafted documents to train AI models.
• We do not use Foreman data for advertising or marketing to third parties.

Lawful basis (UK GDPR Art. 6)

• Contract— to deliver Foreman to you under our Terms of Service: creating and operating your account, receiving and transcribing voice notes and photos, producing draft documents, and processing payments through Stripe.
• Legitimate interest— to keep the service secure, debug technical issues, improve the product, and hold evidence of who signed each certificate and when. Our legitimate interest does not override your privacy rights; you can object to this processing at any time.
• Legal obligation— to keep tax records (six years) and respond to lawful requests from regulators or authorities.
• Consent— for any optional marketing communications (none currently sent), withdrawn at any time.

What happens to a dictation — read this one

This is the part of the policy that matters most, so we are stating it plainly rather than burying it in a list.

When an electrician dictates a certificate, the recording is typically a description of somebody else’s home— the property address, and the condition and electrical faults of that property. To turn that into a certificate, we send it to two AI providers outside the UK:

• The raw audio is sent to OpenAI to be transcribed into text (we use the gpt-4o-transcribemodel). This is the actual recording of the electrician’s voice, including any address or occupant name spoken aloud.
• The resulting transcript, and any photos taken (for example of a consumer unit), are sent to Anthropic (the Claude models) to be turned into the structured certificate: observations, classification codes, and remedial actions.

Both providers process this data in the United States. Under our API terms with each of them, this content is not used to train their models, and it is sent over their business APIs rather than their consumer products.

If you are an electrician using Modyx, you should know this is happening, because youare the data controller for your customers’ information and it is your call whether that is an acceptable use of it. If you do not want a property’s address processed by an AI provider, do not speak it into the dictation — type it in afterwards, or use a job reference instead.

What we record when you sign a certificate

Signing is the moment the certificate becomes yours and the liability moves to you. So we keep a deliberate record of it. This is evidence of who certified what, and when — it is not analytics, and it is not kept for debugging.

• Your signature image— the signature you draw is stored as a file on your account and printed on the issued certificate. It is kept for as long as the certificate is, which is deliberately longer than an ordinary uploaded file: a signed certificate has to stay intact and readable.
• Your registration number and scheme membership number — as you enter them at signing. They are stored on the certificate record and printed on the certificate itself.
• The time, your IP address, and your browser or device, captured at the moment you sign. These are here to evidence that it was you who signed, and when — the same job the signature and date do on a paper certificate.
• How you reviewed it— how many seconds passed between the certificate being put in front of you and you signing it, and how many changes you made to it. We keep this so that a pattern of instant, unedited signatures across an account is something we can see. One fast signature proves nothing, and we do not treat it as though it did.
• A digest of the exact PDF we issued, so an altered copy of your certificate can be shown to differ from the one you actually signed.

We record the same time, IP address, and browser or device against consent decisions— the exact wording you were shown and the choice you made — for the same reason: evidence of what was agreed. This record is kept with your account and deleted when your account is deleted.

The taster on our website

Our home page lets you try the engine without an account: you describe a fault and watch it come back coded. That is the real system, not a canned animation, so what you enter is really processed.

• What you type is sent to Anthropic to be coded. If you record instead of typing, the audio goes to OpenAI to be transcribed first and is discarded once the text comes back.
• Coding what you type stores nothing. If you go on to generate the specimen certificate, the observation the engine wrote from your words — and the resulting PDF, which contains it — are stored in our database under a single shared demo account. They are not attached to you, and they are not carried into your own account if you later sign up. The PDF is marked SPECIMEN on every page and its link stops working after two hours.
• Your IP address is used to rate-limit the taster so one visitor cannot run it thousands of times.
• Please do not type a real person’s name or address into the taster. It demonstrates on an invented property and does not need them.

Who we share data with (sub-processors)

We use the third parties below to operate the service. Each is bound by a data processing agreement or equivalent contractual terms. We notify you in advance of any material addition or replacement of a sub-processor that handles personal data.

Sentry (error and crash monitoring) is present in our code but switched off. It only activates when a connection key is configured, and that key is not set in any of our environments — so no error reports, performance traces, or crash data are sent to Sentry from our website, our servers, or the iOS app. It is therefore not a sub-processor today and is deliberately not listed in the table above. If we switch it on, we will add it to that table and to the cookies policy — naming where it is hosted and what it receives — before it starts receiving anything.

International transfers

We do not claim that Modyx is “UK-hosted”, and you should not rely on that. Our application and database run in the European Economic Area, and several sub-processors — including the two AI providers that see your dictations — are in the United States.

• Transfers to the EEA(our hosting) are permitted under the UK’s adequacy decision for the EEA. No additional transfer agreement is required.
• Transfers to the United States(OpenAI, Anthropic, Resend, Stripe, Expo) rely on a safeguard under UK GDPR Chapter V — either the UK Extension to the EU-US Data Privacy Framework where the provider is certified under it, or the European Commission’s Standard Contractual Clauses read with the ICO’s International Data Transfer Addendum.

We will tell you which specific safeguard we rely on for any given sub-processor if you ask — email hello@modyx.co.

How long we keep it

• Active accounts— for as long as your account is active.
• After account deletion— your data is immediately deactivated at deletion. All account data (transcripts, photos, drafted documents, etc.) is permanently deleted within 30 days, after which database backups will have rotated. A hashed audit record of the deletion is retained for legal and accountability purposes (one-way hashes only — no identifying details).
• Voice recordings — the audio itself is never stored. A recording is held only for as long as it takes to send it to OpenAI and get the text back, then it is discarded. We keep no audio file, so there is none to export, play back, or delete later.
• Transcripts and photos — the text of what you dictated is stored, and so are the photos you send. Both are retained for as long as the related document is active on your account, and are deleted on request or when your account is deleted.
• Document share links (PDF URLs)— the link generated for viewing or downloading a certificate PDF is an unguessable, randomly generated address (a 256-bit token), not a predictable or sequential one. It does not expire on a timer: a homeowner needs to be able to retrieve their certificate for as long as they own the property, so the link is permanent by design. The electrician who issued it can revoke and reissue the link at any time — the old link stops working immediately and a fresh one is generated in its place. The file is served with response headers that stop browsers and intermediate caches from storing a copy, and is deleted on request or when your account is deleted.
• Billing records— Stripe retains transaction records for at least six years to meet UK tax requirements.
• Technical logs— application logs are retained by our hosting provider under its own retention settings and are deleted on that provider’s rotation schedule. We do not currently operate a separate fixed-period purge of application logs, and we would rather say so than quote you a number we do not enforce. Logs are not used for anything other than diagnosing faults.
• Data held by AI providers— OpenAI and Anthropic apply their own limited retention to API requests for abuse-monitoring purposes, under their commercial API terms, and do not train on this content. We do not control those retention periods.

Your rights

Under UK GDPR you have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Erase your data (“right to be forgotten”)
• Restrict or object to processing
• Receive your data in a portable format
• Withdraw any consent you have given
• Lodge a complaint with the ICO at ico.org.uk/make-a-complaint, or by post at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

To exercise any right, or to request deletion of your account and data, email hello@modyx.co. We respond within 30 days.

Security

Data is encrypted in transit (HTTPS/TLS) and sensitive credentials are encrypted at rest. The database enforces tenant isolation at the row level — one account cannot read another’s data. Passwords, where set, are hashed with bcrypt. Sign-in links are single-use and expire after 15 minutes, and a signed-in session lasts up to 7 days before you need to sign in again. Webhook signatures are verified before any state change is processed.

Cookies

See our cookies policy for details on what we set and why.

Automated decision-making

Foreman uses AI to draft electrical documents from the voice notes and photos you send. This does not constitute solely automated decision-making that produces legal or similarly significant effects on you within the meaning of UK GDPR Article 22 — every draft must be reviewed and signed by you before it has any legal effect. You remain in control at all times.

Children

Foreman is intended for adults (18+) operating an electrical business. We do not knowingly collect data from children.

Changes to this policy

We will update this page and revise the “Last updated” date. Material changes will also be notified to active accounts via email at least 30 days before they take effect.

Contact

Questions, requests, or concerns: hello@modyx.co.