Data processing terms.

01Roles

• You are the controller of the personal data in the documents and records you put into the platform (for example, bills, invoices, fuel-card statements and site details).
• We are your processor. We process that data only to provide the services you have engaged us for.
• When you invite suppliers, or share with a buyer, you are the controller of the contact details you give us and of what you choose to share; we process them on your behalf. A buyer you share with receives that information as its own controller, not as our sub-processor.

02What we process

• Purpose: Recording, checking and reporting your organisation's carbon emissions, including preparing Carbon Reduction Plans and related compliance documents, and, when you choose, making selected results available to the buyer organisations you name.
• Nature: Storage; reading of uploaded bills by an AI model to propose values for a person to confirm; a check by a second person on paid plans; calculation and reporting; making selected results available, read-only, to organisations you choose.
• Types of personal data: Names, business or site addresses, account numbers, meter and card references, and similar details that appear on your documents; the names and email addresses of your users.
• Data subjects: Your staff and users; individuals named on your bills and invoices, including your suppliers' staff and sole traders; the contacts at your suppliers you invite.
• Duration: For the term of the agreement, then as set out in section 7.

03Our commitments

We will:

• process the data only on your documented instructions, including these terms and your use of the platform, unless UK law requires otherwise, in which case we'll tell you before processing, unless that law forbids it;
• ensure everyone who processes it is under a duty of confidentiality;
• keep appropriate security measures in place, including: your uploaded data held in London; access limited to members of your organisation and authorised seer. staff, and enforced in the database; files kept private and served only through short-lived links; every AI call logged; no AI-proposed value used until a person has confirmed it and, on paid plans, a second person has checked it;
• use sub-processors only as set out in section 5;
• help you respond to requests from individuals exercising their rights, so far as the platform allows (see section 7);
• help you meet your obligations on security, breach notification and data protection impact assessments;
• at the end of the agreement, delete or return the data as set out in section 7;
• give you the information you reasonably need to show compliance with Article 28, and allow for audits on reasonable notice.

We will tell you without undue delay, and within 48 hours of becoming aware of it, if a personal data breach affects your data.

We will tell you straight away if we believe an instruction from you breaks data protection law.

04Sharing with buyers you choose

When an owner or admin of your organisation shares information with a buyer on seer., that is your instruction to us to make it available to that buyer, read-only, until you withdraw it. You choose what to share for each buyer separately: totals of your figures, with checked and not checked shown separately; the status and date of your Carbon Reduction Plan, and its signed copy; or the documents you added.

If your organisation relies on its parent's group plan. A company in a group on seer. that its parent wholly owns can record that it relies on the parent's group Carbon Reduction Plan, once an owner or admin of the parent has agreed. While it does, and unless it has signed a plan of its own, sharing its Carbon Reduction Plan with a buyer shows that buyer the parent's signed group plan that covers it: its status and date, and its signed copy, labelled as the parent's plan. When an owner or admin of a parent agrees that a company may rely on its group plan, that is the parent's instruction to us to show the plan in this way to the buyers that company shares its plan with. It stops when either side ends the reliance or the company leaves the group; what a buyer has already downloaded stays with it.

You can withdraw any choice at any time. The buyer can download the signed plan and the documents you share: anything it downloaded while you shared it stays with the buyer, and withdrawing ends its access to everything else.

We record each choice and each withdrawal in your audit trail. We don't share anything with a buyer without your instruction. Documents you choose to share may contain personal data; you confirm you have a lawful basis to share them.

05Sub-processors

You give general authorisation for the sub-processors below. We will give you at least 30 days' notice of any addition or replacement, and you may object. If you object and we can't reasonably resolve it, you may end the affected services. We impose data protection obligations on each sub-processor that are no less protective than these terms.

• Supabase: database, file storage and sign-in. Processed in London (eu-west-2). Transfer safeguard: UK (data stored in London); Supabase's Data Processing Addendum with the UK Addendum.
• Vercel: hosting and server functions. Server functions in London; requests first reach Vercel's nearest network location, which may be outside the UK. Transfer safeguard: Standard Contractual Clauses with the ICO's UK Addendum.
• Google Cloud: AI reading of uploaded bills, and a nightly backup copy of the files stored in seer. (bills and other evidence, signed plans and statements, and documents), kept so they can be restored if lost. Processed and stored in London (europe-west2) only. Transfer safeguard: UK; Google's Cloud Data Processing Addendum.
• Google Workspace: business email and correspondence. Processed as set by Google's data location settings. Transfer safeguard: Google's Data Processing Addendum, including its UK transfer terms.
• Resend: sending account and notification emails. Processed in the United States. Transfer safeguard: Standard Contractual Clauses with the UK Addendum; EU-U.S. Data Privacy Framework and its UK Extension.
• Sentry (Functional Software, Inc.): error reports from server code, with request bodies, cookies, headers, query strings and email addresses removed before sending. Error data stored in the EU (Frankfurt, Germany); account and organisation settings in the United States. Transfer safeguard: EU-U.S. Data Privacy Framework and its UK Extension; Standard Contractual Clauses with the UK Addendum where the Framework doesn't apply.

Supabase and Vercel run on Amazon Web Services in its London region; AWS is their sub-processor, covered by their own data processing agreements.

Google may keep a request in an in-memory cache for up to 24 hours, and, only where its automated checks flag a request, a log for up to 90 days which authorised Google staff may review. Google does not use the data to train its models.

06International transfers

We do not transfer your personal data outside the UK except as shown in section 5, and only with the safeguard named there.

07Retention, deletion and the limits of the ledger

• Returning your data. An owner of your organisation can download all of its data at any time, on every plan, from Settings → Export: a CSV file for each kind of record, your signed plans and SECR statements, and the files attached to entries and your documents, with a manifest giving each file's SHA-256 fingerprint. This is how we return your data, during the agreement and at its end. It holds only your organisation's own data: what another organisation shared with you, such as a supplier's figures, stays theirs. If no owner can sign in, email admin@seerconsult.com: we first check that the person asking has authority to act for your organisation, and then provide the export to them.
• We keep your data for 7 years from the end of the agreement, except as set out next, because buyers, auditors and procurement teams may ask for the evidence behind a published plan years after it was issued.
• Free organisations that were never used for a paid plan. If your organisation has never had a paid plan and has never signed a Carbon Reduction Plan, the 7-year period doesn't apply. When nobody in it has signed in or used it for 12 months, we email its owners. If nobody signs in within 30 days of that email, we delete all of its data at our next quarterly clean-up, including its ledger entries, files, audit trail and the sign-in accounts of members who belong to no other organisation. We keep only a record that the deletion happened, with no personal data in it. If your organisation shares with buyers on seer., we tell each of them when we email your owners.
• On request, or at the end of that period, we delete the stored files (bills, evidence and imports), invitations, completed verification requests and the sign-in accounts of your members and former members who belong to no other organisation on seer., except your last owner and anyone we can't confirm belonged only to your organisation. We follow a documented and tested procedure, and we send you a record of what was deleted and what was kept.
• What we keep: the confirmed figures, each file's digital fingerprint (SHA-256) and the audit trail, so that a published plan can still be proved. Signed plans are kept unless you ask us to delete them.
• A current limit, stated plainly: some personal text recorded inside checked ledger entries and the audit trail (for example, a supplier or site name) cannot yet be removed, because the ledger is built so that checked records cannot be altered. We intend to add a way to redact it, and will tell you when it is available.
• Copies in backups expire on the backup provider's normal schedule. A backup copy of a stored file is deleted 7 days after the file itself is deleted.

08Your responsibilities

You confirm that you have a lawful basis to give us the personal data in your documents, and that you have told the people concerned, where required, that their data will be processed for these purposes.

09Changes to these terms

If we change these terms we will publish a new version on this page, with its number and date, and ask an owner of your organisation to accept it. The record of the version you accepted is kept.

Contact for data protection matters: admin@seerconsult.com