Version draft-2026-10-05 · effective 2026-10-08
This text is an engineering draft that describes what the platform actually does with personal data, written so it can be handed to a lawyer and to a privacy reviewer. It has not been reviewed by counsel. Items marked [COUNSEL REVIEW REQUIRED] need a decision or a verification before this becomes the published policy.
For the account and usage data described below, International Welding Bureau is the controller.
For the documents and records your organization uploads, your organization is the controller and we are its processor: we handle that content on its instructions, under its agreement with us.
[COUNSEL REVIEW REQUIRED] Legal entity, registered address, and whether a data protection officer or EU/UK representative is required.
Account data: your name, work email address, phone number if you give it, your role, the organizations you belong to, and your password in hashed form. We never store your password in a form we can read.
Authentication and security data: sign-in times, IP address, browser user agent, failed sign-in attempts, session and token identifiers, and the record of your acceptance of these terms and this policy — including the version accepted, the time, and the IP address it came from.
Content data: the documents, material test reports, qualification records and comments your organization uploads or creates, including any personal data inside them, such as a welder's name or stencil number.
Usage data: which features you use, scans run, pages processed, credit movements, and the audit trail of privileged actions.
Billing data: your organization's billing contact, invoices, credit balance and transaction history. Card details are entered directly into our payment gateway and are never stored on our systems; we hold only a token, the card brand, its last four digits and its expiry month.
Support data: tickets you raise and anything you attach to them.
To provide the platform and your organization's account: performance of the contract with your organization.
To authenticate you, keep accounts secure, detect abuse and keep audit records: our legitimate interest in a secure, accountable service, and in places where that concept does not apply, performance of the contract.
To bill, collect payment and keep accounting records: performance of the contract and our legal obligations.
To send service and billing notifications — expiring cards, low balance, credit expiry, scan outcomes: performance of the contract. These are not marketing and are not optional while your account is active.
To comply with law, and to establish or defend legal claims: our legal obligations and legitimate interests.
We do not sell personal data, and we do not use your organization's document content to train models for other customers.
MTR validation is automated. It produces findings for a human reviewer in your organization to accept or reject; it does not make a decision about any individual, and it does not by itself determine anyone's qualification, employment or certification.
Service providers that help us run the platform, under contract and only for that purpose:
Within your organization: administrators can see the accounts, activity and records of their organization's users. That is how the product works, and it is their decision who holds those roles.
Others: where we are required by law, to establish or defend legal claims, or to a successor if the business is sold.
[COUNSEL REVIEW REQUIRED] Publish the named sub-processor list, with each one's purpose and location, and keep it current. Confirm whether the AI validation engine is self-hosted in all deployments; if any deployment sends document content to a third-party model provider, that provider must be named here before launch.
The platform and its backups are hosted in the United States. If your organization is outside the United States, using the platform involves transferring personal data there.
[COUNSEL REVIEW REQUIRED] Transfer mechanism for EU/UK customers — standard contractual clauses plus a transfer impact assessment — before selling outside the United States.
Account data: while your account is active. When an account is closed we remove the personal details and keep a non-identifying record that the account existed, because the audit trail and signed documents reference it.
Content data: for as long as your organization's retention settings and the standards it works under require, and as long as the law requires.
Billing and ledger records: kept for the statutory accounting retention period. Credit and payment history is append-only and is not deleted on request, because it is a financial record.
Security and audit logs: kept for the period in the platform's retention configuration.
Encryption in transit; access control by role and by organization; per-organization data isolation; hashed passwords; audit logging of privileged actions; and separation of payment card data into the gateway so it never reaches our systems.
No system is perfectly secure. If a breach affects your personal data, we will notify you and the relevant regulator as the law requires.
Depending on where you live, you may have the right to access your data, to get a copy of it, to correct it, to delete it, to restrict or object to processing, and to complain to a data protection authority.
You can export your personal data and close your account yourself from Account & Security. For anything else, or for data your organization controls, contact us or your organization's administrator.
Some data cannot be deleted on request: audit records, signed documents and financial ledger entries are kept because we are required to keep them.
We do not discriminate against anyone for exercising these rights.
[COUNSEL REVIEW REQUIRED] Confirm which regimes apply at launch — GDPR, UK GDPR, CCPA/CPRA, and state privacy laws — and align this section and the response deadlines with them.
We use cookies that are necessary to sign you in and keep your session secure. We do not use advertising cookies or third-party tracking for marketing.
[COUNSEL REVIEW REQUIRED] Verify against the deployed frontend that no analytics or marketing tags are present, and state whether a consent banner is required in the markets we sell into.
The platform is for workplace use and is not intended for anyone under 16. We do not knowingly collect their data.
We publish each version of this policy separately and record which version each user accepted. When a version changes materially, we ask you to accept it the next time you sign in and tell you what changed.
Privacy questions and rights requests: [email protected]
[COUNSEL REVIEW REQUIRED] Confirm the contact address, the postal address, and the escalation path for rights requests.