Privacy Policy — Ireland
How Cerrax handles personal data under the GDPR, in plain terms.
1. Who we are
Cerrax Ltd ("Cerrax", "we") provides software for removals firms: a pricing engine, and the enquiries, customer records, quotes and jobs around it. We have not appointed a Data Protection Officer. We are a company registered in England and Wales and we are not established in the European Union. This policy explains what personal data we handle for firms in Ireland and the people they quote, why, and your rights. Questions: hello@cerrax.io.
We have not designated a representative in the EU under Article 27 of the GDPR, and we do not think one is required. For a firm's customers, contacts, enquiries and job data, we act as the firm's processor: the firm is established in the EU and is the controller, and we do not offer goods or services to those people, so Article 3(2) — and with it Article 27 — does not apply to that processing (EDPB Guidelines 3/2018 on territorial scope). Our own processing, as a controller, of data about people in the EU is limited to administering our business customers' accounts, answering enquiries sent to us, keeping the service secure, and the few uses of our own that section 1 of our Data Processing Agreement lists (de-identified records, and descriptions of items kept for 30 days); it is occasional, low-risk and involves no special-category data, and for that remainder we rely on the exception in Article 27(2)(a). We keep this under review and will name a representative here if it changes. In the meantime, contact us directly at the address above.
2. Two different roles
Our role under the GDPR depends on whose data it is:
- Your data (the removal firm using Cerrax). For account holders' own details, we are the controller.
- Your customers' data. When a firm uses Cerrax, personal data about the people it deals with — its customers, the people who enquire with it, its other contacts, and its own staff and crew in their working role — is handled by us as a processor, on the firm's instructions. The firm is the controller; our processing is governed by our Data Processing Agreement with the firm. If you are a firm's customer, the firm's own privacy notice applies to you, and questions about your data are best sent to the firm first.
- Partner offers on a firm's customer pages. We are the controller for partner offers, which we run for our own purposes (see §3). As far as a firm is responsible with us because it chooses to show them, we have agreed that we handle the information and any request about them.
- Website visitors. We are the controller for the limited data you give us directly (e.g. a waitlist or contact form), and for keeping the service secure.
3. What we collect
From firms using Cerrax: account and contact details (name, company, email, phone, VAT number if you give it), and the job inputs you enter to produce a price. When you sign up, we also note which website or campaign sent you — the referring website's name (never the page), the Cerrax page you landed on and any campaign label on the link — and your answer if you tell us how you heard about us. We use this only to learn which channels work; it is not used for advertising and is not shared. Within job data: addresses and job details, which may be personal data of your customers — processed only to produce and explain a price and record the outcome you tell us. From the job itself: where your crew use Cerrax on the day, photographs they take of the property, its access and any damage found; if you ask your customer to sign the inventory, the name they give and the signature they draw; and, if you invite it and your customer chooses to, a video of their home, or photographs of it, that they send you to be quoted from. These are held as the record of the job, on your instructions, and are used for nothing else: they never affect a price and are never shared with another firm, unless the firm chooses to send a link to its crew or its insurer (see below). The one exception is your customer's own choice, described next. From website visitors: what you submit in a waitlist, demo or contact form. We do not record your browsing sessions or track behaviour for advertising; the only advertising on Cerrax is partner offers on a firm's customer pages, described below.
Contacts and enquiries (for firms that switch them on). A firm can keep a contact record for each of its customers and enquirers — their name, email addresses, phone numbers, company, preferred language, the addresses they have moved from or to, where the enquiry came from, the firm's notes, and any choice the person made about the firm's messages. The firm decides what is kept and is the controller; we hold it as the firm's processor, only within that firm's account, and never share it with another firm. To recognise the same person arriving twice, we keep a scrambled key made from their email address or phone number that cannot be read back without a secret held only by us.
Enquiry emails and AI. A firm can give lead websites a Cerrax address to send enquiries to. We receive those emails (through Amazon Web Services, London) and read them to fill in the enquiry. If an email isn't laid out in labelled lines, we send its text — without the forwarding headers or earlier quoted messages — to Anthropic, an AI provider in the United States, which suggests the name, contact details, addresses, date and size of the move. A suggestion is only used if the words appear in the email, and a person at the firm checks it before anything is priced or sent. Anthropic does not use it to train its models and deletes it within 30 days (longer only if it is flagged for misuse). We do not keep the email's text for any purpose of our own. When a firm describes a job's items and rooms to Cerrax, we keep that description — with any email address, phone number or Eircode removed — for 30 days to improve how Cerrax recognises items, and then delete the text.
Messages a firm sends through Cerrax. A firm can switch on emails in its own name: reminders to someone who asked it for a quote (up to three, stopping as soon as they reply, accept or decline — in Ireland only if the person agreed to them when they enquired, as the ePrivacy Regulations (S.I. 336/2011) require), a thank-you after a move, and — only if the customer ticked a box agreeing to it — one email after the move asking whether they know anyone else who is moving. Every one has a one-tap link to stop them; stopping covers all of these emails from that firm to that person. We keep a record of each choice and when it was made so the firm can show it later, and we keep a scrambled note of a stop so it is honoured even after other records are deleted. The firm is responsible for these messages; we send them on its instructions.
Training software. Cerrax does not ask customers in Ireland to let it keep their video or photographs to train software: every video and its photographs follow the 90-day rule in §10.
Links a firm chooses to share. A firm can send its crew a link to a job sheet, and can give its insurer, broker or claims handler a link to a job's evidence — the customer's name, the photographs, video and signatures, never their email address or phone number. Evidence links expire after a period the firm chooses, at most 90 days; they can be revoked at any time and record each time they are opened. Who receives a link is the firm's decision.
Calendar feeds. If a firm subscribes its own calendar (for example Google, Apple or Microsoft) to its Cerrax calendar link, that calendar provider fetches the firm's booked jobs — including the customer's name, addresses and phone number unless the firm chooses the private version — and holds that copy under the firm's own agreement with it.
Messages about a job. As part of a job, a firm can send its customer booking confirmations, move-day reminders, requests for a video or a payment, a note before a quote expires and, after the move, a request for a review — by WhatsApp where the firm has connected it and the customer uses it, otherwise by email. The customer can instead answer the review request privately, with a rating from 1 to 5 and a comment that only the firm sees. A firm can also keep follow-up tasks about a customer, with notes.
When a customer accepts a quote, we record the time, the version of the firm's terms and the cancellation statement shown, and any box the customer ticked. We do not record their IP address or device. We also count how many times the page for a quote is opened, and note when it was last opened, so the firm can see whether its quote has been read.
A firm's team. The logins of the people a firm invites — their name, email address and sign-in details, including two-step sign-in if they turn it on (the secret that links their authenticator app, and one-time recovery codes kept in scrambled form) — are account data that we are responsible for. What a firm records about its crew for its jobs — the mobile numbers used to send them job sheets, who is assigned to which job, and the times they mark arrival or completion — is the firm's data, which we hold on its behalf. No location is ever captured.
Faces in photographs and video. Nothing in Cerrax recognises a face or keeps any measurement of one. Where faces are blurred, software finds them only to blur them, and the unblurred original is then deleted.
Feedback and problem reports. If someone at a firm reports a problem or sends us feedback from inside Cerrax, we keep it with their name and account so we can look into it and tell them when it is fixed. We may use Anthropic to sort feedback into categories.
Dictation. If you dictate into Cerrax, your browser's own speech-recognition service (Google in Chrome, Apple in Safari) turns your speech into text before it reaches us, under your browser's terms. We receive only the text; you can type instead.
Email delivery records and the audit trail. For each email sent through Cerrax we keep the recipient's address, the subject and whether it was delivered, to investigate delivery problems. We also keep a record of consequential actions in an account and who took them, to keep the service secure and accountable.
Partner offers. A firm's customer pages may show offers from our partners, marked "Ad · Partner offer". For these, Cerrax is the controller. We keep no offers data about any individual customer. The first time a customer taps an offer we ask whether the visit may be tracked (Regulation 5(3) of the ePrivacy Regulations 2011, S.I. 336/2011, requires that consent); their answer, and whether they hid offers, are kept only on their own device, in their browser, which is strictly necessary to remember the choice they made. They can change it there at any time, and it is lost if they clear their browser or change device — they are then simply asked again. For each tap we record only the firm (as a code), the offer, the country, whether tracking was on, and the time: no customer, job or device identifier, no IP address and no Eircode. Because nothing in it can identify a customer, we do not treat the click record as personal data; if it ever were, our basis would be our legitimate interest (Article 6(1)(f)) in being paid correctly for the offers taken. The affiliate network receives only what the tap itself carries. If the customer taps "Check availability at [Eircode]" on a broadband offer, the new home's Eircode goes to that partner. Nothing else about the customer is ever sent to a partner.
4. Cookies
We use only the cookies needed to make the site and service work (for example, keeping you signed in). We don't set advertising or cross-site tracking cookies ourselves. When a customer taps a partner offer and allows it, the offer's affiliate network sets its own cookie on its own website to record the visit; we ask first, and "No" opens the partner by a plain link. If we ever add analytics or other non-essential cookies, we'll ask for consent first, as the ePrivacy Regulations (S.I. 336/2011) require.
We measure how many people visit these pages and the Cerrax app using Vercel Web Analytics, which is privacy-preserving by design: it sets no cookie, stores no identifier, and cannot follow you between sites or sessions. It tells us page counts, referring sites and countries — never who you are.
We also keep a few things in your browser so the service works — for example a draft you have not saved yet, or your language. These are strictly necessary and are never used for tracking.
5. Why we use it, and our lawful bases
- To provide the service — performance of our contract with you (Article 6(1)(b)). We need your name and email address to open an account; without them we cannot provide Cerrax.
- To keep the service secure and prevent abuse (for example, rate limits, blocking attacks, and checking that a visitor to the public price check is a person) — our legitimate interest in keeping Cerrax and the firms on it safe (Article 6(1)(f)).
- To improve the pricing engine — our legitimate interest in calibrating prices (Article 6(1)(f)), using de-identified data (see §7); and, to improve how Cerrax recognises items, keeping a firm's descriptions of a job's items and rooms for 30 days with email addresses, phone numbers and Eircodes removed (see §3).
- To meet legal obligations — e.g. accounting, responding to lawful requests (Article 6(1)(c)).
- To run partner offers — the customer's consent for a tracked tap (Article 6(1)(a)), kept on their own device; the click record identifies no customer, and so far as it were ever personal data, our legitimate interest (Article 6(1)(f)) (see §3).
6. Automated pricing
Cerrax produces a price automatically from the inputs and settings provided. This is a tool for the firm: the firm decides what to charge its customer (see our Terms). Cerrax can price an enquiry as soon as it arrives, but that price is a proposal to the firm: the firm reviews it and chooses to send it, change it, or not to quote, and a customer is always free to decline a quote. AI in Cerrax only suggests details for a person to confirm; it never sets a price. Cerrax does not take a decision about anyone based solely on automated processing that produces legal or similarly significant effects on them within the meaning of Article 22 of the GDPR.
7. The learning corpus (important)
Cerrax gets more accurate as it sees real outcomes. When a job is completed, we make a separate de-identified record of it, on the firm's instruction: the volume, a distance band, access features, crew, vans, hours, the price and cost, the month of the move, and an area no finer than the first letter of the Eircode (for example "D"). It never holds a name, contact detail, full Eircode, address, map position, free text, photograph, video, signature, the firm's identity, or any reference that links it back to the job. While we still hold the original job it is treated as personal data like the job itself; once the original is deleted, or the customer erased, no one could identify a living person from it using means reasonably likely to be used — it is then anonymous, and we keep it indefinitely. We never try to re-identify anyone. Aggregated insight may inform regional benchmarks; we never expose an individual firm's prices or any customer's identity.
8. Who we share it with
We don't sell personal data. We use a small set of service providers (sub-processors) under contract. Today they are:
- Google Cloud and Firebase — hosting, database and file storage (London region), and account sign-in.
- Google Maps — geocoding and distances between addresses.
- Anthropic (an AI provider, United States) — only when a firm uses a feature that reads what it is given: the capture bar and narrative capture (turning a description of a job into a list of items), photographs of a written or printed list, spreadsheet import, and enquiry emails with no labelled layout (§3). It proposes items or details for a person to confirm; it never sets a price. It does not train on this data and deletes it within 30 days.
- Amazon Web Services (SES and SNS, London region) — delivers email: to you (account notices, password resets and anything you ask us for) and, on your behalf, to your customers (the quotes and messages you send them through Cerrax); and receives the enquiry emails sent to your Cerrax lead address.
- Stripe — takes payment for your Cerrax subscription; and, if you connect your own Stripe account to take deposits or balances, handles your customer's payment on your account.
- Meta (WhatsApp Business) — only if you connect your own WhatsApp Business number, in which case the messages you send your customers through it are delivered by Meta.
- Xero — only if you connect your own Xero account, in which case the invoice details of the jobs you send to it (your customer's name and address and the amounts) are written into it as draft invoices by Xero.
- Sage — only if you connect your own Sage account instead, in which case the same invoice details are written into it as invoices by Sage.
- QuickBooks (Intuit) — only if you connect your own QuickBooks company instead, in which case the same invoice details are written into it as invoices by Intuit.
- Vercel — runs our website, the Cerrax app and the pages your customers open (London servers, US company), and provides the cookieless visitor analytics described in §4.
- Cloudflare Turnstile — checks that a visitor to our public price check is a person, not a bot.
Stripe (for your customers' payments), Meta, Xero, Sage and QuickBooks act under your own account and agreement with them when you connect them. We keep this list current and reflect only services actually in use; we email account owners at least 30 days before a new provider starts handling their customers' data.
Anthropic is also used to suggest adjustments from the notes on a quote, to write a move-preparation checklist for a customer from the job's Eircodes, date and notes, and to sort feedback sent to us. It does not train on this data and deletes it within 30 days. If a firm asks Cerrax to suggest items from a customer's video, still images taken from that video (never the video itself) are sent to Anthropic, which lists the items it can see, does not train on them and deletes them within 30 days. Cerrax does not keep the still images, and the firm checks the suggestions before anything is priced.
Independent recipients (not our sub-processors). When a customer taps a partner offer, the partner and, if the tap is tracked, its affiliate network receive the visit directly from the customer's browser and handle it under their own privacy notices. For broadband only, and only when the customer taps the button, the partner also receives the new home's Eircode. We have not yet joined any affiliate network in Ireland; we will name each one here, and email account owners, before we use it.
Services you connect yourself. If you connect Zapier, or any other service of your choice through a webhook or API key, we send it the details you ask it to receive (such as an enquiry's contact details and move date); it acts under your own account and agreement with it, not as our sub-processor.
9. Where your data is stored
Your data is held in the United Kingdom, in London. For a firm in Ireland that is a transfer of personal data out of the European Union, and it is lawful because the European Commission has decided that the United Kingdom provides an adequate level of protection (Decision (EU) 2021/1772, renewed by Implementing Decision (EU) 2025/2574 of 19 December 2025 until 27 December 2031). Where a provider processes data outside the EU and the UK — AI processing in the United States is the case today — we rely on the EU–US Data Privacy Framework for providers certified to it, or otherwise on the EU standard contractual clauses (Anthropic, for example, is covered by its data processing agreement with those clauses). We don't move personal data anywhere without a valid transfer mechanism.
As things stand today: every Cerrax account is in a country Cerrax is open in — the United Kingdom, Ireland and France — and the data behind every one of them is held in London. That is a statement of fact on the date at the top of this page rather than a promise about the future — if you need it in writing for a particular account, or want to know where a specific service processes data, ask us at hello@cerrax.io and we will tell you.
10. How long we keep it
Your account data (where we are the controller): for as long as your account is active and for up to six years after it closes, to meet our legal, accounting, and tax obligations — unless the law requires us to keep it longer.
Your customers' data (where we are your processor): for as long as you keep it with us, and deleted or returned when you ask, as the Data Processing Agreement sets out. Unless you tell us otherwise, job records — a quote, its booking and outcome, the crew's sheets, and any survey or damage photographs attached to them — are kept for six years after the move (or after the quote, if the job did not go ahead), unless a claim or dispute about that job is still open, and then deleted. Photographs have no separate clock: they are kept for as long as the job record they belong to and are deleted with it. A customer's video, and any photographs the customer sends with it, are deleted 90 days after the job's last date.
Unless a firm sets different periods: an enquiry that was never priced or sent is deleted 12 months after its last activity; a quote that was sent but never accepted, 24 months after it was sent; a contact record is kept while any job record linked to it is kept, and deleted 12 months after the last one goes (or 12 months after it was made, if it was never linked to a job). A record of a person's consent is kept for as long as their contact record and six years after, so the firm can show it; a scrambled record of a request to stop messages is kept indefinitely, so it keeps being honoured.
Our own records: waitlist, demo and contact enquiries, 24 months after our last contact with you (or sooner if you ask); security logs, 90 days. De-identified records (§7) are not personal data and are kept indefinitely. You can ask us to erase personal data (§12); committed pricing records are never silently altered, but personal identifiers within them are removed.
Also: email delivery records, 90 days; security logs, 90 days (a block on an address is kept while it lasts, then 90 days); the audit trail, up to six years after the account closes, with a customer's details removed when that customer is erased; feedback and problem reports, while the account is open and up to six years after it closes; two-step sign-in details, until they are switched off or the login is removed; click records for partner offers, 24 months (a customer's offers choices are not kept by us at all: they stay on the customer's own device).
11. Marketing and communications
We'll send you service messages needed to run your account. If you ask for a demo or sign up, we may contact you about Cerrax; you can opt out of marketing at any time via the unsubscribe link or by emailing us. We follow the ePrivacy Regulations (S.I. 336/2011) for any electronic marketing.
12. Your rights
Under the GDPR and the Data Protection Act 2018 you can request access, correction, erasure, restriction and portability, and object to processing based on our legitimate interests. You can object to direct marketing at any time, and we will stop. Where we rely on your consent, you can withdraw it at any time without affecting what was done before. For a firm's customers' data (where we are processor), direct requests to the firm as controller; we help the firm answer them. To exercise a right, contact hello@cerrax.io. We answer within one month.
13. Children
Cerrax is a tool for businesses and is not directed at children. We don't knowingly collect data from children.
14. Complaints
If you're unhappy with how we handle your data, tell us at hello@cerrax.io — we will acknowledge your complaint within 30 days, look into it without undue delay, and tell you the outcome. You can also complain to the Data Protection Commission (dataprotection.ie), which is the supervisory authority in Ireland.
15. Security
We protect data with access controls, encryption in transit and at rest via our cloud provider, and audited administrative actions. No system is perfectly secure, but we take reasonable measures appropriate to the data.
If a personal data breach occurs, we act promptly: where we are the controller we notify the Data Protection Commission within 72 hours where required, and affected individuals where required; where we are a processor we notify the affected firm without undue delay, and within 48 hours, so it can meet its own obligations.
16. Changes
We may update this policy; we'll post the new version here with a revised effective date, and email account owners about any change that affects them.
17. Contact
Cerrax Ltd, 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. hello@cerrax.io.