Effective date: 28 July 2026
Last updated: 28 July 2026
1. ABOUT THIS PRIVACY POLICY
This Privacy Policy explains how Bullion Apps Ltd (“Bullion Apps”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal information when RAMS Assessor™, its related mobile and tablet applications, and its secure online services are used.
RAMS Assessor™ is intended for professional and business use. It assists a competent human reviewer by analysing uploaded risk assessments, method statements and equivalent workplace-safety documents, preparing an AI-assisted draft review, identifying possible omissions or inconsistencies and helping complete a review form.
RAMS Assessor™ does not make the final professional, contractual, legal or safety decision. The competent human reviewer must check the original documents, review and correct the AI-generated draft, resolve any missing or contradictory information, personally select the final outcome and sign and authorise the completed review.
2. WHO WE ARE
RAMS Assessor™ is provided by:
Bullion Apps Ltd
United Kingdom
Email:
Website:
For personal information processed to operate RAMS Assessor™, provide support, manage purchases, maintain credits, protect the service or meet Bullion Apps Ltd’s own legal obligations, Bullion Apps Ltd is generally the data controller.
Where an employer, client, contractor, principal contractor or another organisation uses RAMS Assessor™ to upload and review documents containing information about its workforce, contractors, suppliers, clients or other individuals, that organisation may be the data controller.
In those circumstances, Bullion Apps Ltd may act as a service provider or data processor when handling the information solely to provide the requested service.
Bullion Apps Ltd has submitted its data-protection fee registration to the United Kingdom Information Commissioner’s Office. The formal registration reference will be added to this Privacy Policy after it has been issued and confirmed. An application number will not be published as though it were the final registration reference.
3. INFORMATION PROCESSED BY RAMS ASSESSOR™
Depending on how RAMS Assessor™ is used, the following categories of information may be processed.
3.1 COMPANY AND REVIEWER INFORMATION
This may include:
• company name and trading name;
• company registration details;
• business address;
• telephone number;
• email address;
• website;
• company logo;
• reviewer or assessor name;
• reviewer job title or professional role;
• saved reviewer signature;
• selected country or region;
• selected local workplace-safety terminology;
• preferred application theme;
• PDF branding colours;
• document-export settings; and
• other company-branding preferences.
A saved signature is used only to place the reviewer’s chosen signature on documents that the reviewer has personally authorised.
Bullion Apps Ltd does not use the saved signature to create a biometric profile or identify the reviewer through automated biometric matching.
3.2 PROJECT AND DOCUMENT INFORMATION
This may include:
• project reference;
• project title;
• site or location information;
• client information;
• contractor and subcontractor information;
• activity, task or scope of work;
• document title;
• document reference;
• issue date;
• revision number;
• uploaded RAMS, JSA, JHA, SWMS or equivalent documents;
• uploaded review forms;
• supporting files, photographs or attachments;
• filenames, file types and file sizes;
• document metadata;
• information contained within uploaded documents;
• names, roles and contact details contained within documents;
• qualifications, competence and training information;
• signatures contained within submitted documents;
• risk, hazard, method and control information;
• review answers;
• page and section references;
• observations;
• missing or unclear information;
• corrective actions;
• priorities and target dates;
• AI-generated draft findings;
• AI-generated suggested outcomes;
• human edits and corrections;
• final outcomes;
• declarations and authorisations;
• project-register entries; and
• generated or exported documents.
3.3 INFORMATION SENT FOR AI-ASSISTED REVIEW
When a user deliberately starts an AI-assisted review, RAMS Assessor™ may send the following through a secure Bullion Apps Ltd backend:
• the source workplace-safety documents selected by the user;
• relevant supporting documents or images;
• the selected review form or template;
• the mandatory project reference;
• the mandatory project title;
• extracted document text;
• document images where required for analysis;
• page and section information;
• filenames and relevant file metadata;
• instructions required to perform the requested review; and
• generated draft answers, comments, observations, corrective actions, uncertainties and suggested outcomes.
Uploaded documents may contain names, signatures, job titles, contact details, qualifications, competence information, training records, project details, site details, commercially confidential information, health or safety information or other personal information.
Users must only upload information that they are authorised to access and process and that is reasonably necessary for the requested review.
3.4 PURCHASE AND CREDIT INFORMATION
RAMS Assessor™ may include an initial allocation of AI review credits and may allow users to purchase additional credits through in-app purchases.
Purchases are processed through the Apple App Store or Google Play.
Bullion Apps Ltd may receive or process limited purchase information such as:
• the relevant store platform;
• product identifier;
• transaction identifier;
• receipt or purchase token;
• purchase status;
• purchase date;
• entitlement status;
• restored-purchase status;
• refund, cancellation or reversal status;
• credit balance; and
• credit-use history.
Bullion Apps Ltd does not receive or store the user’s complete payment-card number or bank-account details.
Payment information is processed by Apple or Google under their own terms and privacy policies.
3.5 TECHNICAL, SECURITY AND SUPPORT INFORMATION
When an online service is used, Bullion Apps Ltd or its service providers may process limited technical information such as:
• Internet Protocol address;
• device type;
• device platform;
• operating-system version;
• application version;
• request date and time;
• response status;
• error and diagnostic information;
• service-failure information;
• credit-use information;
• rate-limit information;
• purchase-validation information;
• security information;
• fraud-prevention information;
• abuse-prevention information; and
• pseudonymous installation or entitlement identifiers where reasonably required to protect credits and prevent unauthorised use.
If a user contacts Bullion Apps Ltd, Bullion Apps Ltd may process the name, email address, message, attachments and related correspondence provided by that user.
4. HOW INFORMATION IS COLLECTED
Information may be collected:
• directly from the user when information is entered into RAMS Assessor™;
• from documents, photographs and images selected by the user;
• from reviewer details and signatures deliberately saved by the user;
• automatically from the device or secure backend when an online request is made;
• from Apple or Google when a purchase, refund, cancellation or restoration is validated; and
• from communications sent to Bullion Apps Ltd.
5. DEVICE PERMISSIONS
RAMS Assessor™ may request access to files, documents, photographs or the device camera only when the user chooses to use a feature that requires that access.
This may include:
• selecting a workplace-safety document;
• selecting a supporting attachment;
• selecting or capturing a company logo;
• importing an image;
• capturing relevant evidence;
• saving or selecting a signature; or
• saving or sharing an exported document.
RAMS Assessor™ does not use these permissions for advertising, unrelated tracking, behavioural profiling or the sale of personal information.
Permissions can normally be reviewed or withdrawn through the device settings. Withdrawing a permission may prevent the related feature from operating.
6. HOW BULLION APPS LTD USES INFORMATION
Bullion Apps Ltd may process information to:
• provide and operate RAMS Assessor™;
• store and organise project documents;
• create and maintain project registers;
• open, preview and display uploaded documents;
• process selected documents through the secure AI service;
• generate an AI-assisted draft review;
• identify missing, inconsistent, contradictory, weak or unclear content;
• compare user-entered project details with information in uploaded documents;
• extract relevant document and project metadata;
• populate review forms;
• prepare white-label review documents;
• generate company-branded PDF documents;
• allow the competent human reviewer to check and edit the draft;
• allow the reviewer to select the final outcome;
• allow the reviewer to sign and authorise the completed review;
• save, print, share and export completed records;
• apply saved company branding and reviewer details;
• manage included and purchased AI review credits;
• validate and restore purchases;
• respond to refunds, cancellations or purchase reversals;
• provide customer support;
• investigate errors and service failures;
• protect the service from fraud, automated abuse, security threats and unauthorised use;
• maintain service reliability;
• meet app-store requirements;
• comply with legal, tax, accounting and regulatory obligations; and
• establish, exercise or defend legal claims.
Bullion Apps Ltd does not sell personal information.
Bullion Apps Ltd does not use uploaded workplace-safety documents for advertising, cross-application tracking or behavioural advertising.
RAMS Assessor™ does not display third-party advertising.
7. LAWFUL BASES
Where the United Kingdom General Data Protection Regulation, European Union General Data Protection Regulation or similar privacy laws apply, Bullion Apps Ltd may rely on one or more of the following lawful bases.
7.1 PERFORMANCE OF A CONTRACT
Processing may be necessary to provide RAMS Assessor™, AI-assisted reviews, credit purchases, generated documents, project registers or support requested by the user.
7.2 LEGITIMATE INTERESTS
Processing may be necessary for Bullion Apps Ltd’s legitimate interests in:
• operating and maintaining RAMS Assessor™;
• providing a secure and reliable service;
• preventing fraud and unauthorised use;
• protecting AI review credits;
• investigating faults;
• providing support;
• improving service reliability;
• protecting Bullion Apps Ltd, its users and its service providers; and
• establishing, exercising or defending legal claims.
Bullion Apps Ltd will consider whether those interests are overridden by the rights and interests of affected individuals.
7.3 LEGAL OBLIGATION
Processing or retention may be necessary to comply with applicable legal, tax, accounting, regulatory, court or law-enforcement requirements.
7.4 CONSENT
Consent may be relied upon where it is required for an optional permission, communication or processing activity.
Consent may be withdrawn at any time, although withdrawal does not affect processing that was already completed lawfully.
7.5 INFORMATION ABOUT OTHER INDIVIDUALS
Organisations and professional users who upload information about employees, contractors, subcontractors, clients, suppliers or other individuals remain responsible for ensuring that they have:
• an appropriate lawful basis;
• authority to use the information;
• provided any required privacy information;
• complied with their contractual and confidentiality obligations; and
• identified any necessary legal condition for processing sensitive or special-category information.
8. AI PROCESSING AND HUMAN REVIEW
When a user deliberately starts an AI-assisted review, the selected workplace-safety documents, relevant supporting files, mandatory project reference, project title, selected review form, document metadata and processing instructions are transmitted securely from RAMS Assessor™ to a Bullion Apps Ltd backend.
The Bullion Apps Ltd backend then sends the information required for the requested review to an artificial-intelligence service provider, currently the OpenAI API.
The AI service may:
• analyse document text and images;
• extract project, contractor and activity information;
• extract document references, revisions and issue dates;
• identify missing, inconsistent, contradictory or unclear content;
• compare the uploaded documents with the project reference and project title entered by the user;
• suggest Yes, No, In Part or N/A responses;
• provide page or section references where available;
• draft comments;
• draft observations;
• draft corrective actions; and
• suggest an overall review outcome.
AI output is a draft only.
AI output must not be treated as:
• professional approval;
• legal advice;
• independent safety approval;
• confirmation that a document is legally compliant;
• confirmation that submitted controls are suitable or sufficient; or
• an autonomous decision to accept or reject a workplace-safety document.
RAMS Assessor™ requires a competent human reviewer to:
• examine the original submitted documents;
• verify the AI-generated findings and references;
• correct or complete the draft where necessary;
• resolve missing, inconsistent, conflicting or uncertain information;
• check whether the information is appropriate for the particular project, task, site and workforce;
• personally select the final review outcome; and
• sign and authorise the completed review.
RAMS Assessor™ does not independently accept, reject, sign or authorise RAMS, JSA, JHA, SWMS or equivalent documents.
RAMS Assessor™ is not intended to make solely automated decisions that produce legal or similarly significant effects without meaningful human involvement.
Bullion Apps Ltd has disabled the voluntary sharing of OpenAI API inputs and outputs for model improvement.
OpenAI states that API inputs and outputs are not used to train or improve its models by default unless the API customer expressly opts in.
OpenAI may nevertheless process API content and related metadata to provide the service, enforce its usage policies, investigate misuse, maintain security and comply with legal obligations.
Under OpenAI’s standard API configuration, abuse-monitoring logs may contain prompts, uploaded content, generated responses and related metadata and may be retained for up to 30 days.
Information may be retained for longer where required by law or where reasonably necessary to protect OpenAI’s services or third parties from harm.
Bullion Apps Ltd will configure the production integration to avoid optional persistent OpenAI API storage where supported.
This includes using non-persistent request settings for the OpenAI Responses API.
Avoiding optional persistent API storage does not override OpenAI’s separate abuse-monitoring retention unless Bullion Apps Ltd is approved for an enhanced arrangement such as Zero Data Retention or Modified Abuse Monitoring.
9. USER RESPONSIBILITY FOR UPLOADED INFORMATION
Users must only upload documents that they are authorised to access and process.
The user or the user’s organisation is responsible for:
• having an appropriate lawful basis or permission to upload and process personal information;
• providing any necessary privacy information to employees, contractors, subcontractors or other affected individuals;
• complying with confidentiality obligations;
• complying with client and contractual requirements;
• checking whether the service is suitable for the security classification of the documents;
• avoiding unnecessary personal information;
• avoiding unnecessary medical or special-category information;
• checking that uploaded information is accurate and relevant;
• ensuring that use of RAMS Assessor™ complies with applicable workplace, sector, regulatory and professional requirements; and
• reviewing the original document rather than relying solely on the AI-generated draft.
Users should redact information that is not required for the review wherever reasonably possible.
Highly sensitive, classified, export-controlled, security-sensitive or legally privileged information should not be uploaded unless the user’s organisation has confirmed that the service, security controls and contractual arrangements are suitable.
10. LOCAL STORAGE AND OFFLINE INFORMATION
Project information, imported source documents, reviewer details, saved signatures, company branding, draft and completed reviews, project registers, settings and exported documents may be stored locally on the user’s device.
Local information normally remains on the device until the user:
• deletes the relevant record;
• clears the application’s stored data;
• uses an available deletion function;
• resets RAMS Assessor™; or
• uninstalls RAMS Assessor™.
Copies may remain in:
• device backups;
• downloaded folders;
• shared locations;
• printed documents;
• email accounts;
• cloud-storage services;
• messaging services; or
• third-party applications selected by the user.
Bullion Apps Ltd cannot delete copies that have been printed, exported, shared, backed up or saved outside RAMS Assessor™.
Users are responsible for protecting locally stored and exported workplace-safety documents from unauthorised access.
11. DATA RETENTION AND DELETION
11.1 INFORMATION STORED ON THE USER’S DEVICE
Information stored locally by RAMS Assessor™ remains on the device until it is deleted by the user, removed by clearing app data, removed through an available reset function or removed when RAMS Assessor™ is uninstalled, subject to the device operating system and backup arrangements.
Files exported or shared outside RAMS Assessor™ must be deleted separately from the locations or services where they were saved or shared.
11.2 BULLION APPS LTD BACKEND FILES
Bullion Apps Ltd will configure the production AI service so that uploaded source documents, extracted document content and temporary processing files held on the Bullion Apps Ltd backend are deleted within 24 hours after the AI-processing request has been successfully completed or has permanently failed.
A longer retention period may apply only where:
• it is reasonably necessary to diagnose a processing failure;
• it is reasonably necessary to retry an interrupted request;
• it is reasonably necessary to investigate a security incident;
• the user has specifically requested secure support assistance;
• retention is necessary to prevent fraud, abuse or unauthorised access;
• retention is necessary to establish, exercise or defend legal claims; or
• retention is required by law.
Where an exception applies, the information will be retained only for as long as reasonably necessary for that purpose and access will be restricted.
The 24-hour deletion period applies to files held temporarily on the Bullion Apps Ltd backend.
It does not apply to:
• copies stored locally on the user’s device;
• copies exported, printed or shared by the user;
• information stored in device backups;
• information stored by Apple, Google or another service selected by the user; or
• information retained separately by an AI service provider under its own security and abuse-monitoring arrangements.
11.3 OPENAI API RETENTION
Information transmitted to the OpenAI API is subject to OpenAI’s separate data-handling and retention controls.
Under OpenAI’s standard API configuration, API inputs, outputs and related metadata may be included in abuse-monitoring logs and retained for up to 30 days.
OpenAI may retain information for longer where required by law or where reasonably necessary to protect its services or third parties from harm.
Bullion Apps Ltd has not opted in to sharing RAMS Assessor™ API inputs and outputs with OpenAI for model training or improvement.
Bullion Apps Ltd will configure OpenAI Responses API requests to avoid optional persistent application-state storage where supported.
Bullion Apps Ltd may in the future apply for enhanced OpenAI retention controls, including Zero Data Retention or Modified Abuse Monitoring.
This Privacy Policy will be updated if such controls are approved and activated.
11.4 OPERATIONAL AND SECURITY RECORDS
Limited security, rate-limit, entitlement, purchase-validation and operational records may be retained for up to 30 days, or longer where reasonably necessary for:
• fraud and abuse prevention;
• service security;
• diagnosing technical failures;
• resolving disputes or support requests;
• legal and regulatory compliance; or
• establishing, exercising or defending legal claims.
11.5 PURCHASE AND ACCOUNTING RECORDS
Purchase, transaction, tax and accounting records may be retained for the period required by applicable law.
11.6 SUPPORT CORRESPONDENCE
Support correspondence may be retained for as long as reasonably necessary to:
• resolve the request;
• document the support provided;
• maintain appropriate business records;
• protect legal rights; or
• comply with legal obligations.
12. SHARING OF INFORMATION AND SERVICE PROVIDERS
Bullion Apps Ltd does not sell personal information.
Information may be shared or made available only where reasonably necessary to the following categories of recipient:
• OpenAI, as the current AI service provider, to analyse selected documents and generate the requested AI-assisted draft review;
• secure hosting, infrastructure, database, storage, security and monitoring providers used to operate the Bullion Apps Ltd backend;
• Apple and Google for app distribution, in-app purchase processing, receipt validation, restored purchases, refunds and fraud prevention;
• professional advisers;
• insurers;
• auditors;
• accountants;
• regulators;
• courts;
• law-enforcement bodies;
• other authorities where disclosure is legally required; and
• a genuine purchaser, successor or professional adviser in connection with a merger, restructuring, financing or sale of all or part of Bullion Apps Ltd.
OpenAI may process uploaded content, prompts, generated outputs and related metadata under its API data-handling, security and abuse-monitoring arrangements.
OpenAI states that API information is not used to train its models by default unless the API customer expressly opts in.
Service providers are permitted to process information only for the relevant authorised purpose and are expected to apply appropriate confidentiality and security protections.
13. INTERNATIONAL DATA TRANSFERS
Bullion Apps Ltd is based in the United Kingdom.
Bullion Apps Ltd and its service providers may process information in:
• the United Kingdom;
• the European Economic Area;
• the United States; or
• other countries in which an approved service provider operates.
Where applicable law requires safeguards for an international transfer, Bullion Apps Ltd will use an available lawful transfer mechanism, which may include:
• an applicable adequacy regulation or decision;
• approved standard contractual clauses;
• the United Kingdom International Data Transfer Agreement;
• the United Kingdom International Data Transfer Addendum; or
• another lawful transfer mechanism.
Users may contact Bullion Apps Ltd for further information about relevant transfer safeguards.
14. SECURITY
Bullion Apps Ltd uses reasonable technical and organisational measures designed to protect information.
These measures may include:
• encrypted HTTPS transmission for online requests;
• keeping OpenAI API credentials on the secure Bullion Apps Ltd backend rather than inside RAMS Assessor™;
• restricted backend access;
• access controls;
• secure secret and credential storage;
• project spending limits;
• usage quotas;
• rate limits;
• file-size limits;
• purchase and entitlement validation;
• abuse-prevention controls;
• temporary-file deletion procedures;
• secure software-development practices;
• software updates; and
• security and service monitoring.
No method of electronic transmission or storage can be guaranteed to be completely secure.
Users are responsible for:
• securing their devices;
• using an appropriate passcode or device lock;
• installing operating-system and security updates;
• restricting access to their device;
• protecting exported files;
• protecting backups; and
• using appropriate security when sharing workplace-safety documents.
15. PRIVACY RIGHTS
Depending on the user’s location and applicable law, the user may have rights to:
• be informed about processing;
• request access to personal information;
• request correction of inaccurate or incomplete information;
• request deletion of personal information;
• request restriction of processing;
• object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing is based on consent;
• complain to a privacy or data-protection authority;
• request information about categories of personal information collected, used or disclosed; and
• opt out of the sale or sharing of personal information where such rights apply.
Bullion Apps Ltd does not sell personal information.
Bullion Apps Ltd does not share personal information for cross-context behavioural advertising.
Requests may be sent to:
Bullion Apps Ltd may need to verify the requester’s identity and may request enough information to identify the relevant records.
Some information may be held only on the user’s device. Bullion Apps Ltd may therefore be unable to access, correct, export or delete that local information. The user may need to use the controls in RAMS Assessor™ or the device settings.
United Kingdom users may complain to the Information Commissioner’s Office.
Users in the European Economic Area may complain to the supervisory authority in the country where they live, work or believe a data-protection infringement occurred.
Users in other countries may contact their applicable local privacy or data-protection authority.
California residents may have rights to know, correct or delete personal information and to opt out of certain sales or sharing.
Bullion Apps Ltd does not sell personal information and does not share personal information for cross-context behavioural advertising.
16. DELETING LOCAL AND ONLINE INFORMATION
Users can delete locally stored records using the available deletion controls in RAMS Assessor™.
Uninstalling RAMS Assessor™ generally removes locally stored application data from the device, subject to operating-system backups and copies that were previously exported, shared, printed or saved elsewhere.
For requests concerning information held by the Bullion Apps Ltd backend, contact:
Do not send confidential RAMS, JSA, JHA, SWMS or equivalent documents by ordinary email unless Bullion Apps Ltd has specifically requested them through an approved secure method.
If RAMS Assessor™ later introduces user accounts, Bullion Apps Ltd will provide the account-deletion options required by applicable law and app-store policy.
17. BUSINESS, EMPLOYER AND CLIENT USE
If an employer, client, contractor or another organisation provides RAMS Assessor™ or instructs an individual to use RAMS Assessor™, that organisation may control some or all of the information entered or uploaded.
That organisation’s:
• privacy notice;
• document-retention requirements;
• information-security procedures;
• contractual terms;
• client requirements; and
• lawful instructions
may also apply.
Requests concerning information controlled by that organisation should normally be directed to the organisation first.
18. CHILDREN
RAMS Assessor™ is a professional workplace application and is not directed to children.
RAMS Assessor™ should only be used by people who are legally permitted and professionally authorised to handle and review workplace-safety documents.
Users must be at least 18 years old or the minimum legal age required to use the service in their country.
19. NO ADVERTISING, SALE OR BEHAVIOURAL TRACKING
RAMS Assessor™ does not display third-party advertising.
Bullion Apps Ltd does not sell personal information.
RAMS Assessor™ does not use personal information for targeted advertising, cross-application tracking or cross-context behavioural advertising.
20. THIRD-PARTY SERVICES AND LINKS
RAMS Assessor™ may open system services or third-party applications for:
• printing;
• document sharing;
• file selection;
• image selection;
• camera access;
• email;
• website links;
• Apple services;
• Google services;
• cloud storage; or
• other services selected by the user.
Those third parties process information under their own privacy policies and terms.
Bullion Apps Ltd is not responsible for information that a user chooses to send, save or share through an external application or service.
21. CHANGES TO THIS PRIVACY POLICY
Bullion Apps Ltd may update this Privacy Policy when:
• RAMS Assessor™ changes;
• the AI provider changes;
• hosting arrangements change;
• the purchase or credit system changes;
• security arrangements change;
• legal requirements change; or
• data-handling practices change.
The latest version will be published on the Bullion Apps Ltd website and will show the date on which it was last updated.
Material changes may also be communicated within RAMS Assessor™ or through another appropriate notice.
Where a change materially affects how personal information is used, Bullion Apps Ltd will provide an appropriate notice before the new processing begins where required by law.
22. CONTACT BULLION APPS LTD
Questions, requests or complaints about this Privacy Policy or the handling of personal information should be sent to:
Bullion Apps Ltd
United Kingdom
Email:
Website:
Please include enough information to identify the relevant installation, purchase, transaction or support request.
Do not send confidential workplace-safety documents by ordinary email unless Bullion Apps Ltd has specifically requested them through an approved secure method.
END OF PRIVACY POLICY
© 2026 Bullion Apps Ltd. All rights reserved.
Bullion Apps Ltd is a company registered in England and Wales.
Registered Office: 67 Brynmore, Bretton, Peterborough, PE3 8JG.
Telephone: +44 (0)7727122029
Company Registration Number: 17324046
ICO registration reference: ZC209057