Privacy Policy for TBT Mate™

Effective date: 5 August 2026
Last updated: 5 August 2026

TBT Mate™ is developed and published by Bullion Apps Ltd, a company registered in the United Kingdom.

This Privacy Policy explains how information is handled when you download, install or use TBT Mate™ on an Apple iPhone, Apple iPad or Android device.

This policy applies to:

• TBT Mate™ for iOS and iPadOS;
• TBT Mate™ for Android;
• the core toolbox-talk application;
• optional specialist toolbox-talk packs;
• company-branding features;
• organisation-theme activation features;
• PDF creation, export and sharing;
• Apple App Store and Google Play purchases; and
• support communications sent to Bullion Apps Ltd.

TBT Mate™ is principally an offline application. Toolbox-talk records and other operational information entered into the app are stored locally on the user’s device and are not uploaded to a Bullion Apps Ltd cloud database.

For personal information sent directly to Bullion Apps Ltd, such as a support email, Bullion Apps Ltd is the data controller.

Data controller: Bullion Apps Ltd
Country: United Kingdom
Email: contact@bullionapps.co.uk
Website: https://www.bullionapps.co.uk

The organisation, employer, contractor or individual using TBT Mate™ may separately be responsible for personal information entered into toolbox-talk records, such as attendee names and signatures.

Bullion Apps Ltd does not normally receive or access those locally stored records.

Depending on how the app is used, TBT Mate™ may store the following information locally on the user’s device:

• selected country or region;
• company or organisation name;
• company logo;
• authorised-signature image;
• project names and references;
• site names and information;
• team details;
• employee, worker, contractor or attendee names;
• attendance records;
• attendee signatures;
• toolbox-talk delivery dates and times;
• completed toolbox-talk records;
• scheduled toolbox talks;
• quiz answers or results;
• notes associated with toolbox talks;
• selected appearance settings;
• organisation-theme activation status;
• locally stored purchase entitlement information;
• unlocked specialist-pack information; and
• generated PDF documents.

Some of this information, particularly attendee names and signatures, may constitute personal data.

This information is entered voluntarily by the user and is used to provide the requested app functions.

The principal information created through TBT Mate™ is stored within the app’s local storage on the device.

Bullion Apps Ltd does not operate a user-account database for TBT Mate™ and does not routinely receive:

• toolbox-talk records;
• attendee names;
• attendee signatures;
• project or site information;
• company logos;
• authorised signatures;
• quiz results; or
• generated PDF documents.

The information remains on the device unless the user chooses to export, print, back up or share it.

Local app information may also be included in an Apple, Google or device backup, depending on the device’s settings, the operating system and the backup configuration selected by the user. Such backups are controlled by the user and the relevant platform provider.

TBT Mate™ allows users to record information relating to other individuals, including names and signatures.

The user, employer, contractor or organisation operating the app is responsible for:

• ensuring that it has an appropriate lawful basis for recording the information;
• informing attendees how their information will be used;
• restricting access to authorised personnel;
• keeping the information only for as long as required;
• protecting exported or printed records; and
• complying with applicable employment, privacy and data-protection requirements.

Bullion Apps Ltd does not determine why an organisation records attendee information and does not ordinarily have access to those records.

Users may add a company name, logo and authorised signature to TBT Mate™.

This information may be displayed within the app and incorporated into generated toolbox-talk records or PDF documents.

Company logos and signature images selected by the user are stored locally within the app. Bullion Apps Ltd does not routinely receive or access them.

Users should only upload logos and signatures that they are authorised to use.

TBT Mate™ may include approved organisation-specific appearance themes that can be activated using a code provided by Bullion Apps Ltd or an authorised organisation.

When a theme is activated, the app may locally store:

• the fact that the theme is active;
• the corresponding organisation name;
• the organisation logo;
• the selected colour and appearance settings; and
• other theme-related configuration information.

Theme activation does not create a user account and does not give the organisation remote access to the user’s toolbox-talk records.

Unless expressly stated otherwise within the app, organisation-theme activation information is processed locally and is not used for advertising or user tracking.

TBT Mate™ offers optional specialist toolbox-talk packs as non-consumable, one-time in-app purchases.

Purchases are processed through:

• Apple’s App Store and StoreKit services on Apple devices; or
• Google Play and Google Play Billing services on Android devices.

Bullion Apps Ltd does not receive or store the user’s full payment-card details.

Apple or Google may process information such as:

• the user’s store account;
• payment information;
• transaction identifiers;
• purchase history;
• billing country;
• tax information;
• fraud-prevention information; and
• device or account information required to complete the purchase.

Their processing is governed by their respective terms and privacy policies.

TBT Mate™ may receive and store locally the minimum purchase information needed to:

• confirm whether a specialist pack was purchased;
• unlock purchased content;
• maintain the entitlement on the device; and
• restore previous purchases.

This may include a product identifier, purchase status, entitlement status or store-generated transaction information.

Bullion Apps Ltd may receive sales, financial and transaction reports through Apple App Store Connect or Google Play Console for accounting, support, fraud prevention and legal-compliance purposes. These reports do not provide Bullion Apps Ltd with access to locally created toolbox-talk records.

The Restore Purchases feature asks Apple or Google to confirm eligible previous purchases associated with the user’s store account.

The app uses the result to restore access to purchased specialist packs.

Bullion Apps Ltd does not receive the user’s Apple ID password, Google password or full payment-card information during this process.

TBT Mate™ allows users to create PDF toolbox-talk and attendance records.

PDFs may contain:

• company information;
• project or site information;
• toolbox-talk content;
• attendee names;
• attendee signatures;
• dates;
• quiz results;
• notes; and
• authorised signatures.

PDFs are generated for the user’s own operational and record-keeping purposes.

When a user exports, prints, saves or shares a PDF, the document may be transferred to another application, device, printer, cloud-storage provider, email service, messaging service or recipient selected by the user.

Once information has been exported from TBT Mate™, its subsequent handling is controlled by the user and the selected recipient or third-party service. Bullion Apps Ltd is not responsible for information that a user voluntarily shares outside the app.

Users should verify recipients and protect documents containing personal or commercially sensitive information.

TBT Mate™ may use device functions needed to provide features requested by the user.

Depending on the device and operating-system version, this may include access to:

• files or storage for saving and opening documents;
• photographs or selected images for choosing a company logo;
• the system document picker;
• printing services; and
• the system sharing interface.

Where the operating system provides a permission request, the user can choose whether to grant it.

Selecting an image or document does not give Bullion Apps Ltd general remote access to the user’s photo library or files. The selected content is used for the feature requested by the user.

Permissions can normally be reviewed or changed through the device’s settings.

TBT Mate™ does not contain third-party advertising.

Bullion Apps Ltd does not use TBT Mate™ to:

• serve personalised advertisements;
• sell user information;
• rent user information;
• create advertising profiles;
• track users across unrelated apps or websites;
• use an advertising identifier for behavioural advertising; or
• conduct cross-app advertising attribution.

TBT Mate™ does not require Apple App Tracking Transparency permission because the app does not track users across third-party apps or websites for advertising purposes.

TBT Mate™ does not use behavioural analytics to monitor how individual users use toolbox-talk records. The app does not routinely upload user-created records to Bullion Apps Ltd for analytics. Apple, Google, the device manufacturer or the operating system may independently collect technical, diagnostic, performance or store-related information under their own settings and privacy policies.

Depending on the user’s device settings, Apple or Google may provide developers with limited aggregated or anonymised diagnostic information. Where Bullion Apps Ltd receives such information, it is used only to investigate technical faults, improve compatibility and maintain the app.

TBT Mate™ does not require users to create a Bullion Apps Ltd account.

The app does not request or store:

• a Bullion Apps Ltd username;
• a Bullion Apps Ltd password;
• social-media login credentials; or
• an online TBT Mate™ profile.

Apple or Google may require the user to be signed into their relevant store account to purchase or restore specialist packs. That store account is managed by Apple or Google, not Bullion Apps Ltd.

Because TBT Mate™ does not create a Bullion Apps Ltd account, there is no separate TBT Mate™ online account requiring deletion.

If a user contacts Bullion Apps Ltd for support, Bullion Apps Ltd may receive:

• the user’s name;
• email address;
• message;
• app version;
• device or operating-system details supplied by the user;
• screenshots;
• attached documents; and
• information relating to a purchase or technical problem.

This information is used to:

• respond to the enquiry;
• investigate technical issues;
• verify purchase-related problems where possible;
• provide customer support;
• prevent misuse or fraud; and
• maintain records of support provided.

Users should avoid sending toolbox-talk records, signatures or other sensitive information unless it is necessary for Bullion Apps Ltd to investigate the issue.

Where UK data-protection law applies, Bullion Apps Ltd may rely on the following lawful bases:

Where processing is necessary to provide support, assist with a purchase or deliver a service requested by the user.

Where processing is necessary for Bullion Apps Ltd’s legitimate interests in:

• operating and supporting TBT Mate™;
• investigating technical problems;
• protecting the app against fraud or misuse;
• maintaining business records;
• improving reliability; and
• responding to customer enquiries.

These interests are balanced against the rights and interests of affected individuals.

Where information must be retained or disclosed to comply with tax, accounting, court, regulatory or other legal requirements.

Where consent is the appropriate lawful basis, including where a user voluntarily grants an operating-system permission that is not required for basic use of the app.

Consent may be withdrawn through the relevant device setting or by contacting Bullion Apps Ltd, although withdrawal does not affect processing that occurred before consent was withdrawn.

Bullion Apps Ltd does not sell personal information.

Information may be shared only where reasonably necessary with:

• Apple, for App Store purchases and related services;
• Google, for Google Play purchases and related services;
• email, website-hosting or technical-service providers used to receive support enquiries;
• professional advisers such as accountants, legal advisers or insurers;
• law-enforcement agencies, courts, regulators or public authorities where legally required;
• a purchaser or successor if Bullion Apps Ltd undergoes a genuine business sale, restructuring or transfer; or
• a recipient expressly selected by the user when exporting or sharing a document.

Service providers are expected to process information only for the relevant service and subject to appropriate confidentiality and security obligations.

Locally stored TBT Mate™ records are not routinely transferred internationally by Bullion Apps Ltd.

Apple, Google, email providers, hosting providers or other services selected by the user may process information in countries outside the United Kingdom.

Where Bullion Apps Ltd is responsible for an international transfer of personal information, it will use an appropriate legal safeguard where required, such as:

• an adequacy regulation;
• approved contractual clauses;
• the UK International Data Transfer Agreement;
• the UK Addendum to approved contractual clauses; or
• another lawful transfer mechanism.

Apple, Google and independently selected third-party services operate under their own privacy policies and international-transfer arrangements.

Locally stored app information remains on the device until the user:

• deletes individual records;
• clears saved toolbox-talk records;
• uses the Reset App function;
• removes relevant branding or content;
• clears the app’s data through device settings; or
• uninstalls the app.

Some information may remain in an Apple, Google or other device backup until that backup is deleted or replaced.

Bullion Apps Ltd cannot remotely retrieve or delete information that exists only on the user’s device.

PDFs and other exported documents remain wherever the user saved or shared them. They must be deleted separately from the destination application, device, email account, cloud service or recipient system.

Support messages are retained only for as long as reasonably necessary to resolve the enquiry, maintain support records, defend legal claims and meet applicable legal obligations.

Routine support communications will normally be deleted or anonymised when they are no longer reasonably required.

Financial, tax and transaction records supplied through Apple or Google may be retained for the period required by applicable accounting, tax and legal obligations.

TBT Mate™ is designed to minimise unnecessary transmission of user-created information.

Measures used to protect information include:

• local app storage;
• operating-system application isolation;
• use of Apple and Google’s official in-app-purchase systems;
• no storage of full payment-card details by Bullion Apps Ltd;
• limiting access to support information;
• limiting information collection to what is reasonably necessary; and
• maintaining appropriate technical and organisational safeguards.

Users are also responsible for protecting their information by:

• using a device passcode or biometric lock;
• keeping the device operating system current;
• limiting access to the device;
• checking PDF recipients;
• protecting backups;
• deleting records when no longer needed; and
• reporting lost or compromised devices to their organisation.

No electronic-storage or transmission method can be guaranteed to be completely secure.

Users can manage locally stored information through the app and their device.

Available controls may include:

• deleting individual records;
• clearing saved toolbox-talk records;
• changing or removing company branding;
• removing or changing signatures;
• resetting the app;
• deleting exported PDFs from their saved location;
• clearing app storage through device settings; and
• uninstalling TBT Mate™.

Resetting or uninstalling the app may permanently delete local records that have not been backed up or exported.

Purchased specialist packs may be restorable through Apple or Google using Restore Purchases, subject to the store account and the applicable store rules.

For information held directly by Bullion Apps Ltd, users may submit a privacy request to:

contact@bullionapps.co.uk

Depending on applicable law and the circumstances, individuals may have rights including:

• the right to be informed about processing;
• the right to request access to personal information;
• the right to correct inaccurate information;
• the right to request deletion;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to withdraw consent where processing relies on consent; and
• the right not to be subject to certain solely automated decisions.

These rights apply to information actually held or controlled by Bullion Apps Ltd.

Bullion Apps Ltd cannot provide a remote copy of, correct or delete information that is stored only on the user’s device and has never been transmitted to Bullion Apps Ltd.

Privacy requests can be sent to:

contact@bullionapps.co.uk

Bullion Apps Ltd may need to request reasonable information to verify the identity of the person making a request.

Where Bullion Apps Ltd relies on legitimate interests, an individual may object to the processing of their personal information.

Bullion Apps Ltd will stop the relevant processing unless there are compelling legitimate grounds to continue or the information is required for the establishment, exercise or defence of legal claims.

Objections may be sent to:

contact@bullionapps.co.uk

Questions or complaints should first be sent to:

Bullion Apps Ltd
Email: contact@bullionapps.co.uk
Website: https://www.bullionapps.co.uk

Individuals in the United Kingdom also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection.

Bullion Apps Ltd does not use personal information obtained through TBT Mate™ to make decisions that produce legal or similarly significant effects through solely automated processing.

The app does not profile individual users for advertising, employment decisions, insurance decisions, credit decisions or similar purposes.

TBT Mate™ is a professional workplace-safety and construction-management tool.

It is not designed or marketed as a service for children.

Bullion Apps Ltd does not knowingly use TBT Mate™ to collect personal information directly from children for advertising or profiling.

Organisations using TBT Mate™ are responsible for ensuring that any information recorded about younger workers, apprentices or other individuals is handled lawfully and with appropriate safeguards.

TBT Mate™ may include links or integrations that open services operated by other organisations, including:

• Apple;
• Google;
• device printing services;
• email applications;
• file-storage applications;
• cloud-storage services;
• messaging applications;
• PDF-viewing applications;
• online bookstores; and
• the Bullion Apps Ltd website.

Bullion Apps Ltd does not control the privacy practices of independent third-party services. Users should review the privacy policy of any third-party application or website they choose to use.

TBT Mate™ may display links to optional companion books or external retailer pages in supported countries. Opening such a link transfers the user to an external website or application.