Privacy Policy
1. Introduction and Who We Are
Webpush Digital Ltd, trading as Local Review Booster ("we", "our", "us"), is a company incorporated in Hong Kong SAR (CR No: 78908872), with its registered office at Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong S.A.R.
We provide a fully managed "Done-For-You" reputation management and review automation platform for UK businesses. Our services include automated review requests via SMS and Email, review monitoring, AI-assisted response management, and custom workflow integrations via Make.com.
Because we offer services to businesses in the United Kingdom and process personal data of UK residents, UK GDPR applies to our processing activities.
UK Data Operations & Representative (Article 27): While our global technology stack is managed via our Hong Kong headquarters, we maintain a dedicated UK Operational Base for service management, client strategy, and data compliance at: 3 Birdwell Road, Long Ashton, Bristol, BS41 9BA, United Kingdom. All UK-based data protection enquiries should be directed to this address or via email.
Contact us at: [email protected] | +44 7700 140289
2. Our Role: Data Controller and Data Processor
We operate in two distinct capacities depending on the context:
2.1 As a Data Controller
When we collect and use your data to provide, manage, and improve our services — including data from our website visitors and registered business clients — we act as a Data Controller.
2.2 As a Data Processor
When you use our platform to send review requests to your customers, we process their personal data (names, mobile numbers, email addresses) solely on your instructions. In this capacity, we act as a Data Processor and you (our client) are the Data Controller.
As your Data Processor we commit to:
- Process customer data only on your documented instructions.
- Implement appropriate technical and organisational security measures.
- Not engage sub-processors without prior notification.
- Assist you in fulfilling data subject rights requests.
- Delete or return all personal data upon termination of services.
3. What Personal Data We Collect
3.1 Data You Provide Directly (Business Clients)
- Full name, business name, and registered address.
- Email address and telephone number.
- Payment and billing information (processed via Stripe).
- CRM or Point-of-Sale (POS) integration credentials.
3.2 Data Collected for Review Management (End-Customer Data)
- Customer names, email addresses, and mobile numbers for request automation.
- Public review content, ratings, and timestamps from third-party platforms (e.g., Google, Facebook).
- Interaction logs (whether a review link was clicked or an SMS was delivered).
4. Legal Basis for Processing
Under UK GDPR we rely on the following legal bases: Contract performance, Legitimate interests (service improvement and business growth), and Legal obligation.
5. Workflow Automations
Our service utilizes Make.com to facilitate "Done-For-You" automations between your CRM and our review engine. Data passing through these workflows is encrypted in transit and used solely to trigger review requests based on your business activity (e.g., a job being marked as 'Complete').
6. Sub-Processors
| Sub-processor | Purpose | Location |
|---|---|---|
| Make.com | Workflow and API automation | EU/USA |
| Stripe | Payment processing | USA (PCI DSS) |
| Twilio / SMS Providers | SMS Review Request Delivery | USA / UK |
| Google (Workspace) | Client communication and reporting | USA/EU |
| AWS / Cloud Infrastructure | Data hosting and platform backend | USA / EU |
7. Data Retention & Security
We retain business client account data for the duration of the subscription plus 6 years for tax purposes. Customer data used for review requests is retained for as long as necessary to fulfill the service, typically 90 days following a completed request cycle, unless requested otherwise. All data is protected via encryption at rest and in transit.
8. Your Rights Under UK GDPR
UK residents have the right of access, rectification, erasure, and to object to processing. To exercise these rights, please contact [email protected]. We will respond within one calendar month. You also have the right to lodge a complaint with the ICO.
