BTG programme CRM privacy notice

Scope and roles

BridgeBot is operated by Bridge The Gap Sales Ltd, company number 17123996, registered office: Marron Bank, Branthwaite, Workington, United Kingdom, CA14 4SZ.

BTG requires programme students to log activity and uses it for coaching and progress monitoring. BTG determines these purposes independently of simply hosting a subscriber’s CRM. The proposed framing is that BTG is a controller for those purposes; the relationship to the student’s own prospecting purposes must be assessed separately.

Joint controllership is not automatic. If BTG and another controller jointly determine purposes and means, an Article 26 arrangement and an accessible statement of its essence must be completed. If their purposes are independent, document separate controller responsibilities instead. No arrangement is represented as signed.

Information and visibility

Students record real contact names, handles, offers, necessary notes, activities and reminders. Approved coaches with MFA can read only explicitly assigned students who have active BTG CRM membership. Cohort membership alone is insufficient. Public-subscriber CRM is excluded from that access.

CRM activity is used alongside separate fictional practice metrics for coaching. CRM makes no AI-provider calls. Logging requirements, the purpose of monitoring and the consequences of not participating must be explained to students before enrolment; contract participation is not assumed to be freely given data-protection consent.

Prospects and lawful basis

BTG must approve a purpose-specific lawful basis and, if relying on legitimate interests, a balancing assessment for compulsory tracking and prospect data. Prospect notices, sources of information, objection handling and rights allocation remain launch gates. Prospects’ inability to see the app does not by itself excuse notification.

Students must not add special-category data, criminal-offence information or unnecessary private details. A prohibition and 2,000-character note limit do not eliminate accidental collection risk; the DPIA must specify detection, escalation and removal procedures.

Contact and retention

Privacy, rights requests and complaints: bridgethegaphq@gmail.com, or write to the registered office marked “Data protection”. A dedicated privacy inbox must be provisioned and tested before it is advertised. ICO fee registration/payment evidence remains outstanding; no registration number or exemption is asserted.

The common privacy notice states current retention limitations and proposed shorter periods. Revoking BTG membership removes coach CRM access and blocks writes unless another valid entitlement remains; owner reading and export continue.