Privacy Policy

Last updated: 4 July 2026

This Privacy Policy explains how Pinehurst Investment Group Limited (trading as "Groundwork"; "we", "us") collects, uses, shares and protects your personal data when you use the Groundwork service at groundwork.pinehurstproperty.co.uk (the "Service"). We are the data controller for the personal data described here.

• Company: Pinehurst Investment Group Limited (company no. 16073869), a private limited company registered in England & Wales
• Registered address: 41 Boulevard View, Whitchurch Lane, Bristol, England, BS14 0TL
• ICO registration: ZB954939 (Pinehurst Investment Group Limited)
• Contact for privacy questions: support@pinehurstproperty.co.uk

We handle your data in line with the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).

1. Who this applies to

Groundwork is a business tool for owners and managers of small firms (mainly UK construction and trades businesses). The Service is intended for business users aged 18 or over. It is not intended for children, and we do not knowingly collect their data.

2. The personal data we collect

You give us:

• Account data — your email address (used for magic-link sign-in), and any name or business name you provide.
• Your answers — everything you tell the assistant as you work through the stages: your business, sector, size, the problem you're facing, its root cause, rough figures you share (time lost, money at stake, budgets), your goals, who does what in your business, and any other details you type or dictate. These answers are the core of what we hold, and some may identify you or name colleagues.
• The documents we generate for you from those answers.
• Communications — messages you send us by email or support.

We collect automatically:

• Usage and device data — pages viewed, actions taken, approximate location (from IP), browser and device type, and similar technical logs, used to run and secure the Service.
• Cookies and similar technologies — see our Cookie Policy.

We receive from others:

• Payment data — if you buy the full journey (a one-off payment, not a subscription), our payment processor (Stripe) handles your card details and shares limited data with us (that a payment succeeded, the amount, the last four digits, billing country). We never see or store your full card number.

3. How we use your data, and our lawful bases

Where we rely on legitimate interests, we've weighed our interest in running and growing the Service against your rights, and we don't use your data in ways you wouldn't reasonably expect. You can object at any time (see §9).

4. AI processing of your answers

To scope your problem and produce your documents, your answers are sent to and processed by AI models. Depending on configuration, this includes:

• Anthropic (Claude models) and/or OpenAI (GPT models) — cloud AI providers based in the United States; and/or
• AI models we run on our own hardware in the UK/EU (no third party involved).

Our cloud AI providers process your answers only to generate the response for you. Under our agreements with them, your inputs and outputs are not used to train their models. Please avoid typing unnecessary sensitive personal data or third parties' details into the assistant.

5. Who we share your data with (sub-processors)

We share data only with service providers who help us run Groundwork, under contracts that require them to protect it. Current key providers:

We keep an up-to-date sub-processor list and will update this policy when it changes. We do not sell your personal data, and we take no commission or affiliate fee from any software we recommend to you.

6. International transfers

Some providers above are in the United States or process data globally. Where your data is transferred outside the UK, we rely on appropriate safeguards — the UK International Data Transfer Agreement / Addendum to the EU Standard Contractual Clauses, or a provider's certification under an approved framework — so your data keeps an equivalent level of protection.

7. Building a profile of your business, and lead generation

We want to be upfront about this. As you use Groundwork, we build an internal profile of your business from your answers — for example your sector, size, the problems you have, your rough budget and goals, and how far you got. We use this to:

• run and improve the Service and understand who our users are; and
• where appropriate, identify services (our own or related Pinehurst offerings) that may genuinely help you, and — only if you have agreed to marketing, or where the PECR soft opt-in applies — contact you about them.

The "ask Pinehurst for help" button. If you ask for Pinehurst's help inside Groundwork (the in-app option to have a person take it from here), your email, business name, project stage and message are shared with Pinehurst Property Ltd's consultancy team, who may contact you about that request. This is a one-off, deliberate action you take — not part of the automatic profiling described above.

You are in control:

• We will ask for your consent to marketing and make it easy to say no.
• Every marketing message includes a one-click unsubscribe.
• You can object to profiling for marketing at any time by emailing support@pinehurstproperty.co.uk; we'll stop and, if you ask, delete the profile.
• We do not make solely automated decisions that produce legal or similarly significant effects about you.

8. How long we keep it

• Account and answers/documents: for as long as you have an account, so your project and documents are still there when you come back to them. Nothing is deleted automatically on a timer. If you want them removed, email us and we will delete them.
• Business profile (for lead generation): until you object or unsubscribe, or until you ask us to delete it — whichever comes first.
• Payment/billing records: retained for 6 years from the end of the financial year they relate to, to meet UK tax and accounting law — longer where HMRC has opened a compliance check or the records cover a transaction spanning more than one accounting period.
• Backups and logs: on a rolling short-term schedule, then deleted.

9. Your rights

Under UK data protection law you have the right to: access your data; have it corrected; have it deleted; restrict or object to processing (including profiling and marketing); data portability; and to withdraw consent at any time. To exercise any of these, email support@pinehurstproperty.co.uk. We'll respond within one month. Exercising your rights is free, and we won't treat you differently for it.

10. Cookies

We use a small number of cookies. Please see our Cookie Policy.

11. Security

We protect your data with encryption in transit, access controls, a ba database schema that is server-only (not publicly exposed), and reputable infrastructure providers. No system is perfectly secure, but we take our responsibilities seriously and will notify you and the ICO of a qualifying breach as the law requires.

12. Changes to this policy

We may update this policy as the Service evolves. We'll change the "last updated" date and, for material changes, tell you by email or in-app.

13. Complaints

If you're unhappy with how we've handled your data, please tell us first at support@pinehurstproperty.co.uk so we can put it right. You also have the right to complain to the Information Commissioner's Office (ICO) — ico.org.uk, 0303 123 1113.