Data protection policy (UK GDPR)
Last updated 28 September 2026
WindowCleaningPilot is a marketplace where window cleaning customers pass from one business to another: through Pilot bookings, member listings, job swaps, round sales and round builds. This policy sets out who is responsible for customers' personal information at each step, and the rules every member agrees to. It forms part of the member terms and sits alongside our Privacy policy.
1.Who is responsible for what
| Situation | Before the transfer | After the transfer |
|---|---|---|
| Pilot booking (booked with WindowCleaningPilot) | WindowCleaningPilot is the controller | The buying member is an independent controller for their own customer relationship |
| Member listing (a cleaner sells one of their customers) | The seller is the controller; WindowCleaningPilot hosts the listing | The buyer is an independent controller; the seller must stop using the details, except where the law requires them to keep records |
| Job Exchange (two members swap customers) | Each member is controller of their own customer | Each becomes controller of the customer they receive |
| Round sale or finished round build (CSV) | The seller or canvasser is the controller | The buyer is an independent controller once the escrow payment is made and the list is released |
| Canvassing request (customers delivered one by one) | The canvasser is the controller of the details they collect | The requesting cleaner is an independent controller once they have paid for that customer |
WindowCleaningPilot is a controller for running the marketplace itself: hosting listings, keeping transfer records, taking payments, preventing fraud and handling disputes. Transfers between members are controller-to-controller transfers. Members don't act as our processors, and we don't act as theirs.
2.What every member must do
- Use customers' details only to provide window cleaning and closely related services the customer wants (such as gutters, fascias, conservatories or solar panels), and to run your business with them.
- Keep the details secure: a password-protected phone or computer, no sharing of log-ins, and no leaving printed customer lists in vans.
- Don't sell, pass on or advertise to customers you received through the marketplace, except by listing or swapping them through WindowCleaningPilot under these rules.
- Respect customers' wishes: if a customer says they don't want to be contacted or wants their details deleted, stop, and tell us if the request concerns a job you bought or sold through us.
- Tell us within 24 hours at privacy@windowcleaningpilot.co.uk if customer details from the marketplace are lost, stolen or seen by someone who shouldn't have them, so the right people can be told in time.
- Register with the ICO and pay the data protection fee if the law requires it for your business. Most window cleaning businesses that keep customer records electronically do need to.
3.Sellers: before you list a customer
Every seller confirms three things before a listing goes live. Our records show when you confirmed them.
- The customer has been told, or will be told before the first clean by the new cleaner, that their details are being passed to another window cleaner, and they are happy with that. Telling the customer is not optional.
- You have a lawful reason to share the details. Usually this is the legitimate interest of passing on a customer who wants their cleaning to continue, and the customer's reasonable expectation that it will; or their consent. Don't list a customer who has told you they don't want to be passed on.
- The details are accurate and up to date, and the customer isn't listed or sold anywhere else.
Only include what the new cleaner needs: name, address, phone or email, price, frequency, and access or property notes. Don't include bank details, key codes or health information in public notes. Put sensitive practical details (a gate code, where a key is kept) only in the private notes, which only the buyer sees.
4.Buyers: after you take a customer on
- Contact the customer before the first clean, and in any case within 14 days of buying, to introduce yourself: your business name, how to reach you, and that you have taken over their cleaning from the previous cleaner or through WindowCleaningPilot. This is how the customer is told who now holds their details, which the law requires within one month at the latest.
- Give them a simple way to say no. If they don't want to continue, stop contacting them and delete their details, keeping only what you need for your records.
- Don't contact customers for anything unrelated to their window cleaning without their separate agreement.
- If the details turn out to be wrong or the customer says they never agreed, tell us through the dispute process in our Refunds policy.
5.Canvassers: building a round
- Tell every person you sign up, in plain words, that their details will be passed to a local window cleaner who will take over their cleaning, and who that is likely to be if you know. What you tell customers must match the "what customers are being told" section of your round build.
- Record for each customer when and how they agreed (for example the date and a note such as "signed at door, happy to be contacted by new cleaner"). You may be asked for this if a buyer or customer raises a question.
- Don't sign up anyone who is vulnerable or who can't understand what they are agreeing to. Respect "no cold callers" notices.
- Upload only customers who agreed. The customer list (CSV) is stored privately. It's released to the buyer only once their payment is held in escrow, and it is removed from our storage 90 days after the sale completes.
- After the sale, stop using the list, except for what you must keep for your own accounts.
6.Canvassing requests
When a member asks for an area to be canvassed, other members see the postcode districts, the amount of work wanted and the cleaner's preferences. They never see any customer's details. Cleaners and canvassers are shown to each other only by an anonymous rating, and all their messages stay on the platform. Messages containing phone numbers, emails or links are blocked.
- The chosen canvasser must tell each customer, before adding them, that their details will go to a local window cleaner who will take over their cleaning, and record when and how they agreed. Each customer is added with that record.
- A customer's name, address and contact details are released to the cleaner only once the cleaner has paid for that customer. The canvasser can always see the customers they added.
- The cleaner must contact each new customer within 14 days to introduce themselves, as in section 4.
7.How WindowCleaningPilot protects the information
- Addresses and contact details are stored separately from public job information and are released only to the buyer. The seller keeps sight of their own listing.
- Members appear on the map only as an anonymous dot by postcode district, never by name or address, and can turn this off.
- Customer lists are held in private storage that only the canvasser and the buyer can reach.
- We keep a record of every transfer: who listed, who bought, when, and the seller's confirmations. This is so customers' questions and complaints can be answered.
- Our database is hosted in London. See the Privacy policy for other providers and transfers.
8.Customers' rights and complaints
Any customer can ask WindowCleaningPilot which member holds their details, ask for them to stop being used, or complain. We will pass the request to the member concerned, who must deal with it within one month and confirm to us that they have. Members who don't follow this policy may have listings removed, balances held while a problem is resolved, or their account closed.
Questions about this policy: privacy@windowcleaningpilot.co.uk.