Legal

Privacy Policy

Last updated: 10 July 2026 · Version 1.0

⚠️ Draft for legal review. This policy is a first-pass template. It must be reviewed by a qualified solicitor before publication — in particular the retention rules where DAC7 tax-reporting duties conflict with the right to erasure, and the handling of biometric identity-verification data.
Before you publish: insert the real Companies House number and ICO registration number where marked to be confirmed below. Do not publish this page with invented registration numbers — both are public registers, and stating an ICO registration you do not hold is an offence.

1. Who we are

Zero Hours is a UK hospitality staffing marketplace that connects workers with last-minute shifts posted by venues and employers ("the Platform"). This website (app.zerohours.live) and its marketing pages are operated by Zero Hours, a company registered in England & Wales under company number to be confirmed, with its registered office at 30 Churchill Place, London, E14 5RE.

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Zero Hours is the data controller for the personal data described in this policy. We are registered with the Information Commissioner's Office (ICO) under registration number to be confirmed.

Questions about this policy or your data can be sent to privacy@zerohours.live.

2. The personal data we collect

What we collect depends on how you use Zero Hours. We split it into two stages.

a) When you sign up on our marketing pages (available now)

Our "Find Work" and "Hire Staff" interest forms collect only what you enter:

  • Workers: your name, email address, phone number, preferred role, and town/postcode.
  • Employers: your name, work email, business name, location, the roles you typically need, and any message you add.

These submissions are processed by our form provider (Web3Forms) and delivered to our team inbox so we can contact you about early access. They are not used for any other purpose.

b) When you use the full Zero Hours platform (as it launches)

Once the app is live, we collect additional data needed to run a staffing marketplace and meet our legal duties:

CategoryExamples
Identity & accountName, date of birth, profile photo, login credentials
ContactEmail, phone, address/area
Right to work & ID verificationIdentity documents and verification results (processed via our ID provider), which may include biometric data — see section 4
Tax & reportingNational Insurance number and income earned through the Platform (required for DAC7 reporting to HMRC)
Employer verificationCompany registration details (checked against Companies House)
Shift & locationShifts applied for, accepted, worked; check-in/check-out location data (geofencing) to confirm attendance
PaymentPayout details and transaction history. Card details are handled directly by our payment processor (Stripe) and are not stored by us
Reliability & conductReliability score, ratings, cancellations, no-shows
CommunicationsMessages sent through the Platform, support enquiries
TechnicalDevice, IP address, and usage data (see our Cookie Policy)

3. How and why we use your data (lawful bases)

Under UK GDPR we must have a lawful basis for each use of your data:

What we doLawful basis
Respond to marketing sign-ups and contact you about early accessConsent (you submitted the form); legitimate interests in developing our service
Match workers to shifts, run bookings, process payments and payoutsPerformance of a contract
Verify identity, right to work, and report income under DAC7Legal obligation
Prevent fraud, abuse, and off-platform circumvention; maintain reliability scoresLegitimate interests in keeping the marketplace safe and fair
Send marketing about Zero HoursConsent (you can withdraw at any time)
Process biometric identity-verification dataExplicit consent / substantial public interest (see section 4)

4. Special-category and biometric data

To confirm identity and right to work, our identity-verification provider may process biometric data (for example, a facial scan matched to your ID document). Biometric data used to identify you is "special-category" data under UK GDPR and receives extra protection.

Where we rely on this, we do so on the basis of your explicit consent and/or a substantial-public-interest basis for confirming eligibility to work. You can decline, but we may then be unable to verify you and provide the Platform. We keep verification data only as long as needed and delete or anonymise it in line with section 7.

5. Who we share your data with

We do not sell your personal data. We share it only with parties who help us run the Platform or where the law requires it:

  • Web3Forms — delivery of marketing form submissions.
  • Stripe — payment processing and payouts.
  • Our identity-verification provider — right-to-work and ID checks.
  • HMRC — income reporting under the DAC7 digital-platform rules.
  • Companies House — employer/business verification.
  • Other workers and employers — the limited profile and shift information needed to arrange and complete a booking.
  • Hosting, analytics, and notification providers — to operate and improve the service.
  • Authorities, advisers, or acquirers — where required by law or in connection with a sale of the business.

6. International transfers

We aim to keep personal data in the UK or European Economic Area. Where a provider processes data outside the UK/EEA, we ensure an appropriate safeguard is in place (such as UK adequacy regulations or the International Data Transfer Agreement / Addendum) so your data stays protected.

7. How long we keep your data

We keep personal data only as long as necessary for the purpose it was collected, then delete or anonymise it.

Important — tax records vs. the right to erasure. The DAC7 rules require us to retain certain worker income and identity records for an extended period (currently up to around 10 years) for reporting to HMRC. Where you ask us to delete your data, we will honour that request except for records we are legally required to keep. In practice, closing your account means we anonymise or restrict your profile data while retaining the minimum transaction and tax records the law requires.
  • Marketing sign-ups: kept until you ask us to remove them or they are no longer needed to contact you.
  • Account & profile data: kept while your account is active and for a reasonable period afterwards.
  • Tax & transaction records (DAC7): retained for the legally required period.
  • Verification/biometric data: kept only as long as needed to complete and evidence the check.

8. Your rights

Under UK GDPR you have the right to: access your data; correct inaccurate data; request erasure; restrict or object to processing; data portability; and withdraw consent at any time. These rights are subject to legal limits — for example, we may need to retain certain records for tax reporting (section 7).

To exercise any right, contact privacy@zerohours.live. If you are unhappy with how we handle your data, you can complain to the ICO at ico.org.uk or 0303 123 1113.

9. How we protect your data

We use appropriate technical and organisational measures — including encryption in transit, access controls, and payment handling by PCI-compliant providers — to protect personal data against loss, misuse, or unauthorised access. No system is perfectly secure, but we work to keep your data safe.

10. Children

Zero Hours is not intended for anyone under the minimum working age and requires the right to work in the UK. We do not knowingly collect data from children. If you believe a child has provided us data, contact us and we will remove it.

11. Cookies

We use cookies and similar technologies as described in our Cookie Policy. Non-essential cookies are used only with your consent.

12. Changes and contact

We may update this policy from time to time. The "last updated" date at the top shows the current version, and material changes will be highlighted on the site.

Data controller: Zero Hours, 30 Churchill Place, London, E14 5RE. Privacy contact: privacy@zerohours.live.