Legal
Version 0.2-draft · Effective 4 June 2026 · Operator: Andrei Trimbitas trading as Old Forge Technologies
This Privacy Policy explains how Andrei Trimbitas trading as Old Forge Technologies ("Felgate", "we", "us") handles personal data for which we are the controller: the data of practitioners who hold an account, their billing data, and visitors to our websites (felgate.co.uk, app.felgate.co.uk).
Controller: Andrei Trimbitas trading as Old Forge Technologies, The Old Forge, Newmarket Road, Kennett, CB8 7PP, United Kingdom. Privacy contact: legal@felgate.co.uk.
In our capacity as controller we do not seek to collect your clients' special-category health data for our own purposes; that data belongs to your tenant and is processed under the DPA.
| Purpose | Lawful basis (UK GDPR) |
|---|---|
| Create and run your account, provide the Service | Contract (Art 6(1)(b)) |
| Take payment, manage subscriptions, prevent fraud | Contract; Legal obligation; Legitimate interests |
| Secure the platform, prevent abuse, keep logs | Legitimate interests (Art 6(1)(f)) |
| Support and service communications | Contract; Legitimate interests |
| Sync an optional connected calendar you asked us to connect (§6) | Contract; Consent (you choose to connect, and can disconnect) |
| Product analytics and improvement | Legitimate interests |
| Marketing emails to practitioners (not clients) | Consent or soft opt-in; unsubscribe anytime |
| Comply with law, respond to lawful requests | Legal obligation |
We use only strictly-necessary cookies to run the Service: a session cookie to keep you logged in; a "remember me" cookie (up to 30 days) if you choose it; and a CSRF token to protect forms. These are exempt from consent under PECR because they are essential to a service you have requested. We do not use advertising or third-party tracking cookies, and we do not currently use analytics cookies. If we introduce non-essential cookies we will ask for your consent first through a cookie banner and update this policy.
| Recipient | Purpose | Location / safeguard |
|---|---|---|
| Stripe | Payment processing | Safeguarded under UK transfer mechanisms |
| IONOS | Domain / DNS for tenant subdomains | UK / EU |
| Email provider | Transactional & onboarding email | UK / EU preferred |
| Backup provider (if used) | Encrypted off-site backups | UK / EU preferred |
| Calendar sync - only if the practitioner connects a Google account (see §6) | Google LLC / Google Ireland Ltd, under its own safeguards | |
| Professional advisers, authorities | Legal, accounting, regulatory | As required by law |
Core hosting is self-managed by Andrei Trimbitas trading as Old Forge Technologies, which limits the number of third parties touching the data. We do not sell personal data. A current sub-processor list for client data is in the DPA.
Connecting a Google account is optional and entirely the practitioner's choice. Nothing in this section applies unless a practitioner connects one, and disconnecting stops all of it.
When a practitioner connects Google Calendar from their portal, they grant Felgate these Google OAuth scopes:
| Scope | What we do with it |
|---|---|
calendar.events | Create, update and delete the calendar events that correspond to appointments booked in Felgate, and read the events in the practitioner's chosen calendar so their Felgate agenda shows their whole day. |
calendar.readonly | List the calendars on the account so the practitioner can pick which one to sync, and query free/busy so a slot the practitioner is already committed to cannot be booked by a client. |
userinfo.email | Display which Google account is connected, so the practitioner can confirm they linked the right one. |
Only what an appointment needs: the client's first name only - never a surname, contact details, or any health information - plus the appointment's start and end time, the practice name, the meeting link if there is one, and any note the practitioner themselves added to the booking. A practitioner's calendar is often visible to a partner or on a shared screen, so the event is deliberately thin.
Free/busy intervals, and - if the practitioner enables the agenda option - the title and time of events in the chosen calendar, read on demand at the moment they are needed. Google calendar content is not stored in our database, not written to logs, and never shown to clients. What we do store is the OAuth refresh token, the connected account's email address, and the chosen calendar id. These live in that practitioner's own tenant database, encrypted at rest with that tenant's own encryption key. Tokens are never pooled or exchanged centrally, and one practice's connection is not reachable from another's.
Felgate's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically, we do not:
A practitioner can disconnect at any time from Calendar sync in their portal. We revoke the token with Google and delete our copy immediately. They can also revoke access directly from their Google Account at myaccount.google.com/permissions. Events Felgate has already created remain in the practitioner's calendar unless they delete them there.
Where a recipient processes data outside the UK we rely on an approved transfer mechanism (UK adequacy regulations or the International Data Transfer Agreement / UK Addendum to the EU SCCs) and, following the Data (Use and Access) Act 2025, apply the "not materially lower" protection test. We prefer UK/EU regions for email and backups.
We keep account and billing data while you have an account, then only as long as needed for legal, accounting and tax purposes (generally up to 6-7 years for financial records). Logs are kept for a limited period for security. Retention of your clients' data is governed by your tenant settings and the DPA.
Under UK data protection law you can ask to access, rectify, erase or restrict your personal data, to object to certain processing, to portability, and to withdraw consent. Contact legal@felgate.co.uk; we respond within statutory timescales. You can also complain to the ICO (ico.org.uk), though we would appreciate the chance to help first. If your request concerns data held in your clients' records, you are the controller - use the in-product export and erasure tools.
We protect personal data with encryption in transit (TLS) and at rest (special-category fields encrypted with per-tenant keys), access controls, multi-factor authentication, tenant isolation, monitoring and backups. No system is perfectly secure; we keep our measures under review. Our security commitments to practitioners as a processor are set out in the DPA.
The Service is for practitioners (adults) and is not directed at children. Where a practitioner's client is a minor, the practitioner is the controller and is responsible for the appropriate consent and safeguards.
We may update this policy. The version and effective date are at the top. Material changes will be notified by email or in-product.
Questions about this document? Contact legal@felgate.co.uk.