Ping Services Ltd – Privacy Policy 

Document Number: PSIS-PP-02 Version: 1.3 (Consolidated) Document Owner: Ping Services Ltd Review Date: 1 January 2027 

1. Background 

Ping Services Ltd understands that privacy is fundamental to trust. This Privacy Policy explains how personal data is collected, used, stored, shared, and protected across all Ping Services platforms, applications, and services, including: 

• Resident mobile applications 
• Web-based platforms and portals 
• Parcel management and locker / hub solutions (including the Ping Apudos Hub) 
• Integrated services provided to building owners, operators, and managing agents 

This policy consolidates and replaces standalone privacy wording previously contained within Platform Terms and Fair Processing Notices. 

2. Definitions and Interpretation 

Terms such as personal data, processing, controller, processor, data subject, and UK GDPR have the meanings given to them in the UK General Data Protection Regulation and the Data Protection Act 2018. 

3. Information About Us 

Company: Ping Services Ltd Company Number: 12319160 Registered Address: C/O Sobell Rhodes The Kinetic Centre Theobald Street Elstree, Borehamwood WD6 4PJ 

Data Protection Officer: Andrew Alexander Email: [email protected] Support: [email protected] 

4. What Does This Policy Cover? 

This Privacy Policy applies to: 

• Residents and authorised users of Ping Services applications 
• Users of parcel management and hub technologies 
• Visitors to Ping Services platforms 
• Individuals whose data is processed through integrations with property operators 

This policy does not apply to third-party websites or services accessed via links within our platforms. 

5. Data Protection Roles 

Depending on deployment: 

• Ping Services Ltd may act as a Data Processor, providing technology and operational services 
• Building owners, managing agents, or operators act as Data Controllers 

Where Ping Services acts as a processor, data is handled strictly in accordance with the controller’s instructions and applicable law. 

6. What Is Personal Data? 

Personal data includes any information that identifies or can reasonably identify an individual, including contact details, identifiers, usage data, images, and location or device data. 

7. What Data We Collect 

Depending on platform use, we may process: 

a) Identity & Contact Data 

• Full name 
• Email address 
• Contact telephone number 
• Residential address / unit reference 
• Profile photographs 

b) Account & Usage Data 

• Login credentials (encrypted) 
• App activity and interaction logs 
• Booking records and service requests 
• Social forum posts and interactions 

c) Parcel & Access Data 

• Parcel access or collection codes 
• Time and date of collection 
• Signatures and photographic proof 
• Associated CCTV footage (where installed) 

Parcel & Access Data We process information relating to the delivery and collection of parcels, including access codes, timestamps, and proof of collection. 

In some buildings, parcels may be stored in shared parcel rooms or shelving areas. In such cases, information visible on parcel labels (such as name and apartment reference) may be visible to other residents. This visibility is incidental to the delivery and collection process and is not used for any other purpose. 

d) Technical & Device Data 

• Device identifiers 
• Operating system and app version 
• IP address and usage diagnostics 

e) Communications & Submissions 

• Free-text messages 
• Uploaded documents or images 
• Maintenance Requests 

f) Optional, User-Provided & Special Category Data

Depending on how the Platform is configured by the relevant property operator and how individuals choose to use certain features, the Platform may process additional information provided voluntarily by users. This may include: 

• Guest or visitor names (visitor management)
• Health-related information or dietary requirements (such as food intolerances)
• Accessibility or support requirements
• Other optional information provided by the user 

Where special category data is provided, it is processed only where necessary, voluntarily submitted by the individual, and in accordance with applicable data protection law. 

8. How We Use Personal Data 

Personal data is processed to: 

• Create and manage user accounts 
• Deliver resident, parcel, and building services 
• Enable secure parcel collection and auditing 
• Operate social and communication features 
• Investigate incidents, disputes, or misuse 
• Maintain platform security and performance 
• Meet contractual, legal, and regulatory obligations 

9. Lawful Bases for Processing 

We rely on one or more of the following: 

• Contractual necessity – to provide services 
• Legitimate interests – for platform operation and security 
• Legal obligation – regulatory and safety requirements 
• Consent – where required (e.g. marketing, cookies, CCTV awareness) 
• Explicit consent, where required, for the processing of special category data voluntarily provided by users. 

10. CCTV & Image Data 

Where CCTV or photographic capture is enabled: 

• Used solely for security, verification, and investigation 
• Not routinely monitored live 
• Access restricted to authorised personnel 
• Clear signage provided where CCTV is in use 

11. Data Retention 

Data is retained only as long as necessary: 

• Account and usage data: duration of active relationship 
• Parcel logs and signatures: duration of active relationship 
• Photographs: retained for dispute resolution only 
• CCTV footage: typically 30 days unless flagged 

12. Data Storage & International Transfers 

• Data is stored primarily within the UK or EEA 
• Where transfers occur outside these regions, appropriate safeguards are applied 
• Encryption, access controls, and audit logging are in place 

13. Data Sharing

We do not sell personal data. Data may be shared with:

• Building owners and managing agents
• IT and hosting providers, including cloud infrastructure providers such as DigitalOcean and Amazon Web Services (AWS)
• Security, audit, or investigation partners
• Delivery and courier providers (parcel verification only)
• Third-party service providers whose services may be accessed or booked through the Platform’s services marketplace

Where a resident chooses to book or engage a third-party service through the Platform, relevant personal data (such as name, contact details, apartment reference, and booking information) may be shared with the selected provider solely to facilitate the requested service.

Those third-party providers act as independent data controllers and are responsible for their own services, terms, and privacy practices. Ping Services Ltd does not control and is not responsible for how third-party providers process personal data beyond facilitating the introduction or booking. All third parties are subject to appropriate contractual data protection obligations.

• Payment service providers, including Stripe, to process payments, refunds, and transaction-related communications. 

Payment service providers act as independent data controllers for payment processing activities and process personal and financial data in accordance with their own terms and privacy policies. 

14. Cookies & Tracking 

Cookies and similar technologies are used to: 

• Enable core platform functionality 
• Improve performance and user experience 
• Support analytics and optimisation 

Users can manage cookie preferences via browser settings or in-platform tools. 

15. Your Rights 

Individuals have the right to: 

• Access their personal data 
• Request correction or deletion 
• Restrict or object to processing 
• Withdraw consent 
• Request data portability 
• Lodge a complaint with the ICO 

Requests may be directed to the relevant data controller or to Ping Services for assistance. 

16. Children’s Data 

Our platforms are not designed for unsupervised use by children. Data relating to minors is processed only where necessary and under appropriate authority. 

17. Contact Details 

Email: [email protected] DPO: [email protected] Address: C/O Sobell Rhodes The Kinetic Centre Theobald Street 

Elstree, Borehamwood WD6 4PJ 

18. Changes to This Policy 

This Privacy Policy may be updated periodically. Updates will be published via the platform and take effect upon posting. 

Approved by: Gordon Pennock, Director Date: January 2026