This Privacy Policy explains how Front End Engineering Consultancy Limited, trading as FEEC (“FEEC”, “we”, “us”), collects, uses and protects personal data in connection with the emitledger.com website, the EmitLedger web application and the EmitLedger mobile app (together, the “Service”).
1. Who we are
1.1 Controller. Front End Engineering Consultancy Limited is a private company limited by shares incorporated in Hong Kong (Business Registration No. 75797664), with its registered office at Unit B6, 12th Floor, Wing Wah Building, No. 677 King’s Road, Quarry Bay, Hong Kong.
1.2 Contact. For anything about privacy, email privacy [at] emitledger.com.
1.3 Representatives and data protection officer.
- Data protection officer: A formal designation is under counsel review; for privacy questions, contact privacy [at] emitledger.com.
- EU and UK representatives (GDPR and UK GDPR Article 27): Not appointed. Whether one is required is under counsel review.
2. Two roles: controller and processor
2.1 We are the controller for personal data we collect for our own purposes:
- visitors to emitledger.com and people who contact us or request a demo;
- account and sign-in data of users of the Service, to the extent we use it to run, secure and bill for the Service;
- contacts at customers, prospects, partners and suppliers (for sales, contracts, invoicing and support); and
- security logs.
2.2 We are a processor for personal data that our business customers put into the Service (“Customer Data”), such as the names of their staff recorded in audit logs, photos and locations attached to leak findings, and comments in uploaded files. Each customer decides what data goes in and how it is used, and our Data Processing Agreement with that customer governs our processing. If you use EmitLedger through your employer or a client and want to exercise your privacy rights over Customer Data, please contact that organisation. We will help them respond.
3. What we collect and why
3.1 Website visitors (emitledger.com)
- What: our web server records technical data in security logs: IP address, date and time, requested page, referrer and browser user-agent.
- What we do not do: the website uses no analytics, advertising trackers or third-party scripts, and sets no tracking cookies. Fonts and other assets are served from our own domain, so your browser does not contact third parties when you visit. If you choose a light or dark theme, that choice is stored only in your own browser. See our Cookie Notice.
- Why: to deliver the website and protect it against abuse and attacks.
- Legal basis: legitimate interests (security and operation of the website).
3.2 Demo, pilot, partner and sales enquiries
- What: name, business email, company, job title (optional), enquiry type, number of assets (range), any message you write, and your consent confirmation. If the form cannot be sent directly, it opens an email to sales [at] emitledger.com in your own email program instead.
- Why: to reply to your request, arrange a demo or pilot, and follow up on it.
- Legal basis: your consent (given on the form) and our legitimate interests in responding to business enquiries; steps prior to entering into a contract where you represent a prospective customer.
- We will not add you to marketing mailing lists without your separate consent, and you can ask us to stop contacting you at any time.
3.3 Users of the EmitLedger web application
- Account data: name, business email, identity-provider user ID, preferred language, organisation (tenant) memberships, roles and access scopes, invitation details, account creation and last sign-in times.
- Authentication data: sign-in events, multi-factor authentication settings (held in our identity service), failed sign-in attempts used for brute-force protection. Passwords are stored only as salted hashes in our identity service. If your organisation uses its own identity provider, we receive the identity token it issues.
- Audit and activity data: the Service keeps an append-only audit log of who created, changed, submitted, approved, locked, exported or accessed records, with timestamps and request IDs. This is part of your organisation’s Customer Data, and it is a core feature that makes emissions data verifiable.
- Technical data: IP address, browser user-agent, request IDs and error logs.
- Why: to create and manage accounts, authenticate users, provide the Service, keep it secure, provide support, send service messages (such as invitations, password resets, approval notifications and data-due reminders), measure usage for plan limits and billing, and improve the Service.
- Legal basis: performance of our contract with your organisation and our legitimate interests in providing a secure, working service to it; legal obligations (for example security and record-keeping). Where we process data as your organisation’s processor, your organisation determines the legal basis.
3.4 Users of the EmitLedger mobile app
In addition to account data (section 3.3):
- Precise location (latitude and longitude): collected only when you tap to add your current location to a leak detection and repair (LDAR) finding, while the app is open. The app does not use background location.
- Camera and photos: used only when you take or choose a photo to attach as evidence to an LDAR finding. The app re-encodes the photo and removes embedded metadata (EXIF, including any GPS tags) before uploading it.
- Push token: if you allow notifications, a device push token and platform (iOS or Android), used to send approval and reminder notifications. Notifications contain identifiers only (such as a reporting period), never emission figures.
- Data on the device: sign-in tokens are kept in the device’s secure keychain or keystore. Entries waiting to upload, and their photos, are stored in the app until sent, and removed 7 days after sending. Cached reference data is cleared when you sign out.
- What we do not collect: contacts, microphone, background location, advertising identifiers, cross-app tracking, or analytics or crash-reporting SDKs.
- Why and legal basis: location and photos are evidence that your organisation collects as Customer Data (we act as processor); your device permission is requested before first use and you can withdraw it in your device settings. Push tokens are processed to provide notifications you have allowed (performance of contract and legitimate interests; consent to device notifications where required).
3.5 Customers, partners and suppliers
- What: names, business contact details, job titles, contract and order records, invoices, payment records and correspondence.
- Why and legal basis: to enter into and perform contracts, invoice and collect payment, and meet accounting and tax obligations (contract, legal obligation, legitimate interests).
3.6 Support and security requests
- What: content of emails to support [at] emitledger.com or security [at] emitledger.com and any attachments.
- Why and legal basis: to handle your request (contract, legitimate interests). Please do not send more Customer Data by email than needed.
3.7 Sensitive data
We do not ask for sensitive personal data (such as health, biometric, religious or political data). Please do not enter it into the Service. Photos should show equipment, not people.
4. Who we share personal data with
4.1 We do not sell personal data, and we do not share it for advertising.
4.2 We share personal data only with:
- Service providers that host, back up, deliver email or push notifications, or otherwise help us run the Service, under contracts that require them to protect the data. The current list, with locations, is on our Sub-processors page;
- your organisation and the users it authorises (including external verifiers it invites), for data within its tenant;
- professional advisers (lawyers, accountants, auditors, insurers) under confidentiality duties;
- authorities, when required by law or to protect rights, safety and security; and
- a buyer or successor in a merger, acquisition or sale of our business, subject to this policy.
5. International transfers
5.1 We are a Hong Kong company. The Service is hosted in Germany (or, for dedicated customers, in the region they choose, such as Singapore), and encrypted backups are stored in the European Union (Cloudflare R2, EU jurisdiction) and on the hosting server in Germany. Some service providers are in the United States or other countries.
5.2 Where the law requires, we protect transfers with appropriate safeguards, such as the European Commission’s standard contractual clauses (2021/914), the UK International Data Transfer Addendum, the safeguards required under sections 28 and 29 of the Thai PDPA, contractual protections for transfers under the Hong Kong PDPO and Singapore PDPA, and reasonable steps under Australian Privacy Principle 8. Contact privacy [at] emitledger.com for a copy of the relevant safeguards.
6. How long we keep personal data
| Data | Retention |
|---|---|
| Website security logs | Rotated automatically; normally no more than 90 days, unless needed to investigate an incident |
| Demo and sales enquiries that do not lead to a contract | 24 months after our last contact, unless you ask us to delete them sooner |
| User accounts | While the account is active in any organisation; deleted or anonymised when the account is removed and no longer needed, subject to the audit log below |
| Audit log entries and Customer Data | For the life of the customer’s subscription, then deleted 30 days after the 30-day post-termination retrieval period, as described in our Master Subscription Agreement |
| Encrypted backups | Rotated out within 12 months |
| Push tokens | Until you sign out, uninstall the app or the token becomes invalid |
| Contract, invoice and tax records | As required by accounting and tax law (generally 7 years) |
| Support and security correspondence | 3 years after the request is closed, unless needed longer for a legal claim |
7. Security
We protect personal data with technical and organisational measures, including tenant isolation enforced by database row-level security, TLS encryption in transit, encrypted backups, multi-factor authentication, least-privilege access, audit logging and vulnerability scanning. Our staff cannot see customer emissions data by default; support access must be approved by the customer, is time-limited and is audited. See our security page and Annex 2 of the DPA. We do not currently hold ISO 27001 or SOC 2 certification. No system is completely secure, and we will notify you and regulators of a data breach where the law requires.
8. Your rights
8.1 Depending on the law that applies to you, you may have the right to:
- access your personal data and get a copy;
- correct inaccurate data;
- delete data, or restrict or object to its processing (including objecting to processing based on legitimate interests, and to direct marketing at any time);
- receive your data in a portable format;
- withdraw consent at any time, without affecting earlier processing; and
- complain to a data protection authority.
8.2 How to exercise them. Email privacy [at] emitledger.com. We may need to verify your identity. We will respond within the time the law requires (for example one month under the GDPR, 30 days under the Thai PDPA and 40 days under the Hong Kong PDPO). For data your employer or a client put into the Service, we will pass your request to that organisation, as it controls that data.
8.3 Regional information.
- European Union, EEA and Switzerland (GDPR): legal bases are listed in section 3. You may complain to the supervisory authority where you live or work.
- United Kingdom (UK GDPR): you may complain to the Information Commissioner’s Office.
- Thailand (Personal Data Protection Act B.E. 2562 (2019)): you have the rights in sections 30 to 36 and 73 of the Act, including to access, portability, objection, erasure, restriction and correction, and to complain to the Personal Data Protection Committee.
- Hong Kong (Personal Data (Privacy) Ordinance, Cap. 486): you may request access to and correction of your personal data. We may charge a fee that is not excessive for complying with a data access request. We do not use personal data for direct marketing without your consent. You may complain to the Office of the Privacy Commissioner for Personal Data.
- Singapore (Personal Data Protection Act 2012): you may request access and correction and withdraw consent, and may complain to the Personal Data Protection Commission.
- Australia (Privacy Act 1988): we handle personal information consistently with the Australian Privacy Principles. You may request access and correction and complain to us first, then to the Office of the Australian Information Commissioner.
- United States: the Service is for businesses. Where a US state privacy law applies, you may have rights to know, access, correct and delete personal information, and to opt out of sale, sharing or targeted advertising. We do not sell or share personal information, or use it for targeted advertising, and we do not use sensitive personal information to infer characteristics. We will not discriminate against you for exercising your rights.
9. Automated decisions
We do not make decisions about individuals based solely on automated processing that have legal or similarly significant effects.
10. Children
The Service is for businesses and is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, contact privacy [at] emitledger.com and we will delete it.
11. Changes to this policy
We may update this policy. We will post the new version with a new “last updated” date and, for material changes, notify customer administrators by email or in the Service before the change takes effect.
12. Contact
Front End Engineering Consultancy Limited Unit B6, 12th Floor, Wing Wah Building, No. 677 King’s Road, Quarry Bay, Hong Kong Privacy: privacy [at] emitledger.com · Security: security [at] emitledger.com · Legal: legal [at] emitledger.com