Privacy Policy

 Last updated: 13 July 2026

1. Introduction

This Privacy Policy explains how IMMO TGC SRL collects, uses, stores, shares and protects personal data through the TGC construction site management application, including its associated mobile, web and backend services.

TGC is an internal workplace application intended for authorised employees and other authorised personnel working for IMMO TGC SRL. It enables the management of construction projects, personnel, tasks, progress reports, materials, tools, project documents, incidents and financial information.

TGC is not intended for general public use. Users can create an account only after receiving a confidential registration code from IMMO TGC SRL.

For the purposes of applicable data-protection law, including the General Data Protection Regulation, IMMO TGC SRL is the controller of personal data processed through TGC.

2. Controller and contact details

IMMO TGC SRL
Chaussée Gabrielle Richet 227/B
7860 Lessines
Belgium

Email: info@tgcimmo.com

Questions about this Privacy Policy, personal-data requests and account-deletion requests should be sent to the email address above.

3. Who may use TGC

TGC is intended exclusively for people aged 18 or over who are authorised to use it in connection with their work for IMMO TGC SRL.

This may include:

• employees;

• workers;

• site managers;

• project managers;

• administrators; and

• other authorised personnel working on IMMO TGC SRL projects.

TGC is not intended for children and we do not knowingly permit anyone under the age of 18 to create an account.

4. Personal data we collect

4.1 Account and workforce information

When a user creates or uses a TGC account, we may collect:

• full name;

• email address;

• password in securely protected form;

• job title or work role;

• date of birth;

• profile photograph;

• employer-issued registration or invitation code;

• account status;

• assigned project, workplace, team or site;

• user role and access permissions; and

• employment or engagement status where relevant to account administration.

A user’s date of birth and profile photograph may be used for workplace identification, workforce administration, account security, age confirmation and appropriate assignment of site responsibilities.

4.2 Project and operational information

Users and authorised managers may enter information relating to construction projects and workplace operations, including:

• assigned tasks and work orders;

• task status and completion information;

• progress reports;

• project milestones;

• site reports;

• employee or team assignments;

• working activity and performance information connected with assigned tasks;

• material stock and material usage;

• tools, equipment and asset records;

• deliveries;

• project plans, technical drawings and specifications;

• project costs, budgets and financial records;

• invoices and invoice attachments;

• supplier and client information;

• construction-site observations;

• safety observations; and

• other records required to administer a construction project.

This information may identify the user who created, modified, approved or completed a particular record.

4.3 Messages and communications

TGC allows authorised users, including administrators, site managers and workers, to exchange work-related private messages.

We may process:

• message content;

• sender and recipient details;

• date and time sent;

• attachments;

• delivery or read status, where supported; and

• related project or task information.

Messages are not published publicly. However, users should understand that TGC is a workplace system. Messages and related records may be accessible to authorised administrators or managers where necessary for project management, workplace safety, technical support, investigation of misuse, dispute resolution or compliance with legal obligations.

4.4 Photographs, videos, files and documents

Users may submit or upload:

• progress photographs;

• site photographs;

• incident photographs or videos;

• profile photographs;

• plans and drawings;

• work orders;

• invoices;

• project documents; and

• other work-related files.

TGC accesses the device camera only when a user chooses to take a photograph through the app. Files, photographs or videos stored on a device are accessed only when the user chooses to select or upload them.

TGC does not continuously access the camera, photograph library or files in the background.

Uploaded videos may contain audio if the user deliberately uploads a video that already includes sound. TGC does not otherwise use the device microphone for continuous recording or monitoring.

4.5 Incident and safety information

Incident reports may contain information about:

• workplace accidents;

• injuries;

• medical assistance;

• health-and-safety concerns;

• people involved in or witnessing an incident;

• photographs or videos of the incident; and

• actions taken following the incident.

Where incident reports contain health information or other specially protected information, it is processed only where necessary and permitted by applicable law, including for workplace safety, employment obligations, occupational health, insurance, legal claims or protection of an individual’s vital interests.

Users should include only information that is relevant and necessary to document the incident.

4.6 Technical and security information

TGC does not use behavioural analytics, advertising trackers or analytics SDKs.

However, limited technical data may be processed automatically where necessary to operate and secure the service, including:

• IP address used to communicate with the service;

• login and authentication records;

• account-session information;

• dates and times of access;

• device operating system and platform;

• app version;

• security and error logs;

• request and server logs;

• notification registration status; and

• Firebase Cloud Messaging or Apple Push Notification Service device tokens.

This information is used to authenticate users, maintain sessions, deliver notifications, investigate faults, prevent unauthorised access and protect the security of TGC.

4.7 Biometric authentication

TGC may allow a user to unlock the app using a device’s fingerprint or facial-recognition functionality.

The biometric check is performed by the user’s device operating system. IMMO TGC SRL does not receive, copy, upload or store the user’s fingerprint, facial image or biometric template.

TGC receives only the result of the device’s authentication check, such as whether authentication succeeded or failed.

4.8 Information we do not intentionally collect

TGC does not intentionally collect or access:

• device contacts or address books;

• SMS messages;

• telephone call history;

• personal calendars;

• continuous or background location;

• precise or approximate GPS location;

• advertising identifiers for targeted advertising;

• browsing activity outside TGC; or

• biometric templates.

TGC does not use analytics, targeted advertising, social-login, mapping or artificial-intelligence services.

5. How we use personal data

We use personal data to:

• create, authenticate and administer TGC accounts;

• confirm that users are authorised by IMMO TGC SRL;

• assign users to projects, sites, teams and tasks;

• manage construction work and project progress;

• record completed work and operational activity;

• coordinate workers, managers, suppliers and clients;

• manage materials, tools, equipment and project resources;

• provide work orders, plans, drawings and instructions;

• record and investigate incidents and safety concerns;

• support financial administration, invoicing and project accounting;

• enable work-related messages and communications;

• send operational emails and push notifications;

• provide technical support;

• maintain the security and integrity of TGC;

• prevent misuse, fraud and unauthorised access;

• investigate complaints, disputes or workplace incidents;

• maintain appropriate business, employment and project records;

• meet contractual obligations;

• comply with employment, workplace safety, accounting, tax and other legal obligations; and

• establish, exercise or defend legal claims.

TGC does not use personal data for unrelated advertising or sell it to advertisers or data brokers.

6. Legal bases for processing

Depending on the circumstances, IMMO TGC SRL processes personal data on one or more of the following legal bases:

Performance of a contract

Processing may be necessary to administer the user’s employment, engagement or other working relationship and to fulfil contracts relating to construction projects.

Legitimate interests

We may process data where necessary for our legitimate interests, including:

• managing construction sites and projects;

• coordinating personnel and resources;

• maintaining accurate operational records;

• protecting company property;

• ensuring workplace and site safety;

• securing the app and its systems;

• preventing misuse and fraud;

• managing clients and suppliers; and

• establishing or defending legal claims.

We consider the impact on users’ rights before relying on legitimate interests.

Legal obligations

We may process and retain information to comply with legal obligations relating to:

• employment;

• workplace health and safety;

• accounting and taxation;

• insurance;

• construction and contractual records;

• regulatory investigations; and

• court or government requirements.

Special categories of personal data

Where a workplace or incident record contains health information, we process it only where permitted by applicable law, including where necessary for employment and social-protection obligations, workplace safety, legal claims, vital interests or other legally recognised grounds.

Consent

Where applicable law specifically requires consent for an optional processing activity, we will request that consent separately. A user may withdraw consent without affecting processing that took place before withdrawal.

7. Notifications and operational emails

TGC may send:

• task assignments;

• message notifications;

• work-order notifications;

• project updates;

• site or safety alerts;

• account and security messages;

• password or authentication communications; and

• other operational notifications connected with the user’s work.

Push notifications may be delivered through Google Firebase Cloud Messaging on Android devices and Apple Push Notification Service on Apple devices.

Transactional emails may be delivered through Resend.

These services may receive the information necessary to deliver a notification or email, such as the recipient’s email address, name, device notification token and message-delivery details.

TGC does not use push notifications or transactional emails for third-party advertising or unrelated marketing.

Users may control push-notification permissions through their device settings, although disabling notifications may prevent them from receiving important operational alerts.

8. Service providers and data storage

We use selected service providers to host and operate TGC.

Railway

Railway hosts:

• the TGC application programming interface;

• the web application;

• the PostgreSQL database;

• the Redis job queue; and

• associated backend infrastructure.

The principal Railway infrastructure used for TGC is hosted on servers in the United Kingdom.

Amazon Web Services

Amazon Web Services S3 is used to store uploaded project documents and invoice attachments.

The relevant S3 storage region is eu-west-1, located in Ireland.

Google Firebase Cloud Messaging

Firebase Cloud Messaging may process Android device notification tokens and notification-delivery information in order to deliver push notifications.

Apple Push Notification Service

Apple Push Notification Service may process Apple device notification tokens and notification-delivery information in order to deliver push notifications.

Resend

Resend processes information such as users’ names and email addresses where necessary to send transactional and operational emails.

Google Play and Apple App Store

Google and Apple may separately process information connected with app distribution, downloads, device accounts and platform security under their own privacy terms.

Our service providers are permitted to process personal data only for the provision, security and support of their respective services, subject to their contractual and legal obligations.

9. Local device storage

TGC may store limited information on the user’s device in order to maintain authentication, provide app functionality and improve reliability.

Refresh tokens may be stored using the secure storage provided by the device operating system, such as Android Keystore or Apple Keychain.

The web or progressive web version may also store necessary app resources locally through a service worker. TGC does not use this functionality for third-party advertising or behavioural tracking.

Users should protect access to their devices and notify IMMO TGC SRL promptly if a device used for TGC is lost, stolen or accessed without authorisation.

10. How information is shared

Personal data may be shared with the following recipients where reasonably necessary:

• authorised TGC users;

• managers and administrators within IMMO TGC SRL;

• clients and project owners;

• suppliers;

• subcontractors;

• architects, engineers, surveyors and other project professionals;

• health-and-safety professionals;

• insurers;

• accountants and auditors;

• legal advisers;

• technology and hosting providers;

• regulators, courts, police and public authorities; and

• potential purchasers or successors in connection with a sale, merger or restructuring of the business.

Information is shared only where relevant to purposes such as:

• delivering a construction project;

• managing tasks and personnel;

• processing work orders or deliveries;

• administering contracts and invoices;

• managing workplace or site safety;

• investigating an incident;

• resolving a dispute;

• protecting legal rights; or

• complying with a legal obligation.

Information entered in TGC is not publicly distributed.

IMMO TGC SRL does not sell, rent or trade personal data.

11. International data transfers

TGC data is principally hosted in the United Kingdom and Ireland.

Some service providers, including Google, Apple, Amazon Web Services and Resend, may process limited information through infrastructure or personnel located outside the European Economic Area or United Kingdom.

Where personal data is transferred internationally, we take steps intended to ensure that the transfer is protected as required by applicable law. Depending on the destination and provider, these measures may include:

• an adequacy decision;

• approved standard contractual clauses;

• the UK International Data Transfer Addendum or equivalent safeguards; and

• contractual, organisational and technical security measures.

12. Data retention

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy.

As a general rule:

• account, profile and workforce information is retained while the account or working relationship remains active and for up to five years afterwards;

• tasks, work orders, progress reports, messages, photographs, videos and other project records are retained for up to five years after completion or closure of the relevant project;

• supplier, client and contractual records are normally retained for up to five years after the relevant project or relationship ends;

• security, access and technical records are retained only for as long as reasonably required for system operation, security and investigation; and

• support correspondence is normally retained for up to five years after the matter is resolved.

Financial, accounting, tax, employment, insurance, safety, incident or legal records may be retained for longer where required by law, an applicable limitation period, an audit, an insurance requirement, an investigation or a legal claim.

When information is no longer required, it will be deleted, anonymised or securely disposed of where reasonably practicable. Residual copies may remain temporarily in protected backups until those backups are overwritten through the applicable backup cycle.

13. Account deletion

Users may request deletion of their TGC account in either of the following ways:

Through the TGC app

Within the app, go to:

Settings → Account → Delete account

Follow the instructions displayed to submit an account-deletion request.

By email

Users may also request account deletion by emailing:

info@tgcimmo.com

The email should:

• be sent from the email address associated with the TGC account;

• use the subject line “TGC account deletion request”; and

• include the user’s full name and registered email address.

We may request additional information where reasonably necessary to verify the user’s identity and prevent fraudulent or unauthorised deletion requests.

Account-deletion requests will be reviewed and answered within 30 days.

Following approval of the request, IMMO TGC SRL will deactivate and delete the user’s TGC account and delete or anonymise personal data associated exclusively with that account where the information is no longer required.

Deleting an account does not necessarily require deletion of every workplace or project record previously created or contributed to by the user. IMMO TGC SRL may retain employment, project, contractual, safety, incident, financial, accounting or legal records where:

• retention is required by applicable law;

• the information forms part of an official project, employment or workplace record;

• the information is necessary to protect the rights or safety of another person;

• it is relevant to an investigation, dispute, insurance matter or legal claim; or

• deletion would impair the integrity of legitimate business or project records.

Where reasonably possible, retained information will be restricted, anonymised or separated from the deleted account. Information that is retained remains subject to the security, access-control and retention provisions described in this Privacy Policy.

A site manager or authorised administrator may also suspend or delete an account when a user’s employment or authorisation ends, or where required for security, legal or operational reasons. Suspension or deactivation alone is not treated as completion of a user-requested account deletion.

14. Data security

We use technical and organisational measures designed to protect personal data, including:

• encrypted communication using HTTPS/TLS;

• authenticated user access;

• role-based permissions for workers, managers and administrators;

• restrictions on administrative access;

• secure password handling;

• secure device storage for authentication tokens;

• infrastructure security measures provided by Railway and Amazon Web Services;

• access and security logging;

• account suspension controls; and

• procedures for investigating suspected security incidents.

Access to information is limited according to the user’s role and work responsibilities.

No electronic transmission or storage system can be guaranteed to be completely secure. Users must keep their passwords and registration codes confidential and should report suspected unauthorised access promptly to info@tgcimmo.com.

15. Automated decision-making, analytics and advertising

TGC does not use:

• artificial-intelligence services;

• automated employment decisions;

• automated profiling that produces legal or similarly significant effects;

• advertising networks;

• targeted advertising;

• cross-app tracking;

• Google Analytics;

• Firebase Analytics;

• social-media tracking SDKs; or

• third-party behavioural analytics.

Task activity, progress reports and other work records may be reviewed by authorised human managers as part of normal project and workforce administration.

16. Users’ data-protection rights

Subject to applicable law, users may have the right to:

• obtain confirmation that their personal data is being processed;

• request access to their personal data;

• request correction of inaccurate or incomplete data;

• request deletion of data;

• request restriction of processing;

• object to processing based on legitimate interests;

• receive certain data in a structured and commonly used format;

• withdraw consent where processing is based on consent; and

• lodge a complaint with a data-protection authority.

These rights are not absolute. For example, we may need to retain information to comply with employment, safety, accounting or legal obligations or to establish or defend legal claims.

Requests should be sent to info@tgcimmo.com. We may ask for information necessary to verify the requester’s identity.

Users in Belgium may lodge a complaint with the Belgian Data Protection Authority, also known as the Autorité de protection des données or Gegevensbeschermingsautoriteit.

Users in the United Kingdom may also contact the UK Information Commissioner’s Office where UK data-protection law applies.

17. Third-party documents and personal data

Users must ensure that personal data entered or uploaded into TGC is relevant, accurate and appropriate for a legitimate work purpose.

Users should not upload unnecessary personal information, private documents or sensitive information unrelated to the construction project or their work.

Where a user uploads information about another person, the user must do so only where authorised and necessary for a legitimate work, contractual, safety or legal purpose.

18. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to:

• TGC functionality;

• the information we process;

• our service providers;

• our business operations; or

• applicable legal requirements.

The updated policy will be published at:

https://sites.google.com/view/tgcprivacypolicy/home

The “Last updated” date at the top of the policy will be changed when revisions are made. Where changes are material, we may also notify users through TGC or by email.

19. Contact us

For privacy questions, requests to exercise data-protection rights or account-deletion requests, contact:

IMMO TGC SRL
Chaussée Gabrielle Richet 227/B
7860 Lessines
Belgium

Email: info@tgcimmo.com