1. Who we are
BLUT LTD is a company registered in the United Kingdom. We operate NumClean, a phone-number validation and list-hygiene service designed to help businesses identify unreachable, inactive, or misclassified mobile numbers before sending messages.
If you have questions about this policy or how we handle your data, you can reach us at support@numclean.com.
2. What personal data we process
We process two categories of personal data in connection with our service:
- Phone numbers uploaded for validation: Customers upload lists of mobile numbers so we can run reachability and line-type checks. These numbers are the core data we process on behalf of the customer.
- Contact information submitted through our website: When you fill in our enquiry form, we collect your work email address, company name, target region(s), estimated volume, and any optional message you provide.
3. Purpose and legal basis
We process personal data for the following purposes:
- Providing the validation service: We process uploaded phone numbers solely to deliver the validation results the customer has requested. The legal basis is the performance of a contract (or steps taken at your request prior to entering a contract).
- Responding to enquiries: When you submit our contact form, we use your information to respond to your request. The legal basis is our legitimate interest in communicating with prospective customers.
- Service improvement: We may use aggregated, non-identifying usage data to improve our service. The legal basis is our legitimate interest in operating and improving NumClean.
4. Data minimisation and retention
We follow a strict data-minimisation approach:
- Uploaded number lists are processed to produce a validation report and are then deleted within 48 hours of the results being delivered. We do not retain customer lists beyond what is strictly needed to deliver the service.
- Validation results (the output report) are available for download for a limited period and then removed from our systems.
- Contact form submissions are retained only as long as necessary to respond to and follow up on your enquiry, and no longer than 12 months unless a business relationship is established.
5. Sub-processors
To perform phone-number validation, we transmit numbers to a third-party telecom data provider that operates HLR (Home Location Register) lookups via SS7 signalling networks. Numbers are sent to this provider solely to return validation results (reachability, line type, carrier information, porting status). The provider does not use these numbers for any other purpose.
We select sub-processors that maintain appropriate technical and organisational security measures and that are contractually bound to process data only on our instructions.
6. International transfers
Data may be processed in the United Kingdom and, via our telecom data provider, in other jurisdictions as required to perform the network lookups. Where data is transferred outside the UK, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the UK Information Commissioner's Office or adequacy decisions.
7. Data subject rights
Under applicable data protection law, you may have the right to:
- Access the personal data we hold about you.
- Rectification of inaccurate or incomplete data.
- Erasure ("right to be forgotten") of your data in certain circumstances.
- Object to processing based on legitimate interests.
- Data portability — receive your data in a structured, machine-readable format.
- Lodge a complaint with a supervisory authority (in the UK, the Information Commissioner's Office).
To exercise any of these rights, contact us at support@numclean.com. We will respond within 30 days.
8. Customer responsibility
When a customer uploads a list of phone numbers for validation, the customer is the data controller of that list. NumClean (BLUT LTD) acts as a data processor, processing numbers solely on the customer's instructions for the purpose of delivering validation results.
Customers are responsible for ensuring they have a lawful basis (including any required consents) to process the phone numbers they upload and to use the validation results in compliance with applicable data protection and telecommunications regulations (e.g. GDPR, POPIA, local opt-in rules).
9. Cookies and tracking
Our website uses only strictly functional cookies where necessary (e.g. session management). We do not use advertising cookies or third-party tracking pixels.
If we implement analytics in the future, we will use privacy-respecting, aggregate-only analytics and update this section accordingly.
10. Changes to this policy
We may update this privacy policy from time to time. Changes will be posted on this page with an updated "Last updated" date. We encourage you to review this policy periodically.
11. Contact
If you have any questions, concerns, or requests relating to this privacy policy, please contact:
BLUT LTD
United Kingdom
Email: support@numclean.com