Safcomms Privacy Policy

1 Who we are

Safcomms Limited is the controller responsible for the personal data described in this policy. Our company number is 10939521. Our contact address is 2 New Lodge, Amberley, Stroud, GL5 5AA, United Kingdom. Contact benkeyte@safcomms.uk about privacy, support or your information.

This policy covers the Safcomms Android and iOS apps, beta programme and connected account and support services. It explains our handling of information for connection, charging-status and supported external-device features. Acceptance of our Terms is not blanket consent to all processing.

2 Information we handle

Portal, account and support information: joining the client portal is optional. If you join, we process the registration, account and contact information you provide to administer your account and associated services. We also process information you send in support requests and feedback.

Installation and technical information: an app installation identifier, Android or iOS platform, app version, registration and last-seen times, session information, diagnostic status and error categories. Telemetry can be recorded without a named portal account. Reports linked to an installation identifier may still be personal data; we treat this as pseudonymous information rather than claiming that the absence of a name makes it anonymous.

Connection information: feature and connection states, VPN and resolver availability, response times and reconnection events. Where supported, this includes Wi-Fi, mobile-data, VPN or offline status. A VPN can operate over Wi-Fi or mobile data. An unknown transport does not establish that Safcomms independently supplied connectivity.

Battery and external-device information: where supported, battery level and operating-system charging status, identifiers or names of enrolled devices, and compatible equipment readings such as power in kW, energy in kWh, and session or cumulative totals. These are reported readings; they do not by themselves establish the source of energy or that Safcomms caused charging.

Network information: our servers receive the network metadata necessary to handle connections, including the source IP address. Our network logging is limited to connection-status records. We do not retain DNS query histories, domain or browsing-destination histories, or traffic contents as logs. DNS, VPN and proxy services still process the requests or traffic needed to operate the feature you use.

Payment information: Android beta payments are processed through Stripe. Stripe processes payment and transaction information; Safcomms receives the transaction information needed to confirm access, keep payment records, deal with disputes and issue refunds. Buying Android beta access therefore involves payment information even if you do not create a client portal account.

3 Where information comes from

Information comes from you, the app and operating system, our service infrastructure, payment records and equipment you choose to connect. Please enrol only equipment you own or are authorised to manage. Avoid including unnecessary personal information in feedback.

4 Why we use information

Providing requested features: we use account, installation and connection information, and device readings necessary for features you activate, to provide the service and administer your beta access. For processing objectively necessary to perform our contract, our lawful basis is performance of that contract. Refusing genuinely necessary information may prevent the affected feature from working.

Security and fault investigation: we use proportionate technical records to protect accounts, detect misuse and investigate failures. Our lawful basis is legitimate interests in operating a secure and reliable service, where the processing is necessary and your interests and rights do not override those interests.

Beta evaluation: we use connection and charging-status telemetry to assess reliability, identify recurring faults and improve Safcomms during the testing programme. Our basis for this proportionate evaluation is legitimate interests in understanding and improving the performance of the beta service, subject to necessity and the balance with your rights. The beta does not currently provide a separate telemetry opt-out; your right to object is explained in section 8.

Orders and compliance: we use order and transaction information to administer purchases and refunds under our contract with you. We retain records necessary to meet applicable accounting, tax and other legal duties on the basis of legal obligation.

Acceptance of the Terms or payment is not consent to unrelated processing. Where a particular activity requires consent under applicable law or platform rules, we must obtain that consent before the activity and respect withdrawal. A legitimate-interests basis does not replace any separate consent required for access to information on your device.

5 Background reporting and local storage

Telemetry forms part of the current beta and there is no separate in-app option to disable reporting while continuing to use the beta. Enabled connection features may retry and send status reports in the background, subject to Android or iOS restrictions and network availability. This activity may use battery and network data. Reports can remain linked to the same installation without a named portal account.

You may stop using and uninstall the beta if you wish to stop that installation from sending further app reports. Merely closing the app may not stop its background activity. You can also manage permissions through your device settings, although restricting permissions may prevent affected features from working.

Contact benkeyte@safcomms.uk about ending participation, account closure or your data rights. Stopping use or uninstalling the app does not automatically delete records already held on our servers, and does not cancel an active client portal account.

The app may retain settings, installation identifiers and enrolled-device details locally between sessions. Removing a locally enrolled device does not necessarily delete historical server readings. Operating-system backups are subject to your device and backup settings.

6 Storage and access

Safcomms app servers are located in the United Kingdom. We do not grant outside organisations access to the app telemetry held on those servers. Access within Safcomms is limited to authorised people who need it for the purposes described here.

Stripe is our payment provider and processes payment-related information. This is separate from access to Safcomms app telemetry. Stripe may act as our processor for payment services and as an independent controller for purposes such as fraud prevention and meeting its own legal duties. Read Stripe’s privacy policy at https://stripe.com/gb/privacy.

Stripe operates internationally and may process payment information outside the UK. Its privacy policy explains the countries, applicable transfer safeguards and how to contact it about those arrangements. Our use of UK app servers does not mean all information handled by payment or platform providers stays in the UK.

Apple, Google and your network provider may independently process information when you use their platforms or services, under their own privacy notices. Apple processes information associated with TestFlight.

We may disclose necessary information where required by law or where necessary and lawful to establish or defend legal rights. Any such disclosure is limited to its legitimate purpose. We apply appropriate technical and organisational safeguards; no system can promise absolute security.

7 How long we keep information

We retain beta telemetry and connection-status logs throughout the overall testing programme, which may include several three-month phases. We delete these records after the final three-month testing phase and before the public launch of the app. This deadline applies to the beta telemetry dataset, including copies and backups under our control.

There is no routine deletion of older reports during an active testing phase. However, retention remains subject to ongoing necessity and applicable rights: we do not postpone a valid erasure request solely because testing is continuing. If the programme is abandoned or launch is delayed, we do not keep the records indefinitely just in case; we delete them when they are no longer needed for the stated testing purpose.

The deletion of beta telemetry does not automatically close a client portal account. Portal and support information is retained only while needed to administer the account, provide the requested service and resolve outstanding matters. Payment records are kept for applicable accounting and tax requirements. Specific records may be retained for a documented legal obligation or dispute, with access and use limited to that purpose.

Our retention criteria for those separate records are the continuing purpose of the record, whether the account or matter remains active, and applicable legal requirements. You can contact benkeyte@safcomms.uk to ask about a particular record or request deletion.

8 Your rights

Depending on applicable law and the processing basis, you may request access, correction, erasure, restriction or portability of personal data. Where processing relies on consent, you may withdraw it; withdrawal does not invalidate earlier lawful processing. Rights have conditions and exceptions, which we will explain where relevant.

Your right to object: you may object to processing based on legitimate interests because of your particular circumstances. You may object to direct marketing at any time.

Email benkeyte@safcomms.uk to make a request or ask for account closure and deletion of associated information. Include enough information to locate your records, such as your account email or installation identifier if available. Do not send passwords. We may ask for proportionate evidence of identity.

We respond without undue delay, normally within one calendar month. If a lawful extension is needed, we explain it within the applicable initial period. Testing-phase retention does not override applicable rights. Uninstalling the app is not the same as deleting an account or server records.

9 Complaints and age requirements

Contact benkeyte@safcomms.uk with concerns about your information. You may also complain to the UK Information Commissioner’s Office at ico.org.uk/make-a-complaint or your applicable local regulator. You do not need to contact us first.

The beta is offered to people aged 18 or over. If you believe a child has provided information, contact us so we can investigate and take appropriate action.

10 Policy changes

We update this policy when our practices change and identify the updated version. We provide appropriate notice of material changes and obtain consent where required before introducing new processing.