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Privacy Policy

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Privacy Notice
Labrys website

1. About this notice

This privacy notice (Privacy Notice) explains how Labrys Technologies Limited (Labrys, we, our, us) collects, uses and shares the personal data of: (i) visitors to our website at www.labrys.tech (the Site), including people who join the Axiom waitlist or sign up to hear from us; and (ii) our customers, prospective customers, contractors, suppliers and other individuals whose personal data we process as part of running our business and delivering our services. It also explains your rights in relation to that personal data.

If you use the Axiom app, our separate Axiom Privacy Notice explains how we use your personal data in the app. It is available below and you will be directed to it when you first set up your account on the app.

If you take part in a project run by Labrys' managed services team, our separate Managed Services Privacy Notice also applies to you.

2. Who we are and how to contact us

Labrys Technologies Limited is a private limited company incorporated in England and Wales with company number 12728244, whose registered office is at 3rd Floor, 86-90 Paul Street, London EC2A 4NE. Labrys Technologies Limited is a subsidiary of Labrys Group Holdings Limited.

Labrys is the controller of your personal data. We are registered with the Information Commission Office (ICO) under registration number ZB530167. We are subject to the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR).

If you have any questions about this Privacy Notice, or would like to exercise your data protection rights, please contact our Data Protection Officer at dpo@labrys.tech or info@labrys.tech, or write to us at our registered office.

3. How we collect your personal data

We collect personal data:

  • when you join the Axiom waitlist, sign up to receive updates or newsletters from us, or fill in any other form on the Site;
  • when you express interest in our services, or interact with us before becoming a customer;
  • when you correspond with us by phone, email, post or via the Site (including through our website chat);
  • when you instruct us to provide services, including when you use our technology platforms and communication systems;
  • from your organisation, where it is our customer, supplier or partner and you are its point of contact; and
  • through cookies and similar technologies when you browse the Site (see section 9).

4. The personal data we collect

We may collect and process:

  • names, contact details (including email addresses and telephone numbers), and organisation details (such as your organisation's name and your role or job title);
  • if you join the Axiom waitlist: your email address and, if you choose to provide them, your name and organisation;
  • your marketing preferences, including whether you have unsubscribed;
  • information about your business relationship with us, and due diligence information;
  • billing and financial information;
  • other information you provide through the Site, in correspondence, in website chats (including any files you attach) or in enquiries you send us; and
  • information about your browsing activity collected through cookies and similar technologies, such as your IP address, operating system, browser version, the date and time of your visit, the pages you viewed and how long you stayed.

We do not seek to collect special category data (for example, health information or information about racial or ethnic origin, religious beliefs or political opinions). If such data is included in information you share with us, we will process it only where: (i) we have your explicit consent; (ii) you have manifestly made it public; (iii) it is necessary for the establishment, exercise or defence of legal claims; or (iv) it is necessary for reasons of substantial public interest.

5. How we use your personal data and our legal bases

5.1 Contract

We process your personal data where it is necessary to perform a contract with you, or to take steps at your request before entering into a contract.

5.2 Consent: Axiom waitlist and product updates

If you join the Axiom waitlist, we will use your details to email you about Axiom's launch and early access and to send you occasional updates about Axiom and our services. We do this with your consent, which you give by joining the waitlist. You can withdraw your consent and unsubscribe at any time, using the unsubscribe link in any of our emails or by contacting us at info@labrys.tech. Withdrawing consent does not affect our earlier use of your data.

5.3 Legitimate interests

We process your personal data where it is necessary for our legitimate interests, or those of a third party, provided those interests are not overridden by your rights. Our legitimate interests include running our business and the Site efficiently and securely. We use your personal data on this basis:

  • to assess and respond to enquiries and information you send us, including through our website chat (which may be answered automatically in the first instance);
  • to communicate with you by email, telephone or via our technology and communications platforms;
  • to provide our services, including research services, strategic advice and consulting services, and reports for our clients based on information provided to us;
  • to process and verify your instructions;
  • for market research and business development;
  • where you contact us as a representative of an organisation, to send you information by email about our services that we think may interest your organisation (you can opt out at any time);
  • to keep records of enquiries and dealings with us, and a database of our contractors;
  • to outsource selected website administration functions to third parties; and
  • to monitor, evaluate, administer, support, keep secure and improve the Site and our communications with you.
5.4 Legal obligations and legal claims

We may also process your personal data to meet our legal and regulatory obligations; to deal with legal claims, requests and investigations (including requests under data protection law and requests for disclosure by competent authorities); and where necessary to establish, exercise or defend legal claims.

5.5 Your right to object to direct marketing

You have the right to object at any time to our use of your personal data for direct marketing, and we will stop. You can do this by using the unsubscribe link in any of our emails or by contacting us at info@labrys.tech.

6. Who we share your personal data with

We share personal data only where there is a legitimate reason to do so, including with:

  • service providers who help us run our business and the Site, such as our website host, our email and mailing-list provider, Zendesk (our customer support and website chat provider), Google (Google Analytics) and IT and communications providers, who act on our instructions;
  • other companies in our group, including Labrys Group Holdings Limited, where needed for administration and reporting;
  • our customers, where you are involved in services we provide to them;
  • our employees, agents, contractors and professional advisers (such as lawyers, accountants and auditors);
  • regulators, authorities and law enforcement agencies, where we are required by law or it is necessary to protect our rights or those of others; and
  • prospective buyers of all or part of our business, under our legitimate interests in ensuring the business can continue.

We do not sell your personal data.

7. International transfers

We are based in the UK. Our website is hosted by Webflow, Inc. in the United States. Some of our service providers, including Webflow, Google, Microsoft and Zendesk, may process your personal data outside the UK, including in the United States. Where this happens, we make sure appropriate safeguards are in place, such as UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework), or the ICO's International Data Transfer Agreement or Addendum. You can contact us for more information. We may also transfer personal data to customers, contractors or partners outside the UK where this is necessary to provide our services or to perform a contract with you. Where we do, we use the safeguards above or, where they do not apply, an exception permitted by data protection law.

8. How long we keep your personal data

We keep personal data only for as long as we need it for the purposes in this notice, and then delete or anonymise it. How long that is depends on the type of data and why we hold it:

  • Axiom waitlist and updates: until you unsubscribe, or for a limited period after Axiom's public launch. If you unsubscribe, we keep your email address on a suppression list so that we don't contact you again.
  • Enquiries, correspondence and website chats: for as long as needed to deal with your enquiry and any follow-up.
  • Customer, supplier and contractor records: for the length of our relationship and afterwards for as long as needed to meet legal, tax and accounting requirements and to deal with any legal claims.
  • Analytics data: in line with the retention settings of our analytics provider.

We may keep personal data for longer where the law requires it.

9. Cookies

We use cookies and similar technologies (such as local storage) on the Site:

  • Strictly necessary: these are needed for the Site to work securely and to remember your cookie choices. They do not require your consent.
  • Website chat: if you accept cookies, we load our website chat, provided by Zendesk. It stores identifiers in your browser so that your conversation stays open as you move between pages and you can return to it later. If you decline, the chat will not load, but you can still contact us by email at info@labrys.tech. You can change your choice at any time using the Cookie Settings link on the Site.
  • Analytics: we use Google Analytics to understand how visitors use the Site, such as the number of visitors and the pages they view, so that we can improve it. These cookies are not essential, and we only set them if you accept them.

You can accept or reject non-essential cookies using our cookie banner. Refusing non-essential cookies will not affect your ability to use the Site.

10. Your rights

Depending on where you live, you may have some or all of the following rights. Under UK data protection law you have the right to:

  • access, and receive copies of, the personal data we hold about you;
  • have inaccurate personal data corrected;
  • have your personal data erased in certain circumstances;
  • restrict our processing of your personal data in certain circumstances;
  • receive the personal data you have provided to us in a portable format;
  • object to processing based on our legitimate interests, on grounds relating to your particular situation;
  • object at any time to direct marketing (see section 5.5);
  • withdraw your consent at any time, where we rely on consent (this does not affect our processing before you withdraw); and
  • complain to the Information Commission Office (www.ico.org.uk), or the data protection authority where you live. You can also complain to us directly; we will handle your complaint in accordance with our complaints policy and acknowledge it within 30 days of receipt.

These rights are not absolute, and exemptions may apply. If your organisation gives you access to Labrys services, your use may also be subject to your organisation's own policies, and you may wish to contact your organisation's administrator first.

11. Security

We use appropriate technical and organisational measures to protect your personal data, including encryption, access controls and secure hosting. No method of transmission over the internet is completely secure.

12. Age

The Site and the Axiom waitlist are intended for people aged 18 or over. We do not knowingly collect personal data from children.

13. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. The latest version will always be on the Site. This Privacy Notice was last updated in November 2026.

Privacy Notice
Axiom app

1. Who we are

Labrys Technologies Limited is a private limited company incorporated in England and Wales with company number 12728244, whose registered office is at 3rd Floor, 86-90 Paul Street, London EC2A 4NE (Labrys, we, our, us).

Labrys is the controller of the personal data described in this notice, except where we explain otherwise in section 5. We are registered with the Information Commissioner's Office (ICO) under registration number ZB530167.

Labrys provides the Axiom secure communications app (the App) and related software to individuals, commercial organisations, NGOs and government customers around the world.

2. Contact us

If you have any questions about this Privacy Notice, or would like to exercise your data protection rights, please contact us:

  • by email: info@labrys.tech, or our Data Protection Officer at dpo@labrys.tech
  • by post: Data Protection Officer, Labrys Technologies Limited, 3rd Floor, 86-90 Paul Street, London EC2A 4NE.

3. About this Privacy Notice

This Privacy Notice explains how we collect, use and share personal data when you download and use the App from the Apple App Store or Google Play, and what rights you have. It applies wherever you are located. Everyone who uses the App downloads it to their own device and controls the permissions they give it, including camera and location access.

The App is only for adults aged 18 or over. See section 8 for more information.

You may use the App in one or more of the following ways. What we do with your personal data, and who is responsible for it, depends on which applies:

Individual use

You download the App and use it yourself, for example to chat, join groups and share your location with people you choose. Labrys is the controller of the account and service data described in this notice.

Through your organisation (Enterprise)

Your employer or another organisation (an Enterprise Customer) has a subscription with us that adds users or unlocks extra functionality. You still download the App from the app store, but your organisation decides how those features are used, including any location sharing between its staff or users. See section 14.

4. How Axiom protects your communications

The App is built on the "Matrix" open standard and uses end-to-end encryption (E2EE). The content of your messages, including text, photos, videos, and location information you share, is encrypted on your device. It can only be decrypted on the devices of the people you send it to.

The encryption keys that unlock your content are generated and stored on your device, in its secure hardware, and are not held by Labrys. This means Labrys cannot read your messages, view your photos, videos, or see your location. Our servers only store and pass on content in encrypted form.

For the service to work, our servers need to process some information that is not end-to-end encrypted (service data). This is:

  • your Axiom ID user handle, display name and profile picture;
  • the names of groups you are in, who is in them (i.e. their AXIOM ID user handle and display name)), and who you are connected with;
  • who sent a message to whom, in which conversation or group, and when (timestamps and message identifiers);
  • online/offline status, read receipts and typing indicators;
  • technical information about your devices, including device identifiers and the public encryption keys other users need to send you encrypted messages; and
  • your IP address and connection information.

We use service data only for the purposes set out in section 6. Your handle, display name and profile picture are also visible to other users you connect with or share a group with.

5. Our role

Under data protection law, the controller decides why and how personal data is used. A processor uses personal data only on a controller's instructions. Our role is dependent on how you use our app:

Individual use

Labrys' role: Controller of your account and service data.

Other party's role: The people you choose to communicate with, or share your location with, receive that content directly.

Enterprise use

Labrys' role: Controller of your App account, security and service data.

Processor for the Enterprise Customer where we host the service on its behalf where an Enterprise Customer hosts the service itself, Labrys may not process this data at all.

Other party's role: Your organisation is the controller of how the App is set up and used within it, including location sharing between its staff or users.

6. What personal data we collect and why

Where Labrys is the controller, we use personal data as follows:

Checking you are 18 or over

Personal data: Information needed for the age check, depending on the method used: e.g. your declaration of being 18 or over. We keep only the outcome of the check.

Lawful basis: To comply with our legal obligations in relation to online safety and regulatory legislation and legitimate interests in keeping children off an adult service.

Creating and managing your account

Personal data: Your Axiom ID user handle, password (stored in hashed form), email address, a display name and optional profile picture.

Lawful basis: Our contract with you, so that we can fulfil our obligations and provide the App to you.

Connecting with other users

Personal data: Your Axiom ID, which other users can connect to by entering it exactly, or add by scanning your QR code or opening your connection link. We also process your connection requests and contacts list.

Lawful basis: Our contract with you, so that we can fulfil our obligations and provide the App to you..

Providing messaging and groups

Personal data: Service data (section 4). Message content is end-to-end encrypted and not accessible to us.

Lawful basis: Our contract with you, so that we can fulfil our obligations and provide the App to you..

Push notifications

Personal data: Device push token and notification metadata passed to Apple (APNs) or Google (Firebase Cloud Messaging)

Lawful basis: Our contract with you, so that we can fulfil our obligations and provide the App to you and your consent to the extent that your consent is obtained to send marketing notifications. You can turn notifications off or opt out of marketing notifications in your device settings.

Camera, photos and verified media

Personal data: Photos, videos you capture or choose from your device (end-to-end encrypted). For verified media.

Lawful basis: Our contract with you, so that we can fulfil our obligations and provide the App to you.

Map layers

Personal data: To display maps, the App requests map tiles and layers from Mapbox.

Lawful basis: Our contract with you, so that we can fulfil our obligations and provide the App to you.

Location sharing

Personal data: See section 7.

Lawful basis: We rely on your consent. Your consent can be withdrawn at any time.

Handling reports from users

Personal data: Your details and the information you choose to include in a report, such as a description of the issue, a snapshot of the content concerned, and the handle of the account you are reporting. This may include other people's personal data.

Lawful basis: We rely on our legitimate interests in keeping the App safe and enforcing our Terms of Use. Where we have a legal obligation to handle reports on particular topics in a particular way we rely on our legal obligation where it applies.

Security, fraud and abuse prevention

Personal data: Service data, sign-in records, and device and connection logs.

Lawful basis: We rely on our legitimate interests in protecting the App, our users and our systems. We also rely on our contract with you, so that we can fulfil our obligations and provide the App to you.

Running and improving the service

Personal data: Service data used to produce statistics, such as numbers of active users.

Lawful basis: We rely on our legitimate interests in understanding and managing use of our service, improving our service and meeting our regulatory obligations.

Customer support

Personal data: Your contact details and our correspondence with you.

Lawful basis: Our contract with you, so that we can fulfil our obligations and provide the App to you. We also rely on our legitimate interests in handling and responding to your correspondence.

Reporting

You can use the report function in the App to tell us about a user or content that is harmful, abusive, illegal, or that breaches our Terms of Use or any code of conduct or acceptable use policy that we may share with you and update from time to time. Because content is end-to-end encrypted, we cannot access or decrypt conversations to investigate a report. We rely only on the information you choose to send us, which may include a snapshot of the content concerned, taken from your device. We handle reports under our internal reporting policy, and may take action such as warning, restricting or disabling an account. Where the law requires it, we may share information with the relevant authorities.

Other uses

We may also use any of the personal data above:

  • to meet our legal and regulatory obligations;
  • where it is in our legitimate interests and necessary to establish, exercise or defend legal claims;
  • as part of a merger, acquisition or sale of our business, where it is in our legitimate interests to allow the business to continue; and
  • with your consent, where we ask for it.

We do not use your personal data for advertising, and we do not sell it.

We will update this Privacy Notice before we introduce new features that use personal data in new ways.

7. Location sharing

Location sharing is off by default. You have to choose to share your location actively in the App, and allow location access in your device settings. You stay in control:

  • You choose who sees your location – specific people or groups – and for how long.
  • You can see who you are sharing with, and stop sharing with any of them, or everyone, at any time.
  • Nobody can request or switch on your location. Other users only see a location you have chosen to share with them.
  • Your location is end-to-end encrypted. It is sent only to the people you share it with. Labrys cannot see it.
  • When you stop sharing, your location will disappear from the map and the people you were sharing with will no longer see your location or your last shared location.
  • If background location is used: "If you allow 'Always' location access, the App can keep sharing your location when it is closed. You can change this at any time in your device settings."

8. Age restriction

The App is only for adults aged 18 or over. We use age checks when you sign up to confirm this (see section 6). If we learn that someone under 18 is using the App, we will close their account and delete their personal data, except where we need to keep limited information to prevent them from signing up again, or to meet legal obligations. If you believe someone under 18 is using the App, please contact us.

9. Who we share personal data with

We only share personal data where necessary and in line with this Privacy Notice. End-to-end encrypted content cannot be read by us, so we never share it in readable form. We may share personal data with:

  • Service providers who help us run the App (including but not limited to Amazon Web Services (hosting in the UK), Apple and Google (app distribution and push notifications) etc. They act on our instructions, or under their own terms where they provide a service directly to you.
  • Your organisation, where you use the App as part of an Enterprise subscription.
  • Regulators, law enforcement and other authorities, where we are legally required to share, or it is necessary to protect the rights, property or safety of our users, us or others.
  • Professional advisers, such as lawyers, auditors and insurers and other advisors that we engage to provide us with advice from time to time.
Groups and messages

Where you are in a group, any member of a group can see the handle, display name and profile picture of the other members. You can be added to a group with people you are not connected with. You will need to connect with them separately before you can message them directly. Group admins can choose whether only admins, or all members, can add people to the group.

You can delete a message or media for everyone after sending it. Please remember that recipients can forward messages and media you send them to other people, including outside the original conversation or group.

10. Where your data is processed

We store and process your personal data in the UK, on third party servers. Messages, media and location you share are delivered to the people you send them to, wherever they are in the world.

Some service providers that deliver the App to you, such as Apple and Google for push notifications and maps, may process limited technical data outside the UK. Where that happens, we rely on appropriate safeguards, such as UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework) or the ICO's International Data Transfer Agreement or Addendum.

11. How long we keep personal data

We will only retain your personal data for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.

We may anonymise data so that it can no longer be linked to you, and use it to improve our services.

You can delete your account at any time in the App under [Settings > Account > Delete account]. Messages you have already sent to others will stay on their devices.

12. Security

In addition to end-to-end encryption, we protect personal data with measures including hardware-backed key storage on devices, encryption in transit (TLS) and at rest, access controls and multi-factor authentication, network segmentation, logging and monitoring. Labrys holds ISO/IEC 27001 certification. Links in messages are shown in full, and you are warned before leaving the App, to help protect you from misleading links. No system is completely secure, so please keep your device and recovery key safe, and verify new devices when prompted.

13. Device permissions and analytics

The App will ask for your permission before accessing the following features of your device. You can change these permissions at any time in your device settings:

Camera

To take photos and videos in the App, including verified media, and to scan other users' QR codes to connect.

Photos / media library

To let you share existing photos and videos from your device.

Location

To share your location with people you choose, and to show your position on the map.

Notifications

To tell you about new messages and activity.

14. Using the App through your Organisation

This section explains in a bit more detail how your personal data is used if you access the App through an Enterprise Customer's subscription.

Using the App through your organisation

Where an Enterprise Customer gives you access to the App, it may unlock additional features and decide how they are used within the organisation. Your organisation's account owners can turn paid features on or off for users in the organisation. Nobody else, including your organisation, can view or change the data in your account, or read your end-to-end encrypted content unless they are a member of the conversation.

Please direct questions about how your organisation uses the App, and requests to exercise your rights over that data, to your organisation first. We will help it respond where we act as its processor.

Location sharing

Enterprise use. If your organisation asks you to share your location through the App, for example for staff safety while travelling, it is your organisation that decides this and sees your location, not Labrys. Your organisation is responsible for telling you how it uses your location, and on what basis.

15. Your rights

Depending on where you live, you may have some or all of the following rights. Under UK data protection law you generally have the right to:

  • access, and receive copies of, the personal data we hold about you;
  • have inaccurate personal data corrected;
  • have your personal data erased in certain circumstances, including by deleting your account in the App;
  • restrict how we use your personal data in certain circumstances;
  • object to our use of your personal data where we rely on legitimate interests;
  • withdraw consent at any time where we rely on it, for example for location sharing or analytics (this does not affect our use of your data before you withdraw);
  • receive the personal data you have given us in a portable format; and
  • complain to the Information Commission Office (www.ico.org.uk), or the relevant data protection authority for where you live. You also have the right to complain to us directly, we will handle any complaint we receive in accordance with our complaints policy and will acknowledge your complaint within 30 days of receipt.

Because your content is end-to-end encrypted, we do not hold it in readable form and so cannot provide copies of your messages, media or location history. You can access these on your own devices. Where you use the App through an organisation for which we are a processor, please contact that organisation first.

These rights are not absolute, and exemptions may apply.

16. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. We will tell you about significant changes through the App before they take effect.

This Privacy Notice was last updated in November 2026.

Privacy Notice

Axiom Applications
Axiom Communicator
Axiom C2
Axiom X

1. Who are Labrys?

Labrys Technologies Limited is a private limited company incorporated in England and Wales with company number 13995716 (Labrys, we, our, us).

Labrys is a UK-based software company providing services to a broad range of commercial, NGO and government customers. We process personal data to deliver secure, reliable services.

2. Contact Us

If you have any questions about this Privacy Notice, or if you would like to exercise any of your legal rights in respect of your personal data, please contact us by emailing support@labrys.tech, or writing to us at our registered office: 3rd Floor 86-90 Paul Street London EC2A 4NE

3. When does this Privacy Notice apply?

This Privacy Notice explains how Labrys (or the Labrys affiliate company with whom you interact) collects, uses and shares your personal data, and your rights in relation to that personal data when you use the Axiom Communicator or Axiom X Application (the App) in one or more of the following capacities:

  • · Customer Users: Individuals who are an employee or contractor of our Customers (defined below), and have been on-boarded by the Customer to use the App.
  • · Commercial Users: Individuals who are not employed or contracted by a Customer, but who may engage with, and complete tasks submitted by, Customers using the App.
  • · Personal Users: Individuals who use the App in their personal capacity.

4. How we use your personal data

We may work with our customers who engage us to provide our services (Customers), acting as their data processor or an independent data controller. We make clear where we are acting as a data processor or data controller in each section below.

For the processing activities below where we are acting as a data processor to our Customer as the data controller, the Customer is responsible for determining the lawful basis for processing this personal data, and the condition for processing special category data. We may ask for your consent, and where necessary explicit consent, on our Customer's behalf, acting on their instructions as their processor.

Whilst we have included information about our processing as a processor in this Privacy Notice, please note that your use of our App in these circumstances will be subject to the Customer's own privacy notices and internal policies, if any. You should therefore direct your data protection queries, including any requests to exercise your data protection rights, to the relevant Customer in the first instance.
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KYC Checks

· As a data processor - Customer Users: As part of our managed services we provide to Customers we may verify your identity for know-your-customer (KYC) checks, acting on our Customers' instructions. To perform this service, we will process your name, information contained within your national identification document(s) – for example a passport or driving licence (such as your date of birth, nationality and address), and biometric data collected from a live facial recognition scan to check your identity. We will share the outcome of the identity checks, including the documentation you provide, with our Customer to meet their own regulatory requirements or security protocols.

· As a data controller - Commercial Users: We may verify your identity for our know-your-customer (KYC) checks to ensure we can assign you to relevant tasks. To complete these checks we will process your name and information contained within your national identification document(s), such as your date of birth, nationality and address, and biometric data collected from a live facial recognition scan to check your identity, because it is in our legitimate interests to check our Commercial Users are who they say they are. We will process your biometric data used for the purposes of identifying you with your explicit consent.We may share the outcome of the identity checks (on a 'Pass' / 'Fail' basis) and, with your consent, the documentation you provide, with our Customers to meet their own regulatory requirements or security protocols before they can assign you to a task.

· No personal data processed by us – SaaS Offering: We also offer the functionality for our Customers to carry out KYC checks under our software as a service (SaaS) offering. Here all personal data remains on our Customers' infrastructure, meaning we do not process any personal data relating to KYC checks under our SaaS offering

Creation of User Accounts

· As a data processor - Customer Users: If our Customer asks us to create an account for you we will, on their behalf, collect your name, photograph and contact information.

· As a data controller - Commercial Users and Personal Users: When you ask us to create an account for you we will collect your name, photograph and contact information. We collect this personal data under our contract with you to provide our services.

· As a data controller - Personal Users (Children): Where you as a Personal User ask us to create an account for your child, we will collect your child's name, photograph and contact information. We collect this personal data with your consent as your child's parent or guardian

Assignment of Tasks

· As a data processor - Customer Users: To help our customers identify appropriate tasks for you we may, at our Customer's direction, collect your contact details, information from your social media profiles, information about your media, political, security and societal experience, information about your relationships with others in certain locations, sectors,groups or fields of expertise, and information about your political options and religious or philosophical beliefs.

· As a data controller - Commercial Users: To help us identify appropriate tasks for you received from our Customers we may collect your contact details, information from your social media profiles, information about your media, political, security and societal experience, and relationships with others in certain locations, sectors, groups or fields of expertise. We collect this information because it is in our legitimate interests to assign you to appropriate tasks issued by our Customers. We may also collect information about your political options and religious or philosophical beliefs. We collect this personal data with your explicit consent, or because the processing is necessary for reasons of substantial public interest.

Faciliation of Payments

· As a data controller - Commercial Users: You may choose to provide us with either your bank account details or crypto wallet address for us to facilitate payments from Customers for the completion of a task. We collect this information under our contract with you to facilitate payments.

Location Tracking

To enable location tracking in our app so that the App can track your location, even when it is closed or not in use, we may ask you to consent to our App continually collecting your precise location data.

· As a data processor – Customer Users: This will enable our Customers to manage critical features such as real-time location sharing and emergency coordination and response to protect your safety. Your precise location will be visible to us as a data processor and our Customer (your employer) as the data controller.

· As a data controller – Commercial Users and Personal Users: We collect this information with your consent so that you can share your location with others. Your precise location will be visible to us as controller and any others who you choose to share access with.

· As a data controller – Personal Users (Children): We will collect this information with your consent as the child's parent or guardian. Your child's precise location will be visible to us as the controller and any others who you choose to share this information with.

Cookies

· As a data controller – All Users: When you use our App and consent to our use of cookies we may collect information provided to us through cookies when you browse the App, such as your internet protocol (IP) address, operating system, browser version, the date and time of connection, the content viewed during a particular browsing session, and how long you stayed on a particular page. We may use your personal data contained within this information to keep our App secure, to improve our App, and to better understand how people use them. More details on the information we collect and how we do this is set out in our Cookie Policy.

Wider Permitted Processing

We may also process any of your personal data detailed above:



· to meet our legal obligations, including in order to comply with any requirement of any applicable statute, regulation or regulatory rule to which we are subject;

· as part of a merger or acquisition, where it is in our legitimate interest to ensure our business can be continued by the buyer;·

where it is in our legitimate interests, and necessary for the establishment, exercise or defence of legal claims (for example, to protect and defend our rights, property, or those of any affiliates); and


· where we have your consent, including, where necessary, explicit consent for the processing of special category data, to do so.

5. Who do we share personal data with?

We only share personal data when it is necessary and in accordance with this Privacy Notice. For instance, we may share your personal data with:

  • · Service providers, to facilitate the provision of our services, relying on the relevant lawful basis detailed above.
  • · Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our, our customers' and others' rights. This includes exchanging your personal data with other companies and organisations for the purposes of fraud protection.
  • · Prospective buyers of our business under our legitimate interests to ensure our business can be continued by the buyer.

6. International transfers of data outside of the United Kingdom

Your personal data is generally only processed by us within the UK and/or European Economic Area (EEA). An adequacy decision exists in respect of transfers between the United Kingdom and the EEA. This means that the countries in the EEA to which we transfer your data (if at all) are deemed to provide an adequate level of protection for your personal data. As a matter of course, we do not transfer your data outside the EEA.

We may, however, transfer your personal data around the world where necessary, for example where this is necessary for the performance of our services. In such circumstances, we will ensure any necessary safeguards are in place to give adequate protection for the personal data when it is transferred. To keep this notice as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us using the details above for more information about this.

7. How long is your personal data kept

We retain your personal data only as long as necessary to fulfil the purposes outlined in this Privacy Notice, unless a longer retention period is required by law.

Specifically, we will only retain information from your national identification documents and your biometric data for the duration of your continued use of our App, after which it will be securely deleted.

In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work and our services.

8. Security of personal data

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include encryption, secure servers, and access controls. However, no method of transmission over the internet or electronic storage is 100% secure.

9. Cookies

Our App uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our App and also helps us make improvements.A cookie is a small file of letters and numbers that we store on your browser or in your device's storage. We only use (and store) non-essential cookies if you provide your consent.

We use the following cookies:

Cookie
Purpose
Duration
More Information

Google Analytics

This helps us understand how you use the App and helps us to improve your experience. These cookies may track how long you spend on the App and the pages you visit.

The retention period will be between 1 minute and 2 years depending on the type of cookie used.

Google Analytics

10. Your Rights

Under data protection legislation, you have the following rights in relation to our processing of your personal data:

· to obtain access to, and copies of, the personal data that we hold about you;

· to require us to correct the personal data we hold about you if it is incorrect;

· to require us to erase your personal data in certain circumstances;

· to require us to restrict our data processing activities in certain circumstances;

· where our processing is based on your consent, to withdraw that consent (please note this does not affect the lawfulness of our processing based on consent before its withdrawal);



· to receive from us the personal data we hold about you which you have provided to us, in a reasonable format, including for transmitting that personal data to another data controller;


· to object to any of our processing activities where you feel this has a disproportionate impact on your rights; and



· to complain about the processing of your personal data to the Information Commissioner’s Office (ICO)
(www.ico.org.uk), although the ICO recommends that you first try and resolve the complaint with us.

Please note that the above rights are not absolute, and we may be entitled (or required) to refuse your requests where exceptions apply. For example, if we have reason to believe that the personal data we hold is accurate or we can show our processing is necessary for a lawful purpose set out in this Privacy Notice.

11. Updating the Privacy Notice

We may modify this Privacy Notice at any time. Please check back periodically for updates. Any significant changes will be communicated through the App.

This Privacy Notice was last updated in October 2025.