Privacy Policy

1. Introduction

Intellectual Apps UK Ltd. ("we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and protect your information when you use Intntnl ("the App").

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Name, email address, and other registration details
• Contact Data: Names, phone numbers, email addresses, and other contact information you choose to store
• Interaction Logs: Records of interactions you manually log with your contacts
• User-Generated Content: Notes, comments, and other content you create within the App

2.2 Information Collected Automatically

• Device Information: Device type, operating system version, unique device identifiers
• Usage Data: App usage patterns, features accessed, session duration
• Technical Data: App performance metrics, crash reports, error logs

2.3 Information We Do Not Collect

• We do not access your device's contact list
• We do not collect your device's location data
• We do not collect biometric information
• We do not access other apps on your device

3. How We Use Your Information

3.1 Primary Purposes

• Service Provision: To provide core app functionality including contact management and interaction tracking
• Reminders and Notifications: To send you follow-up reminders based on your preferences
• AI Suggestions: To generate communication suggestions (processed without sending personal identifying information data to external AI services)
• Account Management: To maintain and secure your account

3.2 Secondary Purposes

• App Improvement: To analyse usage patterns and improve app functionality
• Customer Support: To respond to your inquiries and provide technical support
• Legal Compliance: To comply with applicable laws and legal obligations

4. AI Processing and Data Protection

4.2 AI Data Safeguards

• Personal identifiers are not included in any AI processing
• All AI processing occurs within secure, isolated environments

5. Information Sharing and Disclosure

5.1 We Do Not Sell Your Information

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

5.2 Limited Sharing Scenarios

We may share your information only in the following circumstances:

• With Your Consent: When you explicitly agree to sharing
• Service Providers: With trusted third-party service providers who assist in app operations (under strict confidentiality agreements)
• Legal Requirements: When required by law, court order, or government request
• Safety and Security: To protect our rights, property, or safety, or that of our users
• Business Transfers: In connection with a merger, acquisition, or sale of assets (with user notification)

5.3 Third-Party Services

• The App may integrate with third-party services (with your consent)
• Each third-party service has its own privacy policy
• We are not responsible for third-party privacy practices

6. Data Storage and Security

6.1 Data Storage

• Local Storage: Most data is stored locally on your device
• Cloud Backup: Optional cloud backup services (with encryption)
• Data Retention: We retain data only as long as necessary for service provision

6.3 Data Protection Rights

Depending on your location, you may have rights including:

• Access: Right to access your personal information
• Correction: Right to correct inaccurate information
• Deletion: Right to request deletion of your information
• Portability: Right to receive your data in a portable format
• Objection: Right to object to certain data processing

7. Apple App Store Privacy Requirements

7.1 App Store Compliance

This app complies with Apple's App Store privacy requirements:

• Privacy Labels: Accurate privacy labels are provided in the App Store listing
• Permission Requests: The app only requests necessary permissions with clear explanations
• Data Minimisation: We collect only the minimum data necessary for functionality

7.2 iOS Privacy Features

• App Tracking Transparency: We comply with iOS tracking transparency requirements
• Privacy Report: The app is compatible with iOS Privacy Report features
• Permission Management: Users can manage permissions through iOS settings

8. Children's Privacy

8.1 Age Restrictions

• The App is not intended for children under 13 years of age
• We do not knowingly collect information from children under 13
• If we become aware of such collection, we will delete the information immediately

8.2 Parental Notice

If you believe your child has provided information to us, please contact us immediately.

9. International Data Transfers

9.1 Cross-Border Transfers

• If you use the App from outside the United Kingdom, your information may be transferred to and processed in the United Kingdom
• We ensure adequate protection for international transfers through appropriate safeguards

10. Your Choices and Controls

10.1 Account Controls

• Profile Management: Update your account information at any time
• Data Export: Request a copy of your data
• Account Deletion: Delete your account and associated data

10.2 Communication Preferences

• Notifications: Control push notifications through app settings
• Reminders: Customise reminder frequency and timing

10.3 Data Processing Controls

• AI Suggestions: Ignore AI suggestions if preferred

11. Data Breach Notification

In the event of a data breach that may affect your personal information:

• We will notify affected users promptly
• We will provide details about the breach and steps being taken
• We will offer guidance on protecting your information

12. Changes to This Privacy Policy

12.1 Policy Updates

• We may update this Privacy Policy periodically
• Material changes will be announced through the App or email
• Continued use after changes constitutes acceptance

12.2 Version History

• Previous versions of this policy are available upon request

13. Contact Information

14. Legal Basis for Processing (EU/UK Users)

For users in the European Union or United Kingdom, we process your data based on:

• Consent: Where you have given explicit consent
• Contract: To fulfill our contract with you (providing the app service)
• Legitimate Interests: For app improvement and security (where not overridden by your privacy rights)
• Legal Obligation: To comply with applicable laws

15. Regional Privacy Rights

15.1 California Residents (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt out of sale (note: we do not sell personal information)
• Right to non-discrimination for exercising these rights

15.2 European Union/UK Residents (GDPR)

EU/UK residents have rights under GDPR including:

• Right of access, rectification, erasure
• Right to data portability
• Right to object to processing
• Right to restrict processing
• Right to lodge complaints with supervisory authorities