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Privacy Notice

Last updated: August 2026  ·  Version 2.1  ·  UK GDPR Article 13 compliant

🔒 Short version: If you create an account, your email address and saved compliance reports are stored securely in Google Cloud Firestore, hosted in London, UK (europe-west2). Documents submitted for analysis are processed by Google’s Gemini AI and not retained after analysis. Documents you save to My Library are stored securely in Firestore, London UK. You can delete your account and all saved data at any time.

1. Who We Are

Data Controller: Privacomply Ltd

DPO / Responsible Person: David Anderson, CIPP/E, CIPM (Data Protection Officer)

Email: privacy@privacomply.co.uk

Website: childsafe-ai.privacomply.co.uk

ChildSafe AI is a compliance assessment tool for organisations that process children’s data. It is operated by Privacomply Ltd and designed by an IAPP-certified privacy professional.

2. What Data We Process and Why

2.1 Document Content You Submit

When you run a compliance analysis, the first 4,000 characters of your document are transmitted to Google’s Gemini AI via our serverless function. This content is:

⚠️ Please do not submit documents containing personal data (e.g., individual names, email addresses). ChildSafe AI is designed for policy documents and compliance reports, not personal records.

2.2 Account and Cloud Data (if you sign in)

ChildSafe AI offers optional user accounts via Google Sign-In (Firebase Authentication). If you create an account, the following data is collected and stored in our cloud database, hosted in London, UK:

DataWhat’s storedLocationRetention
Email addressYour Google account email, used for authentication and account identification🇬🇧 Firebase Auth, London UKUntil you delete your account
Firebase User ID (UID)Anonymised unique identifier assigned by Firebase at sign-up🇬🇧 Firebase Auth, London UKUntil you delete your account
Compliance reportsSaved analysis results: scores, findings, framework assessments, article and standards breakdowns. No document content is stored.🇬🇧 Firestore, London UK (europe-west2)Until you delete the report or your account
Report metadataDocument name (as entered by you), date of analysis, risk level, frameworks assessed🇬🇧 Firestore, London UK (europe-west2)Until you delete the report or your account
Documents saved to My LibraryThe full content of documents you explicitly save to My Library for future reference🇬🇧 Firestore, London UK (europe-west2)Until you delete the document or your account

If you do not sign in, no account data is collected. The tool operates fully without an account; reports are stored in your browser only.

2.3 Data Stored in Your Browser (localStorage)

The following data is stored in your browser only — it never leaves your device via our systems:

KeyWhat’s storedRetention
childsafe_ai_historyUp to 25 analysis summaries: document name, score, risk level, framework tags, date. No document content.Until you clear browser data
childsafe_welcome_seenWhether you have seen the onboarding modalUntil you clear browser data
childsafe_ai_reviewersReviewer registry: name, qualifications, hashed PIN (SHA-256), review countUntil you clear browser data
childsafe_audit_logAnonymised audit entries: timestamp, framework IDs, document type, risk band. No document content. No names.Last 50 entries (FIFO)

2.4 Server / Hosting Logs (Netlify)

Our hosting provider Netlify automatically records standard access logs including your IP address, request timestamp, and response size. These logs are retained for 30 days and are governed by Netlify’s privacy policy.

3. Lawful Basis

Processing activityLawful basis
Transmitting document content to Gemini API for analysisLegitimate interests (Article 6(1)(f)) — you actively submit the document; processing is necessary to deliver the service you requested
Creating and managing your user account (email, UID)Contract (Article 6(1)(b)) — processing is necessary to provide the account-based service you have signed up for
Storing compliance reports in FirestoreContract (Article 6(1)(b)) — report persistence is a core feature of the signed-in service you have requested
Storing My Library documents in FirestoreContract (Article 6(1)(b)) — My Library document storage is a core feature of the signed-in service; users explicitly choose to save documents and retain full control to delete them at any time
Netlify access logs (IP, timestamp)Legitimate interests — security, abuse prevention, service operation
Browser localStorage (history, reviewers, audit log)Legitimate interests — functionality and audit capability; all stored locally under your control

4. Retention

DataRetention
Document content submitted for analysisSession only — discarded immediately after analysis. Zero server-side retention.
User account (email, UID)Retained until you delete your account. Request deletion: privacy@privacomply.co.uk
Saved compliance reports (Firestore)Retained until you delete individual reports or your account.
Documents saved to My LibraryRetained until you delete the document or your account. Deletable within the app.
Browser localStorageRetained until you clear your browser data. You are in full control.
Netlify access logs30 days (Netlify standard)

5. Processors and Data Location

🇬🇧 All personal data is stored and processed in the United Kingdom (London). Our cloud database (Firestore) and authentication service (Firebase Auth) are configured to use Google Cloud’s europe-west2 (London) region. No personal data is transferred outside the UK.

ProcessorProcessing LocationPurposeSafeguard
Google Cloud / Firebase Authentication🇬🇧 London, UK (europe-west2)User authentication — Google Sign-In, account managementUK-region configuration; governed by Google Cloud DPA.
Google Cloud / Firestore🇬🇧 London, UK (europe-west2)Cloud database — storing compliance reports, metadata, and My Library documentsUK-region database; governed by Google Cloud DPA. Data does not leave the UK.
Google Gemini API🇬🇧 London, UK (europe-west2)Processing of document content for compliance analysis. Document content transmitted in-session only and not retained after response.Governed by Google AI API Terms and UK GDPR Data Processing Addendum.
Netlify Inc.UK/EU CDN edgeHosting, CDN, serverless function proxyNetlify DPA; transit proxy only — no content storage.

International Transfers

All personal data is stored in Google Cloud’s London (europe-west2) region. No personal data is intentionally transferred outside the United Kingdom. Should any incidental transfer occur via CDN infrastructure, Standard Contractual Clauses (SCCs) apply via both processors’ DPAs.

6. Your Rights

As a UK data subject, you have the following rights under UK GDPR:

To exercise any right, contact: privacy@privacomply.co.uk

You also have the right to lodge a complaint with the ICO: ico.org.uk/make-a-complaint

7. Automated Decision-Making

ChildSafe AI produces AI-generated compliance assessments. These are advisory outputs only and do not constitute automated decisions about individuals under Article 22 UK GDPR. All compliance certificates require human expert review and sign-off before they are issued.

8. Cookies and Session Storage

ChildSafe AI uses the following browser storage mechanisms:

We do not use any advertising, analytics or third-party tracking cookies.

9. Children

ChildSafe AI is a professional compliance tool intended for use by organisations and privacy professionals. It is not directed at children and we do not knowingly collect data from individuals under 18.

10. Changes to This Notice

Version 2.1 (August 2026) reflects the introduction of Firebase user accounts and Firestore cloud report storage in London, UK, and clarifies My Library document storage. The version number and date at the top of this page reflect the current version.

11. Contact

For any privacy questions: privacy@privacomply.co.uk

For general enquiries: privacy@privacomply.co.uk

ChildSafe AI Privacy Notice v2.1 · August 2026 · Privacomply Ltd · Designed by David Anderson CIPP/E CIPM