Privacy Policy – CC London Alerts

1. Who we are

1.1 CC London Alerts (the "App") is provided by Brilllabs (brilllabs.com), an independent developer ("Brilllabs", "we", "us", "our"). We are not Transport for London (TfL) and are not affiliated with it.

1.2 Contact: hello@brilllabs.com.

1.3 This policy explains what personal data the App handles, where, why, for how long, and what choices you have. It forms part of our Terms and Conditions, and words defined there ("Zones" and so on) have the same meaning here. "Personal data" has the meaning given in the UK GDPR.

2. How the App is built for privacy

2.1 On-device by design. The App decides whether you are approaching, entering or leaving a Zone entirely on your device, using the zone boundaries that are bundled inside the App. Your position is not needed by any server, so none is sent.

2.2 We do not receive your data. The App has no account or sign-in, does not ask for your name, email address, phone number or payment details, and does not send usage data, analytics, crash reports or location to us. We use no advertising or analytics software, and no third-party software development kits that collect data about you.

2.3 Our role. Because the personal data the App uses (mainly your location) is processed only on your own device and is never provided to us, we do not hold it and cannot look at it. Where this policy says "the App" processes something, it is your device doing so.

2.4 This may change in future. We reserve the right to change our privacy and data policy and how the App handles data. Such a change could mean that some data is transferred off your device to us or to service providers we choose, for example to add accounts or sign-in, syncing between devices, analytics, crash reporting, advertising, subscriptions or other paid features, or new features that need a server. Our Terms and Conditions already say we may add subscriptions and adverts in future. Before any such change takes effect we will update this policy, say what data would be collected or transferred, why, who would receive it, where it would be held and for how long, and what choices you have; we will tell you in advance (in the App or by email). We may not ask for your consent separately. To the extent the law allows, once you have been told of a change, your continued use of the App after it takes effect means you accept it. Where the law requires us to obtain your explicit consent in a particular way (for example for certain uses of location data or for non-essential tracking technologies), we will ask for it in the way the law requires. Until then, the statements in this policy that data stays on your device apply. If you do not agree to a change, you can stop using the App, withdraw permissions, and delete the App and its data before it takes effect.

3. What data the App uses, and why

• Precise location, including in the background: Your device's GPS and network position, read while monitoring is on. Why: To work out how close you are to a Zone and to alert you. Where it goes: Processed on your device. Not sent to us or anyone else by the App. Not stored as a route or trail.
• Zone entry and exit marks: The position where the App detected you entering or leaving a Zone (Congestion Charge and, if switched on, ULEZ). Why: So that "View on map" in Recent events can show where it happened. Where it goes: Stored on your device only; the newest 50 of each kind are kept; removed by "Clear history".
• Event history: The time, kind (approaching, close, entered, left and so on), rounded distance to the boundary, accuracy, and whether a notification was shown. No coordinates. Why: To show your Recent events. Where it goes: Stored on your device; the newest 200 events are kept; removed by "Clear history".
• History-clearing record: When you last cleared the history and how many events were removed. Why: Shown to help with diagnosis. Where it goes: Stored on your device.
• Your settings: Alert distances, which alerts are on, sounds, repeats, units, banner options, the ULEZ option, map choice and similar. Why: So the App behaves as you chose. Where it goes: Stored on your device.
• Working state: The last zone state, the time and accuracy of recent location fixes, whether alerts are muted, and whether monitoring should restart after a reboot. Why: So alerts keep working and the App can tell you if monitoring stops. Where it goes: Stored on your device.
• Diagnostic logs: For each location update: a sequence number, the time and the accuracy; for each decision: the time, state, rounded distance and whether an alert was shown. No coordinates. Why: To check the App is working. Where it goes: Stored on your device only.
• Crash records: When a crash or freeze happened, its type, a short error message, technical call information and the App version. No location. Why: To fix faults. Where it goes: Stored on your device. Nothing is sent unless you choose to share a crash report (see 4.4).

3.1 Live position. Your current position is held only in the device's memory while the App is running so it can be drawn on the map. It is not written to a history or a route.

3.2 Legal basis (UK GDPR). To the extent the UK GDPR applies to processing on your device: the App uses your location on the basis of your consent, which you give through the operating system's permission prompts and can withdraw at any time in your device settings; and the remaining on-device processing is necessary to provide the App you asked for (performance of a contract) and, for diagnostics, our legitimate interest in keeping the App working, which does not override your privacy because that data never leaves your device.

4. What is on your device, for how long, and how to remove it

4.1 Retention. The App keeps the items in section 3 on your device only, within the limits stated there, until you remove them. It applies no other retention period because we do not hold the data.

4.2 How to remove it.

• Clear history (Recent events) removes the event history and the entry and exit marks.
• Turn off Background monitoring (Map tab or Settings) stops location updates, and the App clears any alert it was showing.
• Withdraw location, notification or "display over other apps" permission in your device's Settings (Apps > CC London Alerts > Permissions).
• Delete the App, or clear its storage in Android settings, to remove everything the App stored on the device.

4.3 Backups and transfers of data from your phone (beyond our control). The App itself never sends the data in section 3 anywhere. However, your phone's operating system and its maker can copy an app's stored data without the App or us being involved, and this is entirely outside our control. This includes: Android's backup service and Google backup to your Google account (if device backup is switched on); backups and cloud services offered by your phone's manufacturer (for example Samsung); copying or restoring data when you set up a new phone, use a phone-to-phone transfer tool or a cable or wireless transfer, or restore from a backup; and device management or "backup and restore" tools you or your employer use. If any of these apply, the App's stored data (which can include your settings, your history and the entry and exit marks, which hold coordinates) may be copied to, held by and restored from those services, under their terms and privacy policies, not ours. We cannot see, access, delete or limit those copies, and we are not responsible for how those services handle them. To control this, use your device and Google (or manufacturer) settings to switch backup off, exclude the App, or delete backups, and use Clear history in the App before you back up or transfer if you do not want the marks copied.

4.4 Crash reports. The App keeps crash records on your device. There is a "Download crash report" option on the hidden Diagnostics screen. If you use it, Android's share sheet opens and you choose where the report goes (for example, an email to us). It contains no location, and it is sent only if you choose to send it. If you send us a report, we will use it only to fix the fault, and delete it when we no longer need it.

5. Permissions the App asks for

The App asks Android for these permissions. You can refuse or withdraw them, although some features will then not work.

• Precise and approximate location: To know where you are relative to the Zones.
• Location in the background ("Allow all the time"): So alerts work when another app, such as a maps app, is in front of the App, or the screen is off.
• Foreground service (location): Android requires this to keep monitoring running in the background. It shows a small ongoing notification while monitoring is on.
• Notifications: To show your alerts.
• Display over other apps (optional): Only if you turn on the alert banner. The banner shows the alert above other apps. It cannot read what is on your screen.
• Run at start-up: To restart monitoring after your phone restarts, if you had it switched on.
• Internet and network state: To fetch map pictures (section 6.1) and to know whether the network is available.

5.1 The App does not use your camera, microphone, contacts, photos, messages, calendar or files, and does not read what other apps are doing.

5.2 Battery. Your phone's battery settings can stop background monitoring. The App shows a warning when this happens. It does not collect anything about your battery beyond what Android reports to the App on your device so it can warn you.

6. Connections to other services and other people who may receive data

The App does not send your data to us. These are the only ways any information leaves your device.

6.1 Map pictures (OpenFreeMap). The street map is drawn using the free OpenFreeMap service (tiles.openfreemap.org), built on OpenStreetMap data. In the default streaming mode, the App requests map tiles, fonts and symbols from that service as you look at the map. Each request carries your device's network (IP) address and the tile being asked for, so the service can see roughly which part of London is on screen (each tile is a few hundred metres to about a kilometre wide; the view is about 1.5 km across), and standard technical information such as the time and your device type. It cannot see your exact position, your alerts or your history. OpenFreeMap has its own privacy practices, which we do not control. See openfreemap.org.

6.2 Offline map option. In Settings > Map data you can choose Download London for offline use (about 70 MB, best on Wi-Fi). The App then downloads a fixed area of London once, the same for every user and not centred on you, and afterwards makes no network requests for the map. Deleting the download frees the space.

6.3 Zone and schedule data. The Congestion Charge and ULEZ boundaries and the bank-holiday dates are bundled in the App and are not downloaded while you use it, so getting them does not reveal anything about you. Zone data is Powered by TfL Open Data; see the Terms and Conditions for the attributions.

6.4 Google Play services and Android. The App uses Android's location services, including Google Play services' fused location provider, to obtain your position. Google may process location information in doing this under Google's own terms and privacy policy, and depending on your device settings (for example Google Location Accuracy). This is part of your phone's operating system, not something the App sends to us.

6.5 App stores. If you buy or update the App through the Apple App Store or Google Play Store, that store collects data about your account, purchase and device under its own privacy policy. We do not receive your payment details or identity from them.

6.6 Sharing. We do not sell or rent personal data, do not share it with advertisers or data brokers, and do not use it for profiling or automated decisions about you. The alerts the App shows are produced on your device from your own position and settings.

6.7 International transfers. The App itself sends nothing to us, so we make no transfers. The services in 6.1, 6.4 and 6.5, and any backup or transfer service you use (section 4.3), may store or process data outside the UK under their own arrangements.

6.8 Backups and device transfers. As explained in section 4.3, data on your phone can leave it through Android's, Google's or your phone maker's backup and transfer features. That is not something the App does or that we can control, and we are not the recipient.

7. Cookies and similar technologies

7.1 The App does not use cookies, advertising identifiers, fingerprinting or tracking pixels. It stores its own settings and history on your device, as described in section 3, because it needs them to work.

8. Children

8.1 The App is not directed at children. As set out in the Terms and Conditions, you must be at least 13 to use it, and if you are under 18 you must have a parent or guardian's permission and must only use the App as a passenger or pedestrian, never while in control of a vehicle.

8.2 We do not knowingly collect personal data from anyone, including children. If you believe a child has provided personal data to us, contact us and we will delete it.

9. Security

9.1 The App's data stays within its private storage on your device, protected by Android's app sandbox and, where your device is encrypted and locked, by your device's own security. Because we hold none of your data, there is no server-side store of it to attack. Keeping your device secure (screen lock, updates) is the most effective protection.

9.2 Connections to the map service use encrypted (HTTPS) connections.

9.3 No system is completely secure, and we cannot guarantee the security of your device or of third-party services, including any backup, cloud or transfer service you use (section 4.3).

10. Your rights

10.1 Under the UK GDPR you have rights over personal data that is held about you, including the right to be informed, to access it, to have it corrected or erased, to restrict or object to its use, to move it, and to withdraw consent at any time. Because we do not hold your personal data, most of these are exercised directly on your device: see section 4.2 to remove or stop the data.

10.2 If you send us something (for example an email or a crash report), we will hold it only to deal with your message, and you can ask us to see it or delete it by writing to hello@brilllabs.com. We will reply within one month.

10.3 You have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO): ico.org.uk, 0303 123 1113. We would be grateful for the chance to put things right first, so please contact us at hello@brilllabs.com.

11. Changes to this policy

11.1 We may update this policy, for example if the App's features or the law change, or if we change how the App handles data, including any change that means data is transferred off your device (see section 2.4). The "Last updated" date and version at the top show when. We will tell you about any material change in advance (in the App or by email). We may not ask you to accept it separately: to the extent the law allows, if you keep using the App after the change takes effect and after we have told you about it, you accept it. Where the law requires us to ask for your explicit consent, we will do so. If you do not agree with a change you may stop using the App and delete it before it takes effect.

12. Contact

12.1 Questions, requests or concerns about this policy: hello@brilllabs.com.