# Privacy Policy for iPhone – CC London Alerts Last updated: 17 October 2026 ## The short version This summary is for convenience only. The full text below applies. - Your location stays on your phone. CC London Alerts checks where you are against the zone boundaries on your device. It never sends your position to us or to anyone else. - We have no accounts, no analytics, no advertising and no tracking. We run no servers that receive data from the app, so we do not collect or hold your personal data. - The street map is the one thing that uses the internet. Unless you choose the zone outline only, the map is Apple Maps, which fetches map pictures from Apple. Apple can see your device's network address and roughly which part of London is on screen (about 1.5 km across), but not your exact position. If you switch on "Map when you are away from the zones" in Settings (it is off by default), Apple can also see roughly where in the UK you are. The same is true if you drag the map to your blue dot: the view is then centred on you, so Apple can see roughly where you are. - Some things are saved on your phone, to make the app work: your settings, a history of alerts (no coordinates), and small marks showing where you entered and left a zone (these do hold coordinates, on your phone only). You can clear the history and marks yourself. - Apple provides parts of the service (location services, iCloud backup, Apple Maps, the App Store). They have their own privacy terms; see section 6. - Backups and phone-to-phone transfers. The App asks iPhone to leave its saved data (settings, history and the entry and exit marks) out of iCloud Backup and computer backups. A few small preferences, such as your appearance choice, hold no location and may still be backed up. Moving to a new iPhone by a direct transfer, or tools you or your employer use, are outside our control; see section 4.3. - This may change in future. We may change our privacy and data practices, and that could mean some data (for example, if we add accounts, syncing, analytics, crash reporting, adverts or subscriptions) being transferred off your device. If we do, we will update this policy and tell you first. We may not ask for your consent separately: once you have been told of a change, carrying on using the App means you accept it (where the law allows). See sections 2.4 and 11. - You are in control. You can turn off background monitoring, withdraw any permission, clear your history, or delete the app at any time. - Questions? Email hello@brilllabs.com. ## 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, 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 is switched on, so it can resume when iPhone starts the App again. 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. They come from the App's own crash handler and from the crash and freeze reports iPhone itself keeps on the device and hands to the App. 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). - Battery numbers: How long location ran at each accuracy level each day, how many location fixes arrived, and the daily usage report iPhone itself gives the App (time in front and behind, CPU time, time using GPS at each accuracy, data downloaded). Numbers only, no coordinates. Why: To check the App is not using more battery than it should, shown on the hidden Diagnostics screen. Where it goes: Stored on your device (the newest 14 days of counts and 30 iPhone reports). Included in the crash report file only if you choose to share it. - Diagnostic information from Apple: If you have turned on Share With App Developers in iPhone Settings > Privacy & Security > Analytics & Improvements, Apple may share crash and usage reports about the App with us. These do not identify you and contain no location. Why: To fix faults. Where it goes: Held by Apple and, if you opted in, shared with us through Apple. The App sends nothing itself. 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 or notification permission in iPhone Settings > CC London Alerts. - Delete the App to remove everything the App stored on the device. 4.3 Backups and transfers of data from your iPhone. The App itself never sends the data in section 3 anywhere. The App marks the folders that hold its saved data (your settings, your history, and the entry and exit marks, which hold coordinates) as excluded, and iPhone then leaves them out of iCloud Backup and out of backups made to a computer with Finder. A few small preferences, such as your appearance choice, hold no location and may still be backed up. This is a request that iPhone honours; we cannot check or control what Apple does with it. Some things are beyond our control and may still copy the App's stored data: a direct iPhone-to-iPhone transfer when you set up a new iPhone, and device management or "backup and restore" tools you or your employer use. If you do not want the marks copied by those, use Clear history in the App first. Any copy made that way is held under that service's terms and privacy policy, not ours, and we cannot see, access, delete or limit it. 4.4 Crash reports. The App keeps crash records on your device (the newest 50). There is a "Download crash report" option on the hidden Diagnostics screen. If you use it, your iPhone'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. Separately, see the row for Diagnostic information from Apple in section 3 for what Apple may share with us if you have opted in. ## 5. Permissions the App asks for The App asks iPhone for these permissions and settings. You can refuse or withdraw them, although some features will then not work. - Location, with Precise Location on: To know where you are relative to the Zones. Approximate location is too coarse to warn you in time. - Location "Always" (after "While Using"): So alerts work when another app, such as a maps app, is in front of the App, or the screen is locked. While monitoring runs in the background iPhone shows its blue location indicator. - Notifications: To show your alerts, with their sound and, where your phone allows it, as time-sensitive notifications. - Background App Refresh (optional): iPhone may use it to start the App again in the background after it was closed, if you had monitoring switched on. - Live Activities (optional): Shows a colour-coded alert card on the lock screen and in the Dynamic Island while monitoring is on, so an alert can be seen while another app, such as a navigation app, is in front. It is drawn from information on your iPhone and is not sent anywhere. You can turn it off in iPhone Settings > CC London Alerts. There is no "display over other apps" banner on iPhone, and the App does not ask for one. The Live Activity above is how an alert stays on screen over another app. 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 and silent mode. Your iPhone's Low Power Mode and Background App Refresh setting can stop or slow background monitoring, and its silent switch and Focus modes can silence or hold back alerts. The App shows a warning where it can tell. It does not collect anything about your battery beyond what iPhone 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 (Apple Maps). The street map is Apple Maps, drawn by the iPhone's own map component. As you look at the map, your iPhone requests map data from Apple, so Apple can see your device's network (IP) address, roughly which part of London is on screen (the view is about 1.5 km across) and standard technical information, under Apple's own privacy policy, which we do not control. If you switch on Map when you are away from the zones in Settings (off by default, and offered only while you are in or near the UK, and only while the street map is on), the map shows where you are when you are far from London. The map data your iPhone then asks Apple for covers the area around you (about 2 km across), or a wide view of the UK between you and London, so Apple can see roughly where in the UK you are. The same applies if you drag the map to your blue dot (this works whatever that setting is): the map data your iPhone then asks Apple for is centred on you, so Apple can see roughly where you are, but not your exact position. The App does not give Apple your position, your alerts or your history; your position is drawn over the map on your device. 6.2 Zone outline only. In Settings > Map data you can choose Zone outline only (no street map). The App then draws the zone and your position on a plain outline and makes no network requests for the map at all. There is no map download on iPhone. 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 iPhone location services. The App uses Apple's Core Location to obtain your position. Apple may process location information in doing this under Apple's own terms and privacy policy and your Location Services settings. This is part of your iPhone's operating system, not something the App sends to us. 6.5 App Store. If you buy or update the App through the Apple App Store, Apple 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, the App asks iPhone to leave its saved data out of backups, but a direct device-to-device transfer or a device management tool can still copy it. 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 iPhone'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 Apple's map service use encrypted 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.