Privacy Policy

Eyooz OÜ (“Company”, “we”, “us”, or “our”) operates the TheSafeGrid mobile application (the “App”) and the website located at thesafegrid.com (the “Website”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Services. Please read this policy carefully. If you do not agree with its terms, please discontinue use of the Services.

This Privacy Policy applies to all users of the Services, including parents and legal guardians who use the App to manage their children’s devices, adult users who use the App for self-regulation, and visitors to our Website. It has been drafted to comply with the European Union General Data Protection Regulation (GDPR), the Children’s Online Privacy Protection Act (COPPA), the Apple App Store Review Guidelines, and Google Play’s Developer Program Policies.

1. Information We Collect

We collect only the information that is strictly necessary to provide and improve the Services. The categories of data we may collect are described below.

1.1 Information You Provide Directly

• Account Data: Full name and email address when you create an account.
• Payment Data: Your subscription plan and transaction identifiers (but not payment card numbers, which are handled exclusively by the App Store or Google Play).
• Support Communications: Messages or attachments you send when contacting our support team.

1.2 Information Collected Automatically

• Device Information: Device model, operating system version, unique device identifiers, and app version.
• Usage and Diagnostic Data: Log files, crash reports, and diagnostic data to help us identify and fix technical issues.
• Approximate Location: General geographic region derived from your IP address (country or city level only). We do not collect precise GPS location.

1.3 Information Related to VPN and Content Filtering

TheSafeGrid uses VPN technology solely to perform content filtering on your device. In connection with this functionality, we wish to make the following explicit disclosures:

• We do not log, store, or transmit the websites you visit, the URLs you access, or the content of your internet traffic.
• We do not log, store, or transmit the list of applications you use or the frequency of their use.
• Content filtering is performed locally on your device. Your browsing traffic is not routed through our servers.
• We do not sell, share, or disclose any browsing or usage data to third parties for advertising, analytics, or any other commercial purpose.

1.4 Information About Child Devices

When a Supervisor configures the App to manage a Child Device, we may process the following data in connection with that device:

• The blocking rules and schedules configured by the Supervisor (e.g., list of blocked websites or apps).
• Basic device identifiers necessary to link the Child Device to the Supervisor’s account.

We do not collect the child’s name, date of birth, email address, or any other personal information directly from the child. All account management is performed by the Supervisor.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Service Provision: To create and manage your account and authenticate your identity.
• Synchronisation: To synchronise blocking rules and settings across devices linked to your account.
• Billing: To process subscription payments through the App Store or Google Play.
• Customer Support: To respond to your support requests and resolve technical issues.
• Service Improvement: To analyse aggregated, anonymised usage patterns to improve the App’s features and performance.
• Communications: To send you important notices about your account, subscription, or changes to our policies.
• Legal Compliance: To comply with applicable legal obligations, including GDPR and COPPA.

3. Legal Basis for Processing (GDPR)

For users located in the European Economic Area (EEA), we process your personal data on the following legal bases under the GDPR:

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You have the right to object to processing based on legitimate interests at any time (see Section 8).

4. Children’s Privacy (COPPA and GDPR)

4.1 No Direct Collection from Children

The App is not directed at children under the age of 13. We do not knowingly collect personal information directly from children under 13. The App is designed so that all account creation and management is performed exclusively by the parent or legal guardian (the “Supervisor”).

4.2 Parental Consent

If you are a Supervisor using the App to manage a Child Device, you represent that you are the parent or legal guardian of the child and that you consent to the limited processing of data from the Child Device as described in this Privacy Policy. In the EEA, for children under 16, this consent is required under Article 8 of the GDPR.

4.3 No Advertising to Children

We do not display targeted advertising to children, and we do not use any data from Child Devices for advertising or marketing purposes.

4.4 Contact Regarding Children’s Data

If you believe that a child under 13 has provided us with personal information without your consent, please contact us immediately at hello@thesafegrid.com. We will take prompt steps to delete such information from our systems.

5. Data Sharing and Disclosure

We do not sell your personal data. We do not share your personal data with third parties for their own marketing or advertising purposes. We may share your data only in the following limited circumstances:

5.1 Service Providers

We may share data with trusted third-party service providers who assist us in operating the Services (e.g., cloud hosting, analytics, customer support tools). These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection laws. Our website is hosted by o2switch.

5.2 App Store and Payment Processors

Subscription payments are processed by Apple (App Store) or Google (Google Play). These platforms operate under their own privacy policies. We receive only transaction confirmation data and do not have access to your payment card details.

5.3 Legal Requirements

We may disclose your data if required to do so by law, court order, or governmental authority, or if we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of the Company, our users, or the public.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of the Company’s assets, your data may be transferred to the acquiring entity. We will notify you via email and/or a prominent notice on the Website before your data is transferred and becomes subject to a different privacy policy.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law. Specifically:

• Account Data: Account data is retained for the duration of your account and deleted within 30 days of account deletion.
• Diagnostic Data: Diagnostic and crash logs are retained for a maximum of 12 months.
• Support Data: Support communications are retained for up to 24 months.
• Billing Records: Billing records may be retained for up to 7 years to comply with Estonian and EU accounting and tax obligations.

You may request deletion of your account and associated data at any time by contacting us at hello@thesafegrid.com or through the account deletion feature within the App.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• Encryption of data in transit using TLS (Transport Layer Security).
• Encryption of data at rest on our servers.
• Access controls limiting data access to authorised personnel only.
• Regular security assessments and vulnerability testing.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority in accordance with applicable law.

8. Your Rights

Depending on your location, you may have the following rights regarding your personal data. To exercise any of these rights, please contact us at hello@thesafegrid.com.

We will respond to all requests within 30 days. If you are located in the EEA, you also have the right to lodge a complaint with your local data protection supervisory authority. In Estonia, this is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon): www.aki.ee.

9. International Data Transfers

Eyooz OÜ is incorporated in Estonia and operates within the European Union. Your data is primarily stored and processed within the EEA. If we transfer your data to service providers located outside the EEA, we ensure that appropriate safeguards are in place, such as the European Commission’s Standard Contractual Clauses (SCCs) or an adequacy decision, to protect your data in accordance with GDPR requirements.

10. Cookies and Tracking Technologies

Our Website (thesafegrid.com) may use cookies and similar tracking technologies to enhance your browsing experience and analyse website traffic. Cookies are small text files stored on your device.

10.1 Types of Cookies We Use

• Essential Cookies: Required for the website to function correctly (e.g., session management, security).
• Analytics Cookies: Help us understand how visitors interact with the Website (e.g., pages visited, time spent). Data is aggregated and anonymised.
• Preference Cookies: Remember your preferences to provide a more personalised experience.

10.2 Your Cookie Choices

You may control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website. Where required by law, we will request your consent before placing non-essential cookies.

The App itself does not use cookies. Any analytics collected within the App use anonymised, aggregated identifiers and do not track your browsing activity.

11. Third-Party Links and Services

The App and Website may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access. We are not responsible for the privacy practices or content of third-party services.

12. Apple App Store and Google Play Store

When you download the App from the Apple App Store or Google Play Store, Apple or Google may collect certain data about your device and download activity in accordance with their own privacy policies. This data collection is governed by Apple’s Privacy Policy (https://www.apple.com/legal/privacy/) and Google’s Privacy Policy (https://policies.google.com/privacy), respectively, and is outside our control.

In-app purchases are processed by Apple or Google. We do not receive or store your payment card information. We only receive a transaction confirmation to activate your subscription.

13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will notify you by updating the “Last Updated” date at the top of this document and, where required by law, by sending a notification through the App or to the email address associated with your account. We encourage you to review this Privacy Policy periodically. Your continued use of the Services after the effective date of the revised Policy constitutes your acceptance of the changes.

14. Contact and Data Controller Information

Eyooz OÜ is the data controller responsible for your personal data. If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Company: Eyooz OÜ
• Address: Ahtri 12, 10151, Tallinn, Estonia
• Email: hello@thesafegrid.com
• Website: thesafegrid.com

If you are located in the EEA and wish to lodge a complaint with a supervisory authority, you may contact the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at www.aki.ee, or the supervisory authority in your country of residence.

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