CALARYS LTD ("we," "us," or "our") is committed to protecting the privacy and security of our users' personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, Calarys Connect (the "App"), and our website, calarys.com (the "Website").
Calarys Ltd is a registered company in England and Wales (Company Registration Number: 17372568). For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Calarys Ltd acts as the Data Controller.
Please read this Privacy Policy carefully. If you do not agree with any terms of this Privacy Policy, please do not access or use the App or the Website.
1. Information We Collect
We collect information you provide directly to us, information collected automatically during your use of our Service, and information from our integrated third-party platforms.
A. Information You Voluntarily Provide to Us
- Account Registration Data: When you sign up for Calarys Connect, we collect your name, email address, password, and contact preferences.
- Identity Verification Data: Uploaded images of official government-issued identification (such as passports, national ID cards, or driving licenses) and selfie photographs used solely for secure identity verification and fraud prevention.
- User-Generated Content: Tasks, to-do lists, reminders, calendars, notes, schedules, and specific action layers that you input into the App to manage your daily life and activities.
- Transactional and Booking Preferences: When utilizing the App's smart assistant features (such as reserving a table or ordering food), we collect transaction-related preferences, diet restrictions, booking times, party sizes, and recipient contact details.
B. Information Collected Automatically
- Device and Usage Data: IP address, unique device identifiers, operating system version, mobile carrier, App performance statistics, crash logs, and browser type.
- Telecommunications Data: Virtual or dedicated telephone numbers allocated to your account, along with call logs, SMS metadata, and communication history routed through the App's virtual number service.
- Location Data: With your explicit permission, we may collect precise or approximate geolocation data from your device to facilitate local lifestyle services and map searches.
2. Legal Basis for Processing (UK GDPR)
If you reside in the United Kingdom or the European Economic Area (EEA), our legal basis for collecting and processing your personal data depends on the specific context:
- Performance of a Contract: To provide and maintain your account, provision your virtual telephone number, synchronize your tasks, and carry out your requested transactions (such as restaurant bookings or takeaways).
- Consent: Where you have provided clear consent (e.g., allowing location services for local listings or subscribing to push notifications).
- Legitimate Interests: To analyze App performance, verify identity documents, prevent fraud, secure our database, and continuously improve our user experience.
- Legal Obligation: Where we are required by United Kingdom law or regulatory authorities to retain certain transactional, telecommunication, or tax records.
3. How We Use Your Information
We process your data for the following business purposes:
- To set up, manage, and synchronize your personal Calarys Connect account across your devices.
- To verify your identity and prevent fraudulent account creation.
- To provision and route your virtual telecommunication services, including the dedicated phone number allocated to you.
- To facilitate and process third-party lifestyle actions (such as reserving a dining table or ordering food deliveries).
- To send you task reminders, upcoming calendar notifications, and account security alerts.
- To optimize and secure the App’s performance, diagnose software errors, and prevent fraudulent activities.
4. Data Sharing and Disclosure
We do not sell, rent, or trade your personal data under any circumstances. We may disclose your data only in the following limited scenarios:
- Third-Party Merchant Integrations: When you use the App to reserve a table ("Book a table") or order food ("Order a takeaway"), we securely transfer necessary transactional details (such as your name, phone number, and order details) to the respective restaurant or delivery platform to fulfill your request.
- Third-Party Map Services: We integrate with official third-party map providers (such as Apple Maps and Google Maps) to retrieve restaurant, merchant, and location data. Your map search queries may be shared with these providers to deliver accurate local results.
- Service Providers: We share data with highly secure, GDPR-compliant infrastructure partners (such as cloud hosting servers and database service providers) strictly under data processing agreements.
- Legal and Regulatory Authorities: When required to do so by UK law, court order, or the HM Revenue and Customs (HMRC).
5. Your Data Protection Rights (GDPR)
If you are a resident of the United Kingdom or the EEA, you have the following statutory rights regarding your personal data:
- The Right to Access: You have the right to request copies of your personal data.
- The Right to Rectification: You can request that we correct any inaccurate or incomplete personal information.
- The Right to Erasure ("Right to be Forgotten"): You can request that we completely erase your personal data from our servers under certain conditions.
- The Right to Restriction or Objection: You have the right to restrict or object to how we process your personal data.
- The Right to Data Portability: You have the right to request the transfer of your data to another service provider.
To exercise any of these rights, please contact our Data Protection Officer at privacy@calarys.com. We will respond to your request within 30 days.
6. Data Storage and Transfers
As a UK-registered business, your data is securely stored on encrypted cloud servers. If personal data is transferred outside the UK or EEA for hosting purposes, we ensure that appropriate safeguards (such as Standard Contractual Clauses approved by the European Commission and UK authorities) are in place to maintain the highest level of security.
7. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the revised policy on this page and updating the "Effective Date" at the top of this document.
8. Contact Us
For any inquiries, data rights requests, or feedback regarding this Privacy Policy, please contact our Legal and Privacy Team at:
Company Name: CALARYS LTD
Company Registration Number: 17372568
Registered Office Address: College House, 2nd Floor, 17 King Edwards Road, Ruislip, London, HA4 7AE, United Kingdom
DPO Email: privacy@calarys.com