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Privacy Policy

Dignity Labs — Base Privacy Policy

Effective Date: 11 February 2026 · Last Updated: 11 February 2026

This is the base privacy policy for all Dignity Labs apps. Each app has its own privacy addendum that details what data that specific app collects and how it is handled:

Suracode Privacy Addendum · Pocket Proof Privacy Addendum

1. Data Controller

Dignity Labs Ltd
Company Number: 16954194
Registered in England and Wales

167-169 Great Portland Street, 5th Floor
London, W1W 5PF

Email: [email protected]
Website: https://dignitylabs.co.uk

For data protection enquiries, contact us at the email address above.

2. Our Principles

These principles apply across all Dignity Labs apps:

  • Minimum data: We collect the minimum data necessary for each app to function
  • Privacy by default: Privacy-protective settings are the default, not the exception
  • No selling: We do not sell your data to anyone, ever
  • No advertising: We do not use your data for advertising or marketing to third parties
  • No AI training: We do not use your data to train AI models
  • No profiling: We do not build profiles of you or use automated decision-making
  • Transparency: We tell you exactly what we collect and why

3. What Data Each App Collects

Each Dignity Labs app collects different data depending on what it does. The specific data collected by each app is detailed in the relevant privacy addendum:

AppPrivacy AddendumData Model
SuracodeSuracode Privacy AddendumCloud-synced with Supabase. Anonymous UUIDs. End-to-end encrypted content. Authentication via Google/Apple Sign-In.
Pocket ProofPocket Proof Privacy Addendum100% local. No accounts. No cloud. No network calls. All data on your device only. 7-day free trial, then limited free tier or Pro subscription.

4. How We Use Your Information

Across all apps, we use information for the following purposes and legal bases:

PurposeLegal Basis (GDPR)
Provide the core servicePerformance of contract
Maintain and improve our AppsLegitimate interests
Provide customer supportLegitimate interests
Ensure security and prevent abuseLegitimate interests
Comply with legal obligationsLegal obligation

App-specific purposes are set out in the relevant privacy addendum.

We do not use your data for advertising, profiling, automated decision-making, selling to third parties, or training AI models.

5. Data Sharing

We share data only as necessary to operate each app. Where an app uses third-party services, these are listed in the relevant privacy addendum.

We do NOT share data with advertisers, data brokers, marketing companies, social media platforms, or AI training providers.

5.1 Legal Disclosure

We may disclose information if required by law, court order, or government request. Where an app collects no personal data or uses end-to-end encryption, the practical value of such disclosure may be limited. We will notify you of such requests unless legally prohibited.

6. Data Security

We take security seriously across all apps. Common security measures include:

  • PIN and biometric protection for app access
  • Hardware-backed secure storage for sensitive data (iOS Keychain / Android Keystore)
  • Encryption in transit (HTTPS/TLS) where network connections are used
  • Encryption at rest where data is stored
  • Session timeout (auto-lock after inactivity)

App-specific security measures are detailed in the relevant privacy addendum.

6.1 Data Breach Notification

If a personal data breach occurs that is likely to affect your rights and freedoms, we will notify the Information Commissioner's Office within 72 hours and, where the risk is high, notify affected users without undue delay, in accordance with UK GDPR Articles 33 and 34.

Where an app stores no personal data on our servers (such as Pocket Proof), a server-side breach would not affect your app data.

7. Your Rights (GDPR)

Under the UK GDPR, you have the following rights. These apply regardless of which Dignity Labs app you use:

Right of Access

You can request a copy of all data we hold about you. Contact us at [email protected].

Right to Rectification

You can request correction of inaccurate data we hold about you.

Right to Erasure ("Right to be Forgotten")

You can request deletion of your data. App-specific deletion methods are set out in each privacy addendum.

Right to Restriction of Processing

You can request we limit how we use your data in certain circumstances.

Right to Data Portability

You can request your data in a machine-readable format.

Right to Object

You can object to processing based on legitimate interests.

Right to Withdraw Consent

Where we rely on consent, you can withdraw it at any time.

Right to Lodge a Complaint

You have the right to complain to the Information Commissioner's Office (ICO):

  • Website: https://ico.org.uk
  • Helpline: 0303 123 1113

8. Children's Privacy

Our Apps do not knowingly collect personal information from children under 13. Where an app is designed for family use, we recommend that parents and guardians set up and manage the App for younger family members. If we learn we have collected data from a child under 13 without parental consent, we will delete it promptly.

If you believe a child has provided us with personal information, please contact us immediately.

9. International Data Transfers

Where an app uses cloud services, data is processed and stored within the European Economic Area (EEA). Specific hosting details are provided in each app's privacy addendum.

Authentication services (Google Sign-In, Apple Sign-In) may process authentication tokens in the United States using approved data transfer safeguards maintained by those providers.

App store distribution (Apple/Google) is separate from app data.

10. Cookies and Tracking

Our Apps do not use cookies or tracking pixels. We do not track your behaviour across other apps or websites.

If an app offers optional analytics, this is disabled by default and requires your explicit opt-in. Details are provided in the relevant privacy addendum.

11. Regional Privacy Rights

11.1 United Kingdom

Your rights are set out in Section 7. The ICO is your supervisory authority.

11.2 European Union

Your rights under the EU GDPR are equivalent to those in Section 7. You may also lodge a complaint with your local Data Protection Authority. In accordance with the Digital Services Act (Regulation (EU) 2022/2065), Dignity Labs Ltd does not engage in targeted advertising, does not deploy recommender systems, and does not process personal data for profiling purposes. You have a 14-day right to withdraw from any paid subscription. You may use the EU Online Dispute Resolution platform: https://ec.europa.eu/consumers/odr

11.3 United States

Residents of California (CCPA/CPRA), Virginia, Colorado, Connecticut, and other US states with consumer privacy legislation have the right to know what personal information we collect, request deletion, and opt out of sale. We do not sell personal information. We do not share personal information for cross-context behavioural advertising. To exercise any US state privacy right, contact [email protected]. We will respond within 45 days.

11.4 Australia

Your rights are protected under the Australian Privacy Principles (APPs) under the Privacy Act 1988. You may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

11.5 Canada

Your rights are protected under PIPEDA and applicable provincial privacy legislation. You have the right to access, correct, and request deletion of your personal information. You may lodge a complaint with the Office of the Privacy Commissioner of Canada.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date. For significant changes, we will notify you via the relevant App. Continued use after changes constitutes acceptance.

13. Contact Us

For any questions about this Privacy Policy or your personal data:

Dignity Labs Ltd
Company Number: 16954194
Registered in England and Wales

167-169 Great Portland Street, 5th Floor
London, W1W 5PF

Email: [email protected]
Website: https://dignitylabs.co.uk

We aim to respond to all enquiries within 30 days.

14. App Privacy Addendums