Privacy Policy

1. Who we are

[Company legal name], Külbstr. 20, 55131 Mainz, Germany ("Last Seen", "we", "us") is the controller responsible for your personal data.

• Privacy questions and requests: privacy@lastseen.help
• Data protection contact: privacy@lastseen.help
• EU representative:
• UK representative: [UK representative - required under UK GDPR Art. 27 if you offer the app to people in the UK]

2. What we collect

Account and settings

• A random account identifier, and a sign-in token for your device (we store only a hash of it)
• The display name you choose. It is required before you add emergency contacts, share an invite or join someone's circle, because it is how they know the messages are about you
• Your check-in interval, grace period, pause dates, language, notification choices, and the country you pick for the emergency number
• Your phone number and email address, only if you choose to verify them
• Your device's push-notification token

Check-ins and wellbeing

• When you check in, and whether it was the button or a reply
• Replies you send when someone checks on you (for example "I'm okay" or "not feeling well")
• Whether you are on time or overdue, and the reminders and alerts sent about you

Your circle

• The names, phone numbers and (optional) email addresses of emergency contacts you add
• Which app users watch you and which you watch, and the pokes and messages between you

Your final note

• The note itself, encrypted; a scrypt hash of your PIN; and a log of each time it was viewed, changed, requested or released

Records we must keep

• What you agreed to, which version, and when, with the IP address and device type at that moment
• Short-lived security records such as rate-limit counters

We do not collect your location, your address book (if you import one contact, the rest never leave your device), advertising identifiers or analytics profiles.

3. Health-related data

Some of this data can reveal something about your health or wellbeing - for example, that you missed check-ins, or replied that you are not feeling well - and your final note can contain anything you choose to write.

We treat all of it as special category data under the GDPR (Article 9) and as consumer health data under US state laws such as Washington's My Health My Data Act and Nevada SB 370. We collect and share it only with your explicit consent, given when you set up the app, and only to provide the service. You can withdraw consent at any time by deleting your account; we cannot run the service for you without it.

4. Why we use your data, and our legal basis

• To run the service: tracking check-ins, reminding you, alerting your circle, and storing and releasing your final note. Basis: our contract with you (GDPR Art. 6(1)(b)) and your explicit consent for health-related data (Art. 9(2)(a)).
• To keep accounts and the service secure: verifying phone numbers and emails, rate limits, PIN lockouts and abuse prevention. Basis: our legitimate interest in protecting you and other users (Art. 6(1)(f)).
• To record consents and handle your requests. Basis: legal obligation (Art. 6(1)(c)).
• To email waitlist sign-ups from our website. Basis: consent, confirmed by email (Art. 6(1)(a)).

We do not use your data for advertising or profiling. The only automated decision is when to send a reminder or alert, and it follows the schedule you set.

5. Who sees your data

People you choose

• People in your in-app circle see your display name, your last check-in time, and whether you are on time, overdue or paused. If you allow it in Settings, they also see the reply you sent.
• If you reply "I need help", everyone in your in-app circle is told so straight away, whatever your reply-sharing setting, and it stays flagged for them until you check in normally or 24 hours pass.
• If you are overdue, your emergency contacts get a text or email with your display name and how long it has been since you checked in.
• Your final note is released only as described in section 7.

Service providers, who process data only on our instructions under contracts requiring confidentiality and security (GDPR Art. 28):

• Hosting and database provider [e.g. Google Cloud / Neon] — running the service and storing account data ([EU / US])
• Expo (650 Industries, Inc.) — delivering push notifications (United States)
• Twilio Inc. — sending SMS alerts and verification codes (United States)
• Twilio SendGrid — sending email alerts and verification codes (United States)

Others

• Authorities, only where the law requires it. We will tell you unless we are legally prevented.
• A successor, if the service is transferred, bound by this policy.

We do not sell your personal information, and we do not share it for cross-context behavioural advertising, as those terms are used in California law. We never contact emergency services on your behalf.

6. Emergency contacts who don't use the app

When you add someone, we send them one message saying who added them, what they may receive and how to opt out, with a link to this policy. If they opt out - by replying STOP or using the link - we stop messaging them and remember that choice even if they are added again.

By adding someone you confirm they have agreed to be your emergency contact.

7. Your final note

• It is encrypted on our servers with AES-256-GCM using a key unique to your account. That key is itself encrypted with a master key kept outside our database.
• Viewing or changing it needs your PIN. We store only a scrypt hash of the PIN. After 5 wrong attempts the vault locks, for longer each time.
• An unlock lasts 5 minutes, on that device only.
• It is released only when (1) the one person you chose to look after it asks for it, (2) you are at least 6 hours past your check-in deadline, and (3) you do not check in during the following 24 hours. If you have chosen nobody, nobody can ask. We tell you when it is requested and again if it is released, and everyone else in your circle is told when that person asks for it and when they open it. Checking in cancels the request.
• Every view, change, request and release is logged and shown to you.
• If you forget your PIN you can reset it, which permanently erases the note.

Please note: because our servers make the release possible, the note is encrypted by us rather than end-to-end. Access to production systems is restricted and logged, and we do not read notes unless legally compelled.

8. International transfers

Some of our providers are in the United States. When your data leaves the EEA, UK or Switzerland, we rely on the EU-US Data Privacy Framework (and its UK and Swiss extensions) where the provider is certified, or otherwise on the European Commission's Standard Contractual Clauses and the UK Addendum, with additional safeguards. You can ask us for a copy.

9. How long we keep it

• Account, settings, circle, emergency contacts and final note: until you delete your account.
• Check-in history, replies and alert records: 24 months, then deleted.
• In-app notifications and delivery records: 90 days.
• Verification codes and security counters: up to 30 days.
• Final note access log: 24 months, or until you delete your account.
• Consent records: for as long as your account exists.
• Unconfirmed waitlist sign-ups: 30 days.

When you delete your account, your data is removed from our live systems immediately and from backups within 35 days.

10. Your rights

Wherever you live, you can see, correct, export and delete your data and withdraw consent. Use Settings > Your data, or email privacy@lastseen.help. We reply within one month (EU/UK) or 45 days (US), and tell you if we need more time where the law allows it. We confirm requests come from you by checking they come from your signed-in app or a verified phone number or email.

EU, EEA, UK and Switzerland: you also have the rights to restrict processing, to object, and to data portability, and you can complain to your data protection authority (in the EU, see edpb.europa.eu; in the UK, the ICO at ico.org.uk). We would appreciate the chance to address your concern first.

California: under the CCPA/CPRA you can ask what personal information we collected, used and disclosed in the past 12 months and ask us to delete or correct it. In that period we collected identifiers, contact details, sensitive personal information (health-related wellbeing data and the contents of your final note) and device information, from you and from people in your circle, for the purposes in section 4, and disclosed it to the service providers and people described in section 5. We do not sell or share personal information and we use sensitive personal information only to provide the service, so there is nothing to opt out of or limit. We will not treat you differently for using your rights. An authorised agent can act for you with your signed permission.

Other US states (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon and others with privacy laws): you have similar rights. If we decline a request, you can appeal by replying with "Appeal"; if you disagree with the outcome you can contact your state attorney general.

Washington, Nevada and other consumer health data laws: we collect and share consumer health data only as described here and with your consent, you can access and delete it and withdraw consent, and we never sell it.

11. Security

Connections are encrypted in transit. Sign-in tokens and PINs are stored only as hashes, the final note is encrypted at rest, requests are rate-limited, and access to production systems is restricted. No system is perfectly secure; if a breach puts you at risk we will tell you without undue delay and notify the authorities as the law requires.

12. Children

Last Seen is not for anyone under 16. We do not knowingly collect data from children. If you believe a child has created an account, contact privacy@lastseen.help and we will delete it.

13. Changes to this policy

If we make material changes, we will tell you in the app before they take effect and ask you to review them. Where a change needs your consent, we will ask for it again. Earlier versions are available on request.

14. Contact

[Company legal name]

Külbstr. 20, 55131 Mainz, Germany

Phone: +49 6131 9011160

Email: privacy@lastseen.help