Legal Document
Privacy Policy
1. Introduction
This Privacy Policy explains how SafePhone Inc. (“SafePhone,” “we,” “us,” or “our”) collects, uses, discloses, retains, and otherwise processes personal information when you use our websites, Android application, dashboards, enrollment tools, accountability features, support channels, and related services (collectively, the “Services”).
SafePhone is a subscription-based service that provides tools for supported device enrollment, configuration, restrictions, accountability settings, and related administrative controls on eligible Android devices. For personally owned devices, the device owner remains the sole owner of the device and chooses whether to enroll the device, what settings to apply, and whether to enable optional features. Certain Service functionality for personally owned devices may be available only where supported by the device, provisioning method, technical environment, subscription state, and applicable platform policies.
2. Scope and Consent
By using the Services, you acknowledge this Privacy Policy. Where required by applicable law or platform policy, we seek consent before collecting, using, or sharing information. We do not collect information without user consent where consent is required.
Information we collect is used to provide, operate, secure, support, maintain, and improve the Services within the scope of the user’s subscription, lawful instructions, and applicable law.
3. Information We Collect
3.1 Information You Provide
We may collect information you provide directly, including:
- name
- email address
- password or authentication credentials
- account profile details
- billing contact information
- organization, family, or group setup information
- support inquiries and communications
- pilot or lead-capture form submissions
- accountability partner invitation details
3.2 Billing and Payment Information
Payment processing is handled by third-party payment processors. We may receive billing status, subscription status, payment method metadata, invoices, transaction identifiers, and similar information needed to manage subscriptions, but we do not intentionally store full payment card numbers in our own systems.
3.3 Device and Enrollment Information
When you enroll and manage a device through SafePhone, we may collect information reasonably necessary to provide, secure, support, and troubleshoot the Service, such as:
- device identifiers
- model and manufacturer
- Android version and related system details
- enrollment status
- last-seen or check-in information
- device name
- applied profiles, restrictions, or configuration state
- security and operational status information needed to provide the Service
Depending on the Service feature and supported device capability, this may include information such as IMEI, serial number, battery status, rooted status, Wi-Fi or network information, and other device-state information relevant to management and support.
We do not state that every category listed above is collected in every account, on every device, or in every Service configuration.
3.4 User, Group, and Administrative Information
We may collect and process information about users, groups, assigned devices, roles, permissions, and administrators in order to provide account and device management features.
3.5 Accountability Feature Information
If you use accountability features, we may collect and process information related to:
- protected apps
- protected domains or websites
- accountability rules and settings
- delay events
- accountability partner relationships
- logs needed to provide the accountability feature
By default, and where supported, accountability partner views should use a more generic message. If the account owner affirmatively selects a more detailed visibility mode, partner views may include the exact app name or domain name.
3.6 Website, Support, and Marketing Information
If you visit our website or interact with us, we may collect:
- pages visited
- browser and device information
- approximate IP-based location
- cookie and analytics preferences
- contact form submissions
- support requests
- marketing or pilot signup information
3.7 Cookies and Similar Technologies
We use cookies and similar technologies as described in our Cookie Policy.
4. What We Do Not Intend To Do
We do not use third-party advertising networks to place third-party ads on our website or products. We may advertise or promote our own product, plans, offers, features, or updates.
We do not intentionally collect precise geolocation information unless a feature specifically requires it and we separately disclose that collection and request any permissions required by applicable law or platform rules.
Except as described in this Privacy Policy or in feature-specific disclosures, we do not intentionally collect more device or account information than is reasonably needed to provide, secure, support, and improve the Services.
5. How We Use Information
We may use information to:
- create and manage accounts;
- authenticate users;
- process subscriptions and billing;
- enroll and manage devices;
- apply, maintain, and display profiles, restrictions, and accountability settings;
- show current account, user, group, and device state;
- support safe unenrollment;
- provide customer support;
- send service notices, security notices, and administrative communications;
- provide pilot and onboarding support;
- maintain security and prevent abuse;
- troubleshoot and improve the Services;
- comply with law, enforce our agreements, and protect rights and safety.
6. Post-Expiry and Unenrollment Information Use
If a subscription expires or is canceled, we may continue to process the minimum information reasonably necessary to:
- show subscription status;
- support reactivation;
- provide read-only account, user, group, and device state where available;
- allow voluntary unenrollment;
- maintain security, legal compliance, fraud prevention, dispute handling, and records-retention obligations;
- document account and Service lifecycle events.
We do not use subscription expiry to transfer ownership of a personally owned device to SafePhone, intentionally block the user’s core personal access to the device, or force immediate unenrollment by default.
7. How We Share Information
We may share information:
- with service providers that help us provide the Services, such as hosting, analytics, support, authentication, payment, security, and infrastructure providers;
- with accountability partners, other administrators, or authorized users where the feature is designed to disclose information to them and the user has enabled that feature;
- in connection with a merger, financing, acquisition, or sale of assets;
- to comply with law, legal process, or government request;
- to protect rights, property, safety, security, or enforce our agreements.
We do not sell personal information in exchange for money. We do not use third-party ad networks to serve third-party ads in the Services.
8. Legal Bases and Canadian Consent
Where Canadian law applies, we rely on consent, contractual necessity, legitimate business purposes consistent with applicable law, and legal obligations as appropriate. You may withdraw consent where applicable, subject to legal or contractual restrictions and reasonable notice.
9. U.S. State Privacy Rights
Depending on your U.S. state of residence and applicable law, you may have rights to access, correct, delete, or obtain a copy of certain personal information, and to opt out of certain processing where applicable. We will handle valid requests in accordance with applicable law.
10. Retention
We retain information only as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, support enrollment and unenrollment, maintain security, comply with law, resolve disputes, enforce our agreements, and keep appropriate business and legal records.
Retention periods may vary by information type and account state. For example, different retention periods may apply to:
- account and billing records;
- device and enrollment records;
- operational and security logs;
- support communications;
- pilot and lead-submission records;
- accountability-feature configuration or event records.
Some information may remain in backups or archives for a limited time before deletion.
11. Security
We use reasonable administrative, technical, and organizational measures designed to protect information. No system can be guaranteed 100% secure.
12. International and Cross-Border Processing
We may process information in Canada and other jurisdictions where we or our service providers operate. Information may be subject to lawful access by courts, regulators, or authorities in those jurisdictions.
13. Children
The Services are not directed to children as account holders. Where the Service is used in a family setting, the account holder or authorized administrator is responsible for lawful use and any required notice or consent.
14. Your Choices
You may be able to:
- update account information;
- manage subscriptions and billing;
- control accountability settings;
- use a safer default accountability display mode that shows a generic message where supported;
- choose whether to switch accountability partner views from generic messaging to exact app/domain details where supported;
- unenroll devices;
- manage cookie preferences;
- opt out of non-essential marketing communications.
15. In-Product and Platform Disclosures
Some features may also be governed by in-product notices, setup disclosures, permission prompts, enrollment disclosures, or app-store disclosures. Those disclosures supplement this Privacy Policy and help explain feature-specific processing in context.
Where a feature depends on device compatibility, provisioning method, or applicable platform rules, the availability and behavior of that feature may vary accordingly.
16. Changes to this Policy
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice as appropriate and as required by law.
17. Contact Us
Company: SafePhone Inc.
Mailing Address: 30 Powerhouse, 101 Toronto, Ontario M6H 0C6
Privacy: privacy@safephone.net