Website privacy and cookies

Privacy Notice for the app

Version 1.0 · In force from [[OWNER: effective date]]

This notice is about our website, brightnods.co.uk. The BrightNods app has its own Privacy Notice, which also covers emails you send us.

1. Who runs this website

The website is run by KINDHOME LTD, a company registered in England and Wales (No. 17558840), trading as BrightNods, who is the controller of the information described here.

• Address: 32 Mill Street, Worcester, WR1 2NH
• Email for privacy questions: [[OWNER: privacy email]]
• Email for everything else: [[OWNER: support email]]
• Registered with the Information Commission (data protection fee), number [[OWNER: ICO registration number]]

2. What happens when you visit

The website is a set of plain pages. It has no forms, no accounts, no adverts and no analytics. We do not try to find out who you are.

The site is hosted by Cloudflare (Cloudflare Pages). To send you a page, Cloudflare's computers receive what any web host receives:

• your device's IP address;
• the page you asked for, and when;
• technical details your browser sends, such as its type and language, and the page that linked to us if your browser says so.

Cloudflare uses this to deliver the pages and to protect the site from attacks. It does this for us, as our processor, under its data processing terms. Cloudflare keeps these records for its own set periods. We do not download or keep them.

Lawful basis: legitimate interests (UK GDPR Article 6(1)(f)): running a website that works and is secure.

3. Cookies and similar technologies

The website sets no cookies, and stores nothing in your browser (no local storage, no tracking pixels). So there is no cookie banner: none is needed.

• No analytics. We do not count or track visitors, with Cloudflare Web Analytics or anything else.
• Nothing from other companies. The fonts and pictures are stored on our own site, so your browser does not contact Google or anyone else to show them. The site's security settings stop pages loading anything from other websites.
• One small script switches the App Store button on when the app is available. It stores nothing and sends nothing.
• Cloudflare's network error reports. Cloudflare asks your browser to tell it if a page fails to load, so it can find and fix faults in its network. Your browser remembers this request for up to 7 days. A report is about the connection, not about you, but like any request it comes from your IP address. Only failures are reported.

Why no consent is needed: the law on cookies and similar technologies (the Privacy and Electronic Communications Regulations 2003, regulation 6) asks for consent before storing or reading information on your device, unless it is strictly necessary, for example to keep the service secure or to find technical faults (Schedule A1, paragraph 4). Our site stores nothing itself, and Cloudflare's error reports are for finding faults.

4. If we ever count visits

We have no plans to. If we ever switch on Cloudflare Web Analytics (which counts visits without cookies), we will update this notice before we do, explain what it collects and why, and give you a simple, free way to say no, as the law requires for statistics (Schedule A1, paragraph 5). Until this notice says so, it is off.

5. If you email us

If you email us, including through a "Get notified" link to ask to be told when the app is available, we receive your email address and what you write. Your message is handled by our email provider, which acts for us under its data processing terms and keeps mail only for us. If it stores mail outside the UK, we use a provider that protects it with safeguards UK law approves.

• "Get notified" requests: we keep your address only until we send you one email to say the app is available, and we use it for nothing else. We delete it within a month of sending that email. If you change your mind before then, reply and we will delete it straight away. Lawful basis: consent (you asked us to).
• Pre-orders: once BrightNods can be pre-ordered, "Get notified" opens its App Store page instead. If you pre-order there, Apple tells you when the app is available, and we receive nothing about you.
• Other emails: we keep them for 6 years, as our Privacy Notice explains in section 8. Lawful basis: legitimate interests (answering you).

6. Information stored outside the UK

Cloudflare runs a worldwide network, so the details of your visit may pass through Cloudflare computers outside the UK, including in the USA. Cloudflare, Inc. is certified under the UK Extension to the EU–US Data Privacy Framework (the "UK–US data bridge"), which UK law recognises as giving adequate protection, and Cloudflare's data processing terms rely on it. If that certification ever lapsed, the same terms say the EU standard contractual clauses, as amended by the UK Addendum approved by the Information Commission, would apply instead.

7. Your rights

You have the right to see the information we hold about you, and to have it corrected or deleted. You can object to any use based on legitimate interests and withdraw consent at any time. Email [[OWNER: privacy email]]. We reply within one month. We hold almost nothing from your visit ourselves; for Cloudflare's records we will ask Cloudflare to help where we can.

If you are unhappy with how we have handled your information, tell us first. We acknowledge complaints within 5 working days (the law allows up to 30 days), look into them and tell you the outcome. You can also complain to the Information Commission (which still uses the name ICO) at any time: online at ico.org.uk/make-a-complaint, or by phone on 0303 123 1113.

8. Children

The website is written for parents and carers. It does not collect anything from children. The app has a separate notice for children.

9. Changes

We will update this notice if the website changes, before the change takes effect. The version and date are at the top.