ForTotalRecall Ltd

Smart Photo Service

Customer Data Privacy Policy

Last modified: 20th August 2025

OVERVIEW

ForTotalRecall Ltd is the developer of the Smart Photo Service Customer app. This document outlines our policies regarding the collection, use, and protection of personal data provided by users of our app and associated cloud services.

We are committed to safeguarding the privacy of our users and ensuring compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

COMPLIANCE

This policy complies with the UK GDPR and the Data Protection Act 2018. We have implemented appropriate technical and organisational measures to ensure compliance with the seven data protection principles, including:

• Lawfulness, fairness, and transparency
• Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Integrity and confidentiality
• Accountability

If you have concerns about our data practices, please contact us at: jackkirkxxx@gmail.com

PERSONAL DATA COLLECTED

When a Smart Photo Service account is created, we collect the following personal data:

• Likely first language
• Email address or smartphone number
• Moniker used
• Account subscription type (e.g., junior/senior)

We do not collect personal data during app download or upgrade.

Users may optionally provide a self-portrait via the host smartphone’s camera. This image is considered biometric data under UK GDPR and is handled with enhanced safeguards.

DATA SECURITY MEASURES

We take the following steps to protect personal data:

• Limit data collection to the minimum necessary
• Conduct regular vulnerability assessments
• Use secure communications (e.g., HTTPS)
• Apply scoped credentials for cloud services
• Implement encryption and code obfuscation where appropriate
• Restrict access to personal data to authorised personnel only

DATA ACCURACY

Personal data is either provided directly by the customer or via a third-party ticketing system. We rely on individuals to ensure their data is accurate and up to date.

INDIVIDUAL RIGHTS

Under UK GDPR, individuals have the right to:

• Access their personal data
• Rectify inaccurate data
• Erase data (“right to be forgotten”)
• Restrict or object to processing
• Data portability
• Withdraw consent at any time

To exercise these rights, customers may email goapecustomer@gmail.com with their Smart Photo Service account number (e.g., 00a978f7-7c42-4a26-aa38-59c3e3de1291).

DATA RETENTION

• Self-portraits and videos taken in GoApe parks are automatically deleted after 124 days
• Account-related data is deleted after 365 days
• Log data is retained only as long as necessary for analytics and security purposes

PURPOSE LIMITATION

We only collect and process personal data for purposes directly related to the operation of the Smart Photo Service. We do not use or disclose data for unrelated purposes.

CONSENT

All personal data is provided voluntarily by the customer. Where biometric data is involved, we seek explicit consent prior to processing.

DIRECT MARKETING

We do not use personal data for direct marketing purposes.

LOG DATA

We collect anonymised usage statistics such as:

• IP address
• Time and date of app usage
• Duration of session
• Device type and OS

We may use third-party analytics services (e.g., Google Analytics) to monitor and improve app performance.

LOCATION DATA

Our customer apps do not collect location data.

CHANGES TO THIS POLICY

We may update this privacy policy from time to time. Any changes will be reflected in the “last modified” date. Continued use of the app constitutes acceptance of the updated policy.