NOCTIS
PRIVACY POLICY
Last updated: [DATE — fill before publishing]
⚠ DRAFT TEMPLATE — This policy has not yet been reviewed by a solicitor or data-protection adviser. All [BRACKETED] fields must be completed with accurate information before this policy is published. Do not rely on this as legal advice.
This Privacy Policy explains how [YOUR COMPANY / YOUR NAME] ("we", "us", "our") collects, uses, and protects your information when you use the Noctis mobile application ("the App"). We are the data controller for the purposes of UK data protection law (UK GDPR and the Data Protection Act 2018).
Contact: [CONTACT NAME], propertywalker@gmail.com, [POSTAL ADDRESS]
[If applicable: Data Protection Officer / ICO registration number: [NUMBER]]
1. WHAT THIS APP DOES
Noctis is a paranormal-investigation entertainment app. It uses your device's sensors to create an immersive ghost-hunting experience, including a location-based 'Hunt' mode that suggests publicly-accessible places to visit.
2. INFORMATION WE COLLECT
a) Location data.
With your permission, we access your device's GPS/location to determine the general area you are in so we can show nearby Hunt-mode content, and to enable location-based features and safety functions. Your approximate location is sent to our AI provider to generate locally relevant spirit stories. We do not store a history of your precise location on our servers.
b) Camera and microphone.
With your permission, the App uses your camera and microphone for investigation features (e.g. AR view, audio capture). Camera and microphone data is processed live on your device and not recorded or stored. No video or audio is transmitted to our servers.
c) Motion and orientation sensors.
The App reads device motion and compass sensors to position AR elements. This data is processed on-device only and is not stored or transmitted.
d) Content you create.
Evidence Cards, journal entries, your investigator username, XP progress, and captures are stored locally on your device using browser localStorage. We do not sync this content to external servers.
e) Device and usage information.
We may collect basic technical data (device type, OS version, app version, crash logs, anonymous usage analytics) to operate and improve the App.
f) Third-party AI and voice services.
Spirit dialogue is generated using Anthropic (Claude). Your typed or spoken questions and general location context are sent to Anthropic to generate responses. Spirit voices are generated using ElevenLabs. Generated text is sent to ElevenLabs to produce audio. Please review Anthropic's privacy policy at anthropic.com and ElevenLabs' policy at elevenlabs.io for details on how they handle data. We recommend reviewing whether these providers retain submitted data under their current terms.
3. WHY WE USE YOUR INFORMATION (LAWFUL BASES)
We process your data on the following UK GDPR lawful bases:
• Consent — for camera, microphone, and precise location access. You can withdraw consent at any time in your device settings.
• Legitimate interests — to operate, secure, and improve the App.
• Performance of a contract — to provide features you request.
4. SHARING YOUR INFORMATION
We do not sell your personal data. We share data only with service providers who help us run the App (including Anthropic and ElevenLabs as named above, and Stripe for payment processing), under appropriate agreements, and with authorities where required by law. Payment data is handled entirely by Stripe — we never see your card details.
5. INTERNATIONAL TRANSFERS
Some providers (including Anthropic and ElevenLabs) may process data outside the UK. Where they do, we rely on appropriate safeguards such as UK adequacy regulations or the International Data Transfer Agreement (UK IDTA).
6. HOW LONG WE KEEP DATA
On-device content (evidence, journal, XP data) remains until you delete it or uninstall the App. We do not retain server-side records of your sessions. Crash and analytics data is retained for a reasonable operational period and then deleted.
7. YOUR RIGHTS (UK GDPR)
You have the right to: access your data; correct it; erase it; restrict or object to processing; data portability; and to withdraw consent at any time. To exercise these rights, contact us at propertywalker@gmail.com. As all primary data is stored locally on your device, you retain full control at all times and can delete it by clearing app storage or uninstalling. You can also complain to the UK Information Commissioner's Office (ICO) at ico.org.uk.
8. CHILDREN
This App is intended for users aged 16 and over. The Hunt mode involves visiting real-world locations and is not suitable for younger users. We do not knowingly collect data from anyone under 16. If you are under 16, please do not use this App.
9. LOCATION SAFETY AND YOUR RESPONSIBILITY
Hunt mode suggests publicly-accessible vantage points but cannot guarantee any location is safe, open, or accessible at any given time. You are responsible for your own safety and surroundings. Do not play while driving or cycling, do not trespass, and follow all local laws. See our Terms of Use for full safety terms.
10. SECURITY
We use reasonable technical and organisational measures to protect your data. No system is perfectly secure and we cannot guarantee absolute security.
11. CHANGES TO THIS POLICY
We may update this policy from time to time. We will post changes here and update the "Last updated" date. Continued use of the App after material changes constitutes acceptance of the updated policy.
12. CONTACT
For any privacy-related questions: propertywalker@gmail.com
COMPLETION CHECKLIST (do before publishing)
☐ Fill every [BRACKETED] field with accurate, real information.
☐ Make Sections 2 and 4 EXACTLY match what the App actually does.
☐ Confirm what is sent to Anthropic and ElevenLabs and whether it is retained; link their privacy policies.
☐ Decide and state a minimum age, consistent with your Terms of Use.
☐ Host at a public URL; link it in the Google Play Data Safety form, the store listing, and inside the App.
☐ Complete Google Play's separate Data Safety form to match this policy.
☐ Have a solicitor / data-protection adviser review before launch.
☐ Check whether you must register with the ICO as a data controller (ico.org.uk).
NOCTIS is an AI-generated entertainment experience. Not genuine paranormal detection.