UnFog Ltd — Privacy Notice (v3.0, July 2026)
Who we are
UnFog Ltd ("UnlockCity", "we") is the data controller for the UnlockCity app. Contact: contact@unlockcity.app.
The short version
· Your location powers the map and, once you sign in, syncs to your encrypted backup so it restores on a new device — never sold, never shared for ads.
· Challenge photos are uploaded only to check your find, then automatically deleted within 30 days.
· No usage analytics — we don't track how you use the app.
· We never sell personal data, show no ads, and do no cross-app tracking.
What we collect and why
· Account — email address, salted password credential, display name and optional profile photo, handled by our own authentication service. Our email delivery provider receives your address only when sending registration or password-reset codes. Needed to create and secure your account. (Legal basis: contract.)
· Experience — chosen city, Weekly Passes and purchases, hunt progress and attempts, completed Memories. Stored on your device; included in your encrypted account backup once you're signed in. (Contract.)
· Location — used to centre the map, show nearby places and pick local phrases. Your position, the places you visit and the areas you explore are stored on your device and, when you're signed in, included in your encrypted account backup so your map and progress restore on a new device. Location is never shared with other users, sold, or used for advertising. (Contract.)
· Photos — when you snap a find, the photo is sent over an encrypted connection to our verification service to check it against the challenge. For borderline cases an AI vision service assists the check. Verification photos and their results are kept for up to 30 days — so we can resolve disputes about a rejected find and prevent abuse — then deleted automatically. Souvenir photos and Memory films live on your device (and in your backup once you're signed in). Photos are never used to train AI models without your separate opt-in consent. (Contract.)
· Voice — questions to the AI guide are transcribed by your device's built-in speech recognition; only the final text is sent to our AI provider to generate an answer. (Contract.)
· Service logs — short-lived technical logs (timestamps, app version, error traces) to keep the service safe and fix faults. (Legitimate interest.)
Who processes data for us
We use a small number of service providers, each under a data-processing agreement: an email delivery provider (registration and password-reset codes), a cloud host (authentication, backend and backups), AI vision and language providers (photo checks and guide answers), and map-tile providers (OpenStreetMap/CARTO receive your IP address when tiles load, like any website you visit). We never sell your data and never share it for advertising.
International transfers
Where a provider processes data outside the UK/EEA we rely on adequacy decisions or standard contractual clauses (UK IDTA / EU SCCs).
How long we keep things
· Verification photos and check results: up to 30 days, then automatic deletion.
· Technical logs: up to 30 days.
· Verification/reset codes and their one-time continuation tokens: 10 minutes. Login sessions: 30 days.
· Account and backup data: until you delete your account; removal from backups completes within 30 days.
· Data on your device: until you delete it or the app.
Your rights
Under UK GDPR / GDPR you may access, correct, export or erase your data, object to or restrict processing, and withdraw consent at any time. "Export my data" and "Delete account & device data" are in Settings and take effect without contacting support. California residents: we do not sell or share personal information as defined by the CCPA/CPRA; the rights to know and delete are covered by the same Settings controls. Complaints: your local supervisory authority (ICO in the UK).
Children
UnlockCity is not directed at children under 13. Family features are designed for adults exploring with their own children; we do not knowingly collect children's data and will delete it on notice.
AI transparency
Photo verification and the guide use AI. They can make mistakes, and no decision with legal or similarly significant effects is made about you automatically.
Changes
We will notify you in the app of material changes to this notice.
Contact: contact@unlockcity.app · UnFog Ltd, London, United Kingdom