Somewhere Safe privacy policy (draft for legal review)
Status: draft v0.1. Not to be published as final until reviewed by a solicitor. Written in
plain English on purpose; the reviewer should keep it that way.
Who we are
Somewhere Safe is made by STNC LTD, registered in England and Wales, company no. 14679419 ("STNC", "we"). We are the data controller. Contact: support@stnc.com.
The short version
- What you keep in your vault is encrypted on your device with a passphrase only you know. We store the scrambled result. We cannot read it, and neither can anyone who gets hold of our servers.
- We keep the minimum needed to run the service: your email, sign-in identifier, when things changed, how big they are, who you have shared with, and who you have named as someone you trust.
- We do not sell data, run ads or use trackers.
What we hold and why
| Data | Why | Legal basis | Kept |
|---|---|---|---|
| Email address and sign-in identifier (Google, Apple or email link via Firebase Authentication) | To know which account is yours and to send you the notices described below | Contract | Until you delete your account |
| Encrypted vault contents (items, files) and the encrypted keys that open them | To store them and sync them between your devices | Contract | Until you delete them or your account |
| Sizes, timestamps and counts of items and files | To run the service and enforce storage limits | Contract | While the item exists |
| Reminder fire times (dates only, no detail) | To send "something is expiring soon" | Contract | Until sent |
| Who you have shared an item with and who you have named as someone you trust, and the state of any access request | To run sharing and the trusted-access protocol described in the Terms | Contract | Until removed; audit rows for access requests kept 12 months after the relationship ends |
| Notices we sent you (subject and time) | So you can see them in the app and so we can prove we told you | Legitimate interest | 12 months |
| Server logs (IP address, request path with secrets removed, time) | Security and debugging | Legitimate interest | 30 days |
| Waitlist email | To write once when your place comes up | Consent | Until you are let in or ask to be removed |
We do not receive your passphrase, your recovery words, your vault key, or the contents of anything you store. Text recognition of photos happens on your device.
Where it is stored
Encrypted contents and metadata are held on servers in the United Kingdom or European Union (Amazon Web Services). Sign-in is provided by Google Firebase Authentication, which may process your email and sign-in identifier in the United States under Google's standard contractual clauses. Email notices are sent through Amazon SES.
Sharing and someone you trust
When you share an item or name someone you trust, we tell them your email address and, once access is granted, give their device the encrypted material needed to open what you allowed. We hold one half of a split key for each person you trust and release it only when the protocol in the Terms reaches "granted". We never hold enough on our own to open your vault.
Your rights
You can see, export and delete everything from Settings in the app. Export produces a file decrypted on your device; we never see it. Deleting your account removes your vault, files, shares and trusted-access relationships immediately and purges backups within 30 days.
You also have the right to object, to restrict processing and to complain to the Information Commissioner's Office (ico.org.uk). Email support@stnc.com for anything you cannot do in the app.
Children
Somewhere Safe is for people aged 16 and over.
Changes
We will email account holders before any change that affects what we hold or why.