Thank you for choosing to be part of our community at Siccura Ltd, doing business as Siccura (“Siccura”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@siccura.com

When you visit our website www.siccura.com, mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously and that is why we maintain a Zero-Knowledge policy. When you use our services, the information you provide is converted into a unique unbreakable code that even we cannot read (see the section headed “What is our Zero-Knowledge policy?”). In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. Take some time to read through it carefully, as it is important. If there are any terms in this policy that you do not agree with, please discontinue use of our Sites or Apps and our Services.

This privacy policy applies to all information collected through our website (such as www.siccura.com), mobile application (“Apps”), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites”).

Please read this privacy policy carefully. It applies to all interactions you have with any of the Siccura Sites and Apps and it will help you make informed decisions about sharing your personal information with us.

Table of Contents

1. What is our Zero-Knowledge policy?
2. What information we do not collect?
3. What information do we collect?
4. How do we use your information?
5. Will your information be shared with anyone?
6. Who will your information be shared with?
7. Do we use cookies and other tracking technologies?
8. Is your information transferred internationally?
9. What is our stance on third-party websites?
10. How long do we keep your information?
11. How do we keep your information safe?
12. Do we collect information from minors?
13. What are your privacy rights?
14. Controls for do-not-track features
15. Do we make updates to this policy?
16. How can you contact us about this policy?

1. What is our Zero-Knowledge policy?

In Short: We do not know who you are, what your communications are or who you are talking to.

We take your privacy very seriously and that is why we maintain a Zero-Knowledge policy. When you use our services, the personal information you provide (such as your mobile number and email address) is encoded at source on your device using a one-way hash algorithm. This algorithm converts the data into a unique unbreakable code that even we cannot read. There is no point in time when your personal data is visible to the servers or service administrators.

We make your content readable to you alone. Most encryption systems only encrypt your data during transmission. This means that anyone with physical access to the servers on which your data is stored (such as the company’s staff) could have access to it.

The one-way encoding process we use is comprehensive – even with physical access to the servers, third-parties and even Siccura cannot read your data. All they can see are sequentially numbered rows of encoded undecipherable data.

Your message content and data for your third-party service providers (such as Gmail, Outlook or Google Drive) is never sent to the Siccura servers. If you choose to have a Siccura IM account or a Siccura Cloud account, your content and data will follow the same comprehensive encryption process and will be stored on the Siccura server. In both cases, your device will encrypt the message content and send it to the server. Your third-party service provider and even Siccura will not be able to decrypt and read your content. Only you have the ability to decrypt and read your data. The encryption key required to decrypt the data you share with a friend is sent via a separate channel using a separate Siccura server. This encryption key is also encrypted by your device and only you will be able to decrypt it, even Siccura will not be able to access this data.

All data passing through the client is encrypted by default and plain data (in a readable format) never leaves your device unless you specifically select it. Your private encryption key used to encrypt the data is never shared with anyone, even Siccura does not have it.

You can also sync your contacts with the Siccura servers so that you can connect with your friends. This contact data also follows our strict Zero Knowledge policy, which means that it is encoded at source using a one-way hash algorithm. This algorithm converts the data into a unique unbreakable code that even we cannot read. There is no point in time when your contact data is visible to the servers or service administrators.

At registration you have the option to enter an email address so that we can send you marketing and promotional updates. This information will be encrypted but it will not be converted using a one-way hash algorithm into a unique unbreakable code because we may need to read the data so that we can send you marketing and promotional updates and for password recovery purposes.

Some of the data you provide may need to be decrypted for lawful purposes and for compliance with our legal obligations.

2. What information we do not collect?

In Short: We do not collect your personal data or content such as your email content, SMS message content, cloud content etc.

We do not collect any of your personal content that you may choose to synchronise with our Apps, including any data from third party service providers such as Google (Gmail, Drive, etc.).

We do not collect any of your personal content that you access through the Sites or Apps, such as the content you store on cloud storage platforms, your email content or attachments, SMS message content etc.

3. What information do we collect?

Personal information you disclose to us

In Short: We collect encrypted personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.

We maintain a Zero-Knowledge policy. When you use our services, the information you provide is converted into a unique unbreakable code that even we cannot read (see the section headed “What is our Zero-Knowledge policy?”).

We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or Apps (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your name, email address, phone number, country, and other similar contact data. All of which follows our Zero-knowledge policy.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We use third-party processors such as Google Play Store, Apple App Store, and PayPal to process your payments. If you make purchases, data necessary to process your payment, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument may need to be collected. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

If you choose not to provide certain data, the quality of your experience may be impacted.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites or Apps for security, analytics and reporting purposes.

We automatically collect certain information when you visit, use or navigate the Sites or Apps. The information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your:

• IP address
• Browser and device characteristics
• Operating system
• Language preferences
• Referring URLs
• Device name
• Country
• Location
• Information about how and when you use our Sites or Apps
• And other technical information

This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Information collected through our Apps

In Short: We may collect information regarding your geo-location and mobile device when you use our apps to provide location based services.

If you use our Apps, we may also collect the following information:

• GeoLocation Information. We may request access or permission to track locationbased information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s calendar, camera, contacts, microphone, reminders, sensors, SMS messages, and storage to provide additional features within the Sites or Apps. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Push Notifications: We may request to send you push notifications regarding your account or the mobile application. If you wish to optout from receiving these types of communications, you may turn them off in your device’s settings.
• Log Data: We may use the log data generated through the use of our Apps for continuous improvement and bug fixes.

Information collected from other sources

In Short: We may collect limited data from third party service providers, public databases, marketing partners, other outside sources and from other users to help us diagnose and fix issues.

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. We work with companies to help distribute our apps and they may provide information about you in certain circumstances; for example, app stores may provide us with reports to help us diagnose and fix issues.

4. How do we use your information?

In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We maintain a Zero-Knowledge policy. When you use our services, some of the information you provide is converted into a unique unbreakable code that even we cannot read (see the section headed “What is our Zero-Knowledge policy)

We use personal information collected via our Sites and Apps, except for the information as mentioned in “What information we do not collect?” above, for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contact with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We do not collect any of your personal content that you access through the Sites or Apps, such as the content you store on cloud storage platforms, your email content or attachments, SMS message content etc.

We may use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a thirdparty account (such as your Google account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
• To send you marketing and promotional communications. If you choose to provide certain data, we and/or our thirdparty marketing partners may use the information you send to us for our marketing purposes, only when you have opted in. You can opt-out of our marketing emails at any time (see the section headed “What are your privacy rights?”).
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfil and manage your orders. We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the Sites or Apps.
• To protect our Sites. We may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
• To enable userto-user communications. We may use your information in order to enable userto-user communications with each user’s consent.
• To enforce our terms, conditions, and policies.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites or Apps, products, services, marketing and your experience.

5. Will your information be shared with anyone?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.

We may process or share data based on the following legal basis:

• Consent. We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Legitimate Interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contact. Where we have entered into a contact with you, we may process your personal information to fulfil the terms of our contract.
• Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information, except information as mentioned in “What information we do not collect?” above, in the following situations:

• Other Siccura Users.  To ensure transparency between users, the sender of an Email via Siccura application has the ability to view when the receiver has opened the Email, how many times it was opened and the IP address from where such Email was opened. We do not have the ability to view the receiver’s information as this feature is only available to the users of Siccura.
• Vendors, Consultants, and Other ThirdParty Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

6. Who will your information be shared with?

In Short: We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have categorised each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

• Allow Users to Connect to their Third Party Accounts
  • Google Account
• Data Backup and Security
  • Google Drive and Dropbox Backup
• User Account Registration and Authentication
  • Google OAuth 2.0
• Web and Mobile Analytics
  • Google Analytics for Firebase

7. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

8. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Sites or Apps from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see the section headed “Will your information be shared with anyone?”), in United States, and other countries.

9. What is our stance on third-party websites?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

The Sites or Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked or from the Sites or Apps. You should review the policies of such third parties and contact them directly to respond to your questions.

10. How long do we keep your information?

In Short: We keep your information for as long as it is necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law. We never have access to your message content or data.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymise it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your message content and data is never sent to our servers. The client will encrypt the message content and send it via your third-party service provider (e.g. Gmail), the encryption key required to decrypt the message on the other end is sent via a separate channel.

11. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.

No transmission over the internet is completely secure, so we can’t absolutely guarantee that unauthorized parties won’t be able to defeat our security measures. You use Siccura at your own risk and are responsible for taking reasonable measures to secure your account (such as choosing a strong, unique password and keeping it secret).

12. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 13 years of age.

We do not knowingly collect data from or market to children under 13 years of age. By using the Sites or Apps, you represent that you are at least 13 or that you are the parent or guardian of such minor and consent to such minor dependant’s use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data, we have collected from children under the age of 13, please contact us at support@siccura.com

13. What are your privacy rights?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right:

1. To request access and obtain a copy of your personal information
2. To request rectification or erasure
3. To restrict the processing of your personal information
4. And, if applicable, to data portability.

In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact information provided. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account
• Contact using the contact information provided

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps. To opt-out of interest-based advertising by advertisers on our Sites or Apps visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may contact us using the details provided.

14. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanisms that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

15. Do we make updates to this policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

16. How can you contact us about this policy?

If you have questions or comments about this policy, you may email us at support@siccura.com or by post to:

Siccura Ltd

13 Montpelier Avenue

Bexley, Kent

DA5 3AP

United Kingdom

Last modified: 22nd Jan 2020