Gloaming privacy notice
DRAFT. This is not the final text. It has not been reviewed yet and will change before Gloaming is released.
1. Who we are
The person responsible for your data (the "controller") is:
[FULL NAME OF OWNER], trading as Gloaming [POSTAL ADDRESS] Email: hello@getgloaming.com ICO registration number: [NUMBER]
"We" in this notice means that person. Gloaming is a night-sky photography planner and learning app for a phone and for a computer. This notice covers both, and the website.
2. The short version
- You can use much of Gloaming without an account. Then your kit, places, posts and progress stay on your own phone or computer and we never receive them.
- With an account, we store what is listed in section 4 so your phone and computer share it. It is stored in Ireland.
- We don't sell your data. We have no advertising and no analytics or tracking software in the apps, and the web pages set no cookies.
- Some features contact other services directly (weather, maps, search). Those services see your internet address and the place you ask about. Section 6 lists them.
- An account is for adults (18 or over).
3. Where your data comes from
From you (what you type, choose, photograph and share), from your device (your location if you allow it, with the operating system asking you first), and from our own systems (for example which night alerts were sent).
4. What we use it for, and why we're allowed to
UK data protection law needs a reason, called a lawful basis, for each use.
| What we do | Data | Lawful basis |
|---|---|---|
| Run your account and sync it between phone and computer | Email, sign-in, profile, kit, places, targets, posts and their pictures, calendar, Learn progress, settings | Contract: it's what you asked for when you made an account |
| Work out forecasts, drive times and night alerts for your places | Your home and saved places, your alert choices | Contract |
| Send notifications you turned on | A device push address, the alerts sent to you | Consent (you switch alerts on, and the phone asks permission). You can withdraw it by turning them off |
| Use your location to show where things are in the sky and to centre forecasts | Your position, while the app is open | Consent (the phone asks each time you allow it; you can withdraw in phone settings) |
| Share things with other people, if Community is on | Name, handle, picture, bio, shots, comments, messages, spots, groups, events | Contract for what you choose to post; legitimate interests for keeping the community safe |
| Keep Gloaming safe: stop abuse, handle reports, appeals and suspensions | Reports and a copy of the reported content, actions taken, the account involved | Legitimate interests (keeping people safe and the service working) and, where the law requires it, legal obligation |
| Check that accounts are adults | Your age band (adult, 13 to 17 or under 13) and where it came from. An adult's birth date is not kept | Legitimate interests and legal obligation |
| Let invited testers try early features | Which account was switched on for which feature, by whom, when | Legitimate interests (running a safe test) |
| Fix bugs and answer you | Feedback you send (text, optional contact, app version, device), emails to hello@getgloaming.com | Legitimate interests |
| Keep records, accounts and tax records | Records of payments if paid features arrive | Legal obligation |
We don't use your data to make automated decisions about you with legal or similar effects.
5. Your location, said plainly
- "Where you are" is rounded to a grid of about 10 km before it is saved or used, and a live position is kept in memory only.
- A home you search for, a spot you drop at your position, and your shot log are exact. They are saved exactly because a dark-sky spot or a home forecast needs to be precise. They are your own choices. Your home is private: it is never shown to other people or put on a post. A spot you share shows a place rounded to about 1 km unless you choose to share the exact one.
- Photos you upload have their location data (EXIF) removed first.
- Learn's sky features use the rounded position and never write an exact one to your account.
6. Who receives your data
6.1 Companies that work for us (processors)
They handle data only on our instructions, under a data processing agreement.
| Who | What they get | Why | Where |
|---|---|---|---|
| Supabase (Supabase Pte. Ltd.) | All account data and files | Database, sign-in and file storage | Ireland (AWS eu-west-1). Its data processing agreement includes the UK addendum |
Expo [CONFIRM the company name] | Push addresses and the notification text; update checks from the app | Delivers notifications and app updates | United States. [CONFIRM: Expo's data processing terms and transfer route] |
| Google (Firebase Cloud Messaging) | A push address and the notification text, on Android | Delivers notifications to Android phones | Worldwide. Firebase Data Processing and Security Terms apply |
| Porkbun | Emails sent to hello@getgloaming.com, forwarded to us | Email forwarding | [CONFIRM] |
| GitHub | Your internet address and app version, on the computer app | Delivers app updates | United States |
[HOSTING / EMAIL / PAYMENT PROVIDERS ADDED LATER] |
6.2 Services you reach directly, or that receive data under their own policies
These aren't our processors. Each has its own privacy policy. We send them only what the feature needs.
| Who | What they get | When |
|---|---|---|
| Google (on Android) | Google Maps shows the maps and Google Play services supply your location. Google receives your internet address and what the map needs, and acts under its own Privacy Policy | When you open a map or allow location on Android. See section 6.3 |
| Apple | Sign-in, notifications, place names and Apple Maps on iPhone | iPhone |
| Open-Meteo | Your internet address and the coordinates you ask a forecast for. It logs requests for 90 days. It supplies forecast figures, including UK Met Office data | Every forecast |
| Photon (komoot) | The text you type in place search, a rounded position and your internet address | Place search on the phone |
| NASA (GIBS), NOAA, CelesTrak | Your internet address; for the NASA map layer, which map tile you view | Sky, space weather, satellite passes, night-lights layer |
| Wikimedia, CDS, SIMBAD, Wikipedia | Your internet address and the object name | Object information on the computer app, while it is used |
| Apple iTunes | The song text you search, and your internet address | Song search for posts, if you turn it on |
| OpenStreetMap-based and map services (Nominatim, postcodes.io, Overpass, OSRM, Esri) | Typed text or coordinates and your internet address | Place search, directions and map tiles on the computer app, while it is used |
| Anthropic, astrometry.net | Text or pictures you choose to send, using your own key | Only if you add your own key in Settings |
6.3 Google on Android, in more detail
Gloaming for Android uses three Google components: the Google Maps SDK for the spots map, Google Play services Location for your position, and Firebase Cloud Messaging for notifications.
- Your use of Google Maps features and content is subject to the Google Maps End User Additional Terms of Service (https://maps.google.com/help/terms_maps/) and the Google Privacy Policy (https://policies.google.com/privacy).
- Location is requested only while the app is open ("foreground"). You can turn it off in the phone's settings.
- iPhone uses Apple Maps, so none of this applies there.
6.4 Others
We may share data where the law requires it, with the police or a regulator when someone is at risk, or to protect our rights. If the business is sold, the new owner would take this notice with the data.
7. How long we keep it
| What | How long |
|---|---|
| Account data (profile, kit, places, posts, progress, messages and so on) | Until you delete your account. Rows tied to you are deleted with it |
| Files you uploaded (post slides, shared photos) | Until you remove them or delete your account. Deleting your account queues every file for removal, and a sweep removes them within hours; a file an open report points at waits for that report |
| Reports and the copy of reported content ("evidence") | 12 months, then deleted. They stay when you or the other person deletes an account, because the point is to keep people safe. Your name is removed from the link, but words you wrote stay in the copy until it is deleted. A report with an open appeal waits for the decision |
| The team's action log (the "audit log") | At least 3 years. It records what team members did, including switching a feature on for a named tester account, with the account id and nothing else about you (never your email). It is kept after you delete your account, so the record stays honest |
| Feedback you sent | The text stays after you delete your account, with your link to it removed |
| Moderation actions about you, suspensions and appeals | Until you delete your account |
| Server logs | [CONFIRM the Supabase log retention once it is set, for example 30 days] |
| Requests to Open-Meteo | 90 days at Open-Meteo (their policy) |
| Data on your own device | Until you delete it or the app. Uninstalling the computer app keeps its data folders; delete them to remove everything |
8. Moving data abroad
Your account data is stored in Ireland. Expo, Google, GitHub and some map and weather services are in or reachable from other countries, including the United States. Where UK data protection law requires it, those transfers use an adequacy decision (for example the UK-US data bridge), or standard contract clauses and the UK addendum. [CONFIRM each route before publishing; PR15 says to keep a dated copy of each agreement.]
9. Your rights
Under UK data protection law you can:
- see the data we hold about you, and get a copy;
- have wrong data corrected;
- have your data deleted: use You > Account > Delete account in the phone app, or email us (the computer app: email us until it has its own button);
- restrict or object to some uses, including anything we do on the basis of legitimate interests;
- move your data (you can ask us for an export; a self-service export is planned);
- withdraw consent at any time (turn off alerts or location in the app or the phone's settings).
Email hello@getgloaming.com. We reply within one month. We may need to confirm it's you.
10. Complaints
Tell us first: write to hello@getgloaming.com or to the address above. We acknowledge a complaint within 30 days and reply without undue delay. You can also complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113.
11. Children
Accounts are for people aged 18 or over, and the sign-up asks for your age band. If we learn an account belongs to someone under 18, we close it. Without an account, anyone can use the on-device parts of Gloaming, and we hold no data about them. Family accounts aren't offered.
12. Security
Everything in Supabase is protected by row-level rules so that, unless a feature says otherwise, only you can read your own rows. Your sign-in and any keys you add on the computer app are encrypted by the operating system. No system is perfectly secure; if a breach puts you at risk we'll tell you and, where required, the ICO.
13. Changes
We'll update the date at the top and tell you in the app if a change matters. Older versions are kept on request.