Privacy Policy

Version: 3.1

Last Updated: 28/09/2026

1. Introduction

This Privacy Policy (the "Policy") describes how Watchers App Limited, a company incorporated in England and Wales (registration number 13562970) with its registered office at 4 Hill Street, Mayfair, London W1J 5NE, United Kingdom (the "Company", "we", "us"), collects, uses, stores, discloses and otherwise processes personal data in connection with access to and use of the website located at https://watchers.io (the "Website").

The Company acts as the data controller in respect of personal data processed through the Website within the meaning of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

This Policy does not apply to personal data processed by the Company on behalf of its clients within the Watchers SaaS platform, where the Company acts as a processor. Such processing is governed by the Watchers Data Processing Addendum (https://watchers.io/legal/dpa) and the client's own privacy notice.

2. Scope of Application

This Policy applies to personal data collected in connection with: (a) access to and use of the Website; (b) submission of enquiries, contact forms or other communications via the Website; and (c) the use of cookies and similar technologies on the Website.

3. Categories of Personal Data Collected

3.1 Information Collected Automatically

When an individual accesses the Website, the Company may automatically collect certain technical and usage information, including but not limited to Internet Protocol (IP) address, browser type and version, device type, operating system, language preferences, referring URLs, pages viewed, date and time of access and other usage data.

Such information is processed to ensure the proper functioning and security of the Website, to prevent misuse, to analyse Website performance (subject to consent where required) and to improve the user experience.

3.2 Information Provided Voluntarily

Where an individual submits an enquiry, requests a demo or otherwise contacts the Company through the Website, the Company collects the information provided, which may include name, email address, telephone number, organisation name, job title, country and any other information voluntarily provided.

Such information is used to respond to enquiries, to provide requested information, to assess and pursue potential business relationships and to communicate with the individual about the Company's services.

4. Legal Bases for Processing

4.1 Consent

Where required by law, including in relation to analytics cookies, the Company processes personal data on the basis of the individual's consent pursuant to Article 6(1)(a) UK GDPR. Consent may be withdrawn at any time via the "Cookie Settings" link on the Website.

4.2 Legitimate Interests

The Company processes personal data where such processing is necessary for the purposes of its legitimate interests pursuant to Article 6(1)(f) UK GDPR, including ensuring the security and integrity of the Website, operating and improving the Website, responding to enquiries and developing business relationships, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the individual.

4.3 Performance of Contract or Pre-Contractual Steps

Where an individual submits an enquiry relating to potential services, processing may be necessary to take steps at the request of the individual prior to entering into a contract, pursuant to Article 6(1)(b) UK GDPR.

4.4 Compliance with Legal Obligations

The Company may process personal data where required to comply with applicable legal obligations pursuant to Article 6(1)(c) UK GDPR.

5. Cookies and Tracking Technologies

The Website uses cookies and similar technologies to ensure functionality, enhance performance and, subject to consent, collect analytics information.

Analytics services currently used include Google Analytics (Google LLC) and HubSpot, Inc. The Website is delivered and protected through content delivery and security services provided by Cloudflare, Inc., which may set strictly necessary cookies for security purposes.

Analytics cookies are deployed only following explicit user consent and are governed by the Company's Cookie Policy, available at: https://watchers.io/legal/cookie-policy.

6. Disclosure of Personal Data

The Company may disclose personal data to third parties in the following circumstances:

(a) to service providers engaged to support Website functionality, hosting, content delivery and security, analytics, IT services, customer support and customer relationship management. Such service providers currently include:

These service providers process personal data under contractual safeguards and only on documented instructions. A current list of all sub-processors engaged by the Company, including those engaged in respect of the Watchers SaaS platform, is maintained at https://watchers.io/legal/sub-processors and is updated from time to time;

(b) to competent public authorities where required by applicable law, regulation or legal process; and

(c) to other recipients where the individual has provided explicit consent.

The Company does not sell personal data.

7. International Transfers

Certain service providers engaged by the Company, including those listed in Section 6 and at https://watchers.io/legal/sub-processors, may process personal data outside the United Kingdom or the European Economic Area, including in the United States.

Where personal data is transferred outside the United Kingdom or the European Economic Area, the Company implements appropriate safeguards in accordance with applicable data protection law. Such safeguards include reliance on adequacy decisions, UK-approved International Data Transfer Agreements (IDTA) or the UK International Data Transfer Addendum, the Standard Contractual Clauses approved by the European Commission and, where applicable, certification of the recipient under the UK Extension to the EU-US Data Privacy Framework.

8. Data Retention

The Company retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying legal, regulatory, accounting or reporting requirements.

Contact form data shall generally be retained for the duration necessary to respond to the enquiry and to manage any subsequent business discussions.

Analytics data retention periods are determined by configuration settings within the relevant analytics tools.

Where processing is based on consent, personal data shall be retained until consent is withdrawn, unless another lawful basis applies.

9. Data Security

The Company implements appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Such measures are proportionate to the risks presented by the processing and may include access controls, encryption in transit, secure hosting environments, and regular system monitoring.

10. Data Subject Rights

Subject to applicable law, individuals may have the right to: (a) request access to their personal data; (b) request rectification of inaccurate or incomplete data; (c) request erasure of personal data; (d) request restriction of processing; (e) object to processing based on legitimate interests; (f) request data portability, where applicable; and (g) withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

Individuals also have the right to lodge a complaint with the Information Commissioner's Office (ICO) in the United Kingdom.

Requests may be submitted to [email protected];. The Company may request reasonable verification of identity prior to responding to such requests.

11. Individuals in the European Economic Area

Where the processing of personal data of individuals located in the European Economic Area ("EEA") is subject to the EU GDPR, the legal bases described in Section 4 above apply by reference to the corresponding provisions of Article 6(1) EU GDPR, and the rights described in Section 10 apply by reference to the corresponding provisions of the EU GDPR.

Individuals in the EEA have the right to lodge a complaint with the supervisory authority of the EU Member State of their habitual residence, their place of work or the place of the alleged infringement.

Requests may be submitted to [email protected].

12. California Privacy Rights

This Section applies to natural persons who are California residents and supplements the remainder of this Policy, to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"), applies to the Company.

In the preceding twelve (12) months, the Company has collected the following categories of personal information, as described in Section 3: identifiers (such as name, email address, telephone number and IP address); professional or employment-related information; and internet or other electronic network activity information. Such information is collected from the sources, for the purposes and disclosed to the categories of recipients described in Sections 3, 5 and 6.

The Company does not sell personal information and does not share personal information for cross-context behavioural advertising.

California residents have the right to: (a) know and access the personal information collected about them; (b) request deletion of personal information; (c) request correction of inaccurate personal information; (d) opt out of any sale or sharing of personal information; and (e) not receive discriminatory treatment for exercising their rights.

Requests may be submitted to [email protected]. The Company will verify requests in accordance with the CCPA and may permit an authorised agent to submit a request on an individual's behalf.

13. Canadian Residents

Where the Personal Information Protection and Electronic Documents Act ("PIPEDA") or substantially similar provincial legislation applies, the Company processes personal information with the knowledge and consent of the individual, except where otherwise permitted or required by law.

Consent may be express or implied depending on the sensitivity of the information and the reasonable expectations of the individual, and may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice.

Individuals in Canada may request access to, or correction of, their personal information, and may address questions or complaints about the Company's handling of personal information to [email protected]. Individuals also have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada.

The Company sends commercial electronic messages to recipients in Canada only in accordance with Canada's Anti-Spam Legislation ("CASL"): on the basis of express consent or implied consent (for example, an existing business relationship), with clear identification of the sender and a functioning unsubscribe mechanism, actioned within ten (10) business days.

14. Brazilian Residents

Where the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados, Law No. 13,709/2018, "LGPD") applies, the Company processes personal data on the legal bases set out in Article 7 LGPD, including consent, compliance with legal obligations, the performance of contracts and preliminary procedures relating thereto, and the legitimate interests of the Company.

Brazilian residents have the rights set out in Article 18 LGPD, including confirmation of the existence of processing, access, correction, anonymisation or deletion, portability, information regarding sharing, and withdrawal of consent, and may lodge a complaint with the Brazilian National Data Protection Authority (ANPD).

Requests may be submitted to [email protected].

15. Marketing Communications

The Company may send marketing and promotional communications about its services by email. Such communications are sent: (a) with the recipient's consent; (b) where permitted, to existing customers in relation to similar services, with the opportunity to object at the time of collection and in every communication; (c) to recipients in Canada, only in accordance with CASL as described in Section 13; and (d) to recipients in the United States, in accordance with the CAN-SPAM Act.

Every marketing email identifies the Company, includes its contact details and contains an unsubscribe mechanism.

Individuals may opt out of marketing communications at any time by using the unsubscribe link in any such email or by contacting [email protected]; opt-out requests are honoured promptly and in any event within the periods required by applicable law.

Opting out of marketing communications does not affect service or transactional communications.

16. Children

The Website is intended for business users and is not directed to individuals under the age of eighteen (18). The Company does not knowingly collect personal data from children. If the Company becomes aware that personal data has been collected from a child without appropriate consent, it will take steps to delete such data.

17. Amendments to This Policy

The Company reserves the right to amend this Privacy Policy from time to time in order to reflect changes in applicable law, regulatory guidance, technology or operational practices.

Any revised version shall be published on the Website together with an updated "Last Updated" date and version number.

Where changes are material, the Company will take reasonable steps to bring them to the attention of Website users, for example by means of a prominent notice on the Website.

Continued use of the Website following publication of an updated version constitutes acknowledgement of the revised Policy; where applicable law requires consent to such changes, the Company will obtain it.

Contact

Watchers App Limited

4 Hill Street, London, England, W1J 5NE

[email protected];

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