Privacy Policy

ZAHN UK Management Ltd ("ZAHN", "we", "us") is the controller of your personal data. This means we decide how and why it is used. ZAHN UK Management Ltd has a sister company under the same ownership, ZAHN Ltd, a company registered in Cyprus (registration number HE 326378). ZAHN Ltd owns the ZAHN trade marks and publishes the ZAHN app on the App Store.

• Company number: 15851312
• Registered office: 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT, United Kingdom
• ICO registration: we applied to register with the Information Commissioner's Office on 14 October 2026. We will add our registration number here once the ICO confirms it.
• Privacy contact: legal@zahnapp.com
• Data Protection Officer: we have appointed a Data Protection Officer. You can contact them at legal@zahnapp.com.
• EU representative: ZAHN Ltd, Mykinon 8, 1065 Nicosia, Cyprus. If you are in the European Union, you can contact our representative about how we use your data, as well as contacting us directly.

This policy covers the ZAHN app, our website zahnapp.com, our newsletter and our support channels.

Data you give us

• Account details: your mobile phone number, name, username, date of birth and, if you add them, your email address and profile photo.
• Bubbles and contacts: the Bubbles you create or join and the people in them. If you allow it, the app reads the contacts on your phone to help you find and invite people. We do not store your phone contacts on our servers.
• Home address (optional): we ask for your home address when you sign up, but you do not have to give it. If you do, we use it to show you a Safety Score for where you live and to set up your Home Spot. If you share your Home Spot with a Bubble, the people in it can see it and are told when you arrive home or leave. Other users cannot see it.
• Spots: places you save, such as Home, Work or School, and who can see them.
• Check-ins and journeys: check-in requests and replies (including urgent replies), and journeys you share with your expected arrival time.
• Reports: the category, location and time of an incident, whether you chose to be anonymous, any details or photo you add, and your "still there" or "looks clear" votes. Missing person and pet reports may also include a description and photo of the person or pet.
• Voice reports: if you report by voice, your phone turns your speech into text. We send that text to our AI provider, Anthropic, to suggest a category. We do not keep a recording of your voice, and we do not store the text once the category is suggested. Anthropic does not use it to train its AI models.
• Messages to us: emails, support requests, complaints and feedback.
• Website: your email address if you sign up for our newsletter or beta programme, and anything you send through a contact form.

Data we collect when you use ZAHN

• Precise location, including in the background when the app is closed, if you allow it. We use it for live sharing with your Bubbles, Spot alerts, location history, journeys, pinning reports, navigation and showing the Safety Score around you.
• Location history: a record of the places you visited, with times and durations, so the people in your Bubbles can see the last 7 days. We are introducing a 30-day limit on how long we keep it, by December 2026 (see section 6).
• Motion and activity data, if you allow it: your phone's motion sensors tell the app whether you are still, walking or travelling. We use this only to save battery and to know when to update your location. Apple's App Store label lists this as "Fitness" data.
• Device information, such as battery level (shown to your Bubbles), device model, operating system, app version, language and device identifiers.
• Usage and diagnostic data, such as which features you use, crash reports and performance data.
• Safety Score searches: places, addresses or postcodes you search for.

Data from other people

• People who invite you to a Bubble give us your phone number.
• Other users may vote on your reports, or tell us about your reports or your account.
• Our sign-in and SMS providers tell us whether your phone number was verified.

We only use personal data where the law allows. The main reasons are:

Where we rely on legitimate interests, we have balanced our interests against yours, taking extra care where the user is under 18. You can ask us for a copy of the assessment.

Sensitive information

Some reports, such as reports of sexual harassment or violence, may reveal sensitive information (special category data) about you or suggest that someone committed a crime. Please do not include details about yourself or anyone else that are not needed. We handle this information with extra care and keep access to a small team. Under the UK GDPR we rely on Article 9(2)(g) (substantial public interest) and Article 10, with two conditions in Schedule 1 of the Data Protection Act 2018: safeguarding children and individuals at risk (paragraph 18), and preventing or detecting unlawful acts (paragraph 10). We keep an appropriate policy document that explains how we protect this information and how long we keep it.

Automated processing

We use automated tools to suggest report categories, to calculate Safety Scores for areas, to limit how many reports can be made, and to expire old reports. None of these makes decisions about you that have legal or similarly significant effects. The Safety Score is about areas, not people. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects (Article 22 UK GDPR). Decisions to remove content or restrict an account are made by a member of our team. We do not profile you for advertising or marketing.

Other ZAHN users

• People in your Bubbles can see your live location, battery level, when your location last updated, the Safety Score of your area, your arrivals and departures at the Spots you share, your location history for the last 7 days, journeys you share and check-in replies, while you share with them. Ghost mode pauses this.
• Your profile photo is visible only to the people in your Bubbles. Other users can see your reports on the map. If you post a report under your username, other users can see your username and profile photo with that report. If you post it anonymously, they cannot see that it was you.
• Reports are shown on the map. A report does not show who you are unless you post it under your username.

Our service providers

We use trusted providers to run ZAHN. They only use your data on our instructions and under contracts that protect it. They include cloud hosting (Amazon Web Services), real-time location, analytics and crash reports (Google Firebase), sign-in (Auth0 by Okta), SMS codes (Twilio), push notifications (OneSignal), maps, search and routing (Mapbox), AI category suggestions (Anthropic), our team's moderation alerts for new reports (Slack), address lookup (Ideal Postcodes), and our website and newsletter (Squarespace). Part 2 lists each provider, where it processes your data and how your data is protected.

Others

• Police and authorities, where the law requires it, or where we believe in good faith that sharing is needed to prevent death or serious harm, to protect a child, or to detect or prevent crime. This may include your account details, location and reports, including anonymous reports.
• Ofcom and other regulators, where the law requires it.
• Professional advisers, such as lawyers and accountants.
• A buyer or investor, if our business is sold or restructured, under confidentiality and with your rights protected.

We do not sell your personal data. We do not share it with advertisers, and we do not use your location for advertising, marketing or profiling.

• Location: choose "While using" or "Always", or turn location off, in your phone settings. Without location, live sharing and Spots will not work.
• Ghost mode: pause sharing with one Bubble or all of them.
• Bubbles and Spots: leave a Bubble, remove members, and choose which Spots each Bubble can see.
• Reports: post anonymously, and delete your own reports.
• Notifications: turn them off in your phone settings.
• Contacts: you do not have to give access to your contacts.
• Analytics and crash reports: by December 2026, we will ask whether you agree when you sign up, and add a switch in Settings so you can change your choice at any time. Until then, we collect them because we have a legitimate interest in keeping ZAHN working and improving it. You can object by emailing legal@zahnapp.com.
• Newsletter: use the unsubscribe link in any email.

We keep personal data only for as long as we need it. In summary:

We may keep data for longer if the law requires it, or to deal with a legal claim or a safety investigation. Data that has been fully anonymised is no longer personal data and may be kept.

Our main servers are in the United Kingdom (Amazon Web Services, London). Live location data is stored by Google Firebase in the European Union (Belgium). Some of our providers, such as Google, Okta, Twilio, OneSignal, Mapbox, Anthropic and Slack, are based in or may access data from the United States or other countries. When data is transferred outside the UK, we use the protections required by UK law, such as the UK-US Data Bridge, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for details.

We use encryption in transit and at rest, secure sign-in with one-time codes, role-based access for staff, monitoring, and regular security testing (including an external penetration test in August 2025). No system is completely secure. We keep a record of data breaches. If a breach is likely to put people at risk, we tell the ICO within 72 hours of becoming aware of it. If the risk is high, we also tell the people affected without undue delay.

Because ZAHN processes precise location, including for young people, we carry out a data protection impact assessment and review it when we add major features.

ZAHN is for people aged 13 and over. We do not knowingly allow anyone under 13 to use ZAHN. If we learn that someone under 13 has an account, we will close it and delete their data. If you think a child under 13 is using ZAHN, contact legal@zahnapp.com.

Users aged 13 to 17 are children under data protection law. By December 2026, we are introducing extra protections for them: location sharing will be off until they choose a Bubble to share with, a clear sign will show whenever their location is shared, and they will have to accept every Bubble invitation. Our team checks missing person reports about children before they appear. Our Children's Privacy Notice explains, in plain language, how ZAHN works for young people.

You have the right to:

• get a copy of your personal data;
• correct data that is wrong or incomplete;
• ask us to delete your data;
• ask us to limit how we use your data;
• object to us using your data for our legitimate interests;
• receive data you gave us in a format you can reuse;
• withdraw your consent at any time (this does not affect what we did before).

To use your rights, email legal@zahnapp.com. You can also delete your account in the app under Account > Settings > Delete account. We may need to check your identity. We will reply within one month, or tell you if we need longer. There is usually no charge.

If you are unhappy with how we use your data, please tell us first so we can try to put it right. We will acknowledge your complaint within 5 working days and aim to resolve it within 30 days. You also have the right to complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint, 0303 123 1113.

Our website uses cookies, and our app uses similar technologies (software development kits) for analytics and crash reports. See our Cookie Policy for details and how to manage your choices.

When you sign up or sign in, we send a one-time code to your mobile number by SMS. This is needed to secure your account. We send 1 or 2 messages each time you sign in or make certain account changes. Your network may charge for messages. We do not use your phone number for marketing.

We will update this policy when we change how we use personal data. We will tell you about important changes in the app before they take effect. The date at the top shows when it was last updated.

• Privacy questions and requests: legal@zahnapp.com
• Post: ZAHN UK Management Ltd, 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT, United Kingdom
• Information Commissioner's Office: ico.org.uk, 0303 123 1113

This part gives the detailed information required by Articles 13 and 14 of the UK GDPR and the EU GDPR. Read it together with Part 1. Users aged 13 to 17 also have a Children's Privacy Notice.

A. The personal data we process and where it comes from

We do not ask for special category data. Reports about some incidents may reveal it, or allege a criminal offence (see "Sensitive information" in section 3).

B. Our service providers

Where personal data is transferred outside the UK, we protect it with one of: UK adequacy regulations (including the UK-US Data Bridge for certified US companies); the UK International Data Transfer Agreement; or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment. Contact us for a copy of the relevant safeguard.