CanDo Projects Ltd – Privacy Policy

Introduction

Welcome to CanDo Projects Ltd’s (“CanDo”, “we”, “us”, “our”) privacy policy. 

Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share personal data

Controller

CanDo is the data controller and is committed to protecting the privacy of both parents/guardians ("Parents") and minors (“Child” or "Children") who use our products and services (“you”, “yours”). CanDo provides the following products and services:

• Monitoring software that allows Parents to view a Child’s phone activity ("Software").

• Optional device sales where Parents can purchase a mobile phone with or without our Software pre-installed ("Device Purchase Service").

This privacy policy applies to Parents and Children who use the Software and/or the Device Purchase Service, and also to browsers of www.safetymode.com .

Children’s Privacy 

Our Software is intended for use by Parents/Guardians to safeguard their Child’s device. Our products and services are aimed at Children aged between 8-13, therefore we only process a limited amount of Child personal data (and only with verifiable parental authorisation). Parents can delete all Child Data at any time through their account settings or by contacting us.

We only collect and store limited amounts of child personal data to provide our services.  Information about your child’s phone activity will be stored locally on the device, and not shared with third parties. 

Questions/complaints

If you have any questions about this policy or about how we handle your data, please contact our data privacy team/manager as follows:

Email: privacy@safetymode.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We keep our privacy policy under regular review. This version was last updated in September 2025. 

• The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Parent Data

• Identity data: includes name and title.  

• Contact data: includes  email address, delivery address, telephone number.  

• Account data: includes your google account, username, feedback, your contact history, purchase history, device purchase details, and saved items.

• Transaction data: includes details about payments to and from you and other details of products you have purchased from us.

Child Data 

• Identity data: includes age, relationship to parent.   

• Device data: device ID, IMEI number, operating system, software version, app list, device settings, user content.

Website Users

• Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, geo-location data and google account information.

• Usage Data: information about how you use our website, IT, communication and other systems

We also collect, use and share Anonymous Data such as statistical or demographic data for any purpose. Anonymous Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage  to calculate the percentage of users accessing a specific feature or to enable us to improve our services. 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products). In this case, we may have to cancel a product you have purchased from us but we will notify you if this is the case at the time. 

• How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• create an account; or

• give us feedback or contact us. 

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.

Third parties. In limited circumstances we will receive personal data about you from third parties such as Shopify, Bubble, Superbase, Firebase, Mumsnet or Nothing. 

How we use your personal data

We only collect and process personal data where we have a lawful basis to do so under the UK GDPR.
The table below explains what we process, why we process it, and the lawful basis we rely on.

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  

If you are an individual customer, you may receive marketing communications from us if you have consented for us to send you this information or if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.

We do not send direct marketing to children.  

Opting out

You can ask us to stop sending you marketing messages at any time by unsubscribing. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/ purchase, product experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see [LINK TO YOUR COOKIE POLICY].]

Disclosures of your personal data 

We may share personal data with the parties set out below: 

• Service providers acting as processors who provide services such as payment processing services, cloud storage providers.

• Delivery partners helping us to fulfil the Device Purchase Service, including delivering the product to you. 

• Marketing companies and online advertising agencies – helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in. 

• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities based in the United Kingdom.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Occasionally we may transfer your data outside of the UK to the EU or the US. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or 

• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

Please contact us: privacy@safetymode.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected  it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available from us by contacting us: privacy@safetymode.com

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below (Your Legal Rights) to find out more about these rights. 

If you wish to exercise any of these rights please contact us: privacy@safetymode.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Last updated: September 2025