1. Controller
The Black Circle Group Limited (United Kingdom) is the data controller for personal data processed via Procaffeinated.
2. What we collect
- Account data: email, name (optional), authentication identifiers.
- Caffeine and activity logs you submit.
- Technical data: IP-derived country, user agent, referrer, basic page-view analytics.
- Communications you send to us.
3. Why we use it
To operate the waitlist and app, authenticate you, secure the service, send transactional and (with consent) marketing email, and improve the product.
4. Legal bases (UK GDPR)
Performance of contract (operating your account), legitimate interests (security, product analytics), consent (marketing email), legal obligation (tax/records).
5. Sharing
We share personal data with the following categories of recipients:
- Service providers and subprocessors who help us run the service (hosting, database, email delivery, analytics, customer support tooling).
- Paddle.com Market Limited ("Paddle"), our Merchant of Record. When you make a purchase, Paddle receives the personal data needed to process the sale, including your name, email, billing address, IP address, and payment details, and uses it to take payment, manage your subscription, calculate and remit taxes, issue invoices, handle refunds and chargebacks, and prevent fraud. See the Paddle Privacy Notice for details.
- Professional advisers (legal, accounting) where reasonably required.
- Authorities and regulators where required by law.
We do not sell personal data.
6. Retention
Account data is kept for the lifetime of your account and up to 12 months after closure for legal and audit purposes. Waitlist entries are kept until you ask us to remove them.
7. Your rights
You may request access, correction, deletion, restriction, portability, or object to processing. Email
privacy@procaffeinated.co.uk. You can also complain to the ICO (ico.org.uk).
8. Cookies
We use only essential cookies for authentication and session continuity. We do not run third-party advertising trackers.
9. Security
Data is encrypted in transit. Access is restricted via row-level security and role-based access controls. Report security issues to
security@procaffeinated.co.uk.
10. International transfers
Where data is processed outside the UK/EEA, we rely on adequacy decisions or Standard Contractual Clauses.
11. Changes
Material changes will be notified by email or in-app notice.
