1. Controller
The Black Circle Group Ltd (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 use trusted processors for hosting, email delivery, and analytics. 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.