Legal & Compliance

This Privacy Policy explains how Curtisium ("we", "us"), operating QRNFC Global, collects, uses, stores, and protects your personal data. This policy applies to users worldwide and complies with:

• EU General Data Protection Regulation (GDPR)
• UK GDPR & Data Protection Act 2018
• Data Protection (Jersey) Law 2018
• California Consumer Privacy Act (CCPA/CPRA) — see also our dedicated US Privacy tab
• Children's Online Privacy Protection Act (COPPA)

Data Controller: Curtisium, Jersey, Channel Islands
Contact: privacy@qrnfcglobal.com

Account Data: Email address, name, and hashed password when you register.

Content Data: Photos, videos, audio files, and text messages you upload to your QR codes.

Payment Data: Transaction records (amount, currency, date). We do not store card numbers — payments are processed by Paddle (our Merchant of Record).

Scan Analytics: When someone scans a QR code, we record the timestamp, approximate location (country/city derived from IP address), browser type, and device type. IP addresses are hashed for privacy. We do not record the scanner's personal identity.

Technical Data: IP address, browser type, and device information when you access our platform.

For EU/UK users (GDPR):

• Contract: Processing your account and content data is necessary to provide the Service you have paid for.
• Legitimate Interest: Scan analytics help us maintain service quality, detect abuse, and enforce fair use. We balance this against scanner privacy by not collecting personal identifiers.
• Legal Obligation: We may process data to comply with legal requirements (e.g., fraud prevention, law enforcement requests).
• Consent: Where required, we will ask for your explicit consent (e.g., marketing emails).

For US users: We process data as necessary to provide the Service, for our legitimate business interests, and with your consent where required. See our US Privacy (CCPA) tab for California-specific rights.

• To provide, maintain, and improve the Service
• To process payments and manage your code balance
• To compress and optimise your uploaded media for fast playback
• To provide scan analytics to QR code owners
• To enforce our Terms of Service and Fair Use Policy
• To communicate important service updates
• To detect and prevent fraud or abuse
• To comply with legal obligations

We want to be clear about what we do not do:

• We do not sell your personal data to third parties
• We do not use third-party advertising or tracking cookies
• We do not build advertising profiles from your data
• We do not share your data with data brokers
• We do not store payment card numbers
• We do not use facial recognition or biometric data
• We do not collect device location silently — see Section 5a below for the only case where location is captured, and only with explicit consent.

Pet Codes ($9.99) include an optional feature that helps reunite you with a lost pet. Here's exactly how it works:

• Off by default. When you set up a Pet Code, geolocation sharing is disabled. You explicitly toggle it on inside your pet profile if you want it.
• The finder consents on their device. When someone scans a Pet Code with geolocation enabled, their phone's browser shows the standard iOS / Android "Allow location?" prompt. They can decline. We never silently collect anything.
• What we capture if they allow. Latitude, longitude, accuracy radius, optional message from the finder, IP address (for abuse prevention), and a timestamp. That's it.
• What we send to the owner. A single email containing a Google Maps link to the pinged location and any optional message the finder typed. The owner uses this with the public phone number on the recovery card to coordinate the reunion.
• How long we keep it. Pings are retained for 30 days then permanently deleted. You can request earlier deletion at any time via hello@qrnfcglobal.com.
• What we never do. We do not sell, rent, share, or use these pings for advertising. They exist solely to reunite a finder with a lost pet's owner.

If you turn the feature on and later change your mind, switch the toggle off in your pet profile — no further pings will be captured from that point.

Your data is stored on secure cloud servers. Media content is stored in encrypted cloud object storage with global CDN distribution. Passwords are hashed using bcrypt and are never stored in plain text.

We implement industry-standard security measures including:

• HTTPS/TLS encryption on all connections
• Access controls and authentication
• DDoS protection
• Real-time error monitoring (Sentry)
• Regular security reviews
• IP address hashing for scan analytics

Account & Content Data: Retained as long as your account is active, with free automatic annual renewal. If you delete your account, your data will be removed within 30 days.

Scan Analytics: Retained for 24 months, then anonymised.

Payment Records: Retained for 7 years as required by financial regulations.

EU/UK Users (GDPR):

• Right of Access: Request a copy of all personal data we hold about you
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Data Portability: Receive your data in a machine-readable format. You can also self-serve this at any time by clicking "Download my Vault" on your Account or Dashboard — we'll generate a ZIP of all your photos, videos, and a manifest file plus a self-contained offline HTML viewer.
• Right to Restrict Processing: Request we limit how we use your data
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

US Users (CCPA/CPRA): See our dedicated US Privacy (CCPA) tab for your specific rights under California and US state privacy laws.

To exercise any of these rights, contact us at privacy@qrnfcglobal.com. We will respond within 30 days (45 days for CCPA requests).

We do not sell your personal data. We may share data with the following categories of service providers, all bound by data processing agreements:

• Cloud Hosting: Infrastructure and storage providers
• Payment Processors: Paddle.com (Merchant of Record — Paddle handles all card / Apple Pay / PayPal / Google Pay transactions and global VAT/sales-tax compliance on our behalf)
• Email Services: Transactional email delivery (Resend)
• Error Monitoring: Sentry for application health (no PII transmitted)
• Law Enforcement: When required by law or to protect user safety

Your data may be processed in countries outside Jersey, the UK, or the EEA. Where this occurs, we ensure appropriate safeguards are in place:

• EU Standard Contractual Clauses (SCCs)
• UK International Data Transfer Agreement (IDTA)
• Adequacy decisions where applicable

For US users: your data may be stored and processed within the United States.

EU/UK: Our Service is not directed at children under 16. We do not knowingly collect data from children under 16.

USA (COPPA): We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal data, please contact us immediately and we will delete it.

We may update this Privacy Policy from time to time. We will notify you of material changes via email with at least 30 days' notice and update the "Last Updated" date at the top of this page.

If you have concerns about how we handle your data, please contact us first at privacy@qrnfcglobal.com.

You also have the right to lodge a complaint with:

• Jersey: Jersey Office of the Information Commissioner (JOIC)
• UK: Information Commissioner's Office (ICO) — ico.org.uk
• EU: Your local Data Protection Authority
• USA: Federal Trade Commission (FTC) or your State Attorney General