Privacy Policy

Last updated: 17 September 2025
Controller: Samasu Digital Ltd (“we”, “us”, “our”)
Address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Email: privacy@openline.app (or support@openline.app)

This Privacy Policy explains how we collect, use, disclose and protect information when you use the OpenLine mobile application and the website openline.app (together, the “Services”).

If you do not agree with this Policy, please do not use the Services.

1) What we collect

Information you provide

Account & profile: name, email, password (hashed), country/timezone.
In-app content: messages, notes, and other content you choose to submit.
Support: details you send via openline.app/support (subject, description, attachments, device/app/OS data).
Purchases: subscription selections and status (we receive metadata from Apple/Google; we don’t receive your full card details).
Communications: emails, feedback, survey responses.

Information collected automatically

Device & usage: device model, OS version, app version, language, IP address, timestamps, features used, taps and screens.
Diagnostics: crash reports, performance data, error logs.
Cookies & similar tech (website): essential cookies for security/sign-in and optional analytics cookies (see §10).

Please avoid sharing highly sensitive personal information in free-text fields (e.g., passwords, financial info, government IDs, health data).

2) How we use your information (purposes & legal bases)

We process data to:

Provide the Services (create/maintain your account, core features, paywall, restore purchases). Legal basis:contract (UK/EU GDPR Art. 6(1)(b)).
Process subscriptions & purchases via Apple/Google. Legal basis: contract; our legitimate interests in operating the service.
Support & communicate (troubleshooting, responding to requests). Legal basis: contract; legitimate interests.
Improve & secure the Services (analytics, debugging, preventing abuse/fraud). Legal basis: legitimate interests.
Show optional communications (product updates, tips). Legal basis: consent where required; you can opt out anytime.
Comply with law (tax, accounting, legal requests). Legal basis: legal obligation.

If you choose to submit special-category/sensitive data in your content or support messages, you consent to our processing of that data solely to provide the requested service or support. You may withdraw consent at any time (this won’t affect prior processing).

3) Payments & subscriptions

On iOS, purchases are processed by Apple (Apple ID). On Android, by Google Play. We receive transaction status metadata (e.g., product, renewal status) but no full payment card details. Refunds are handled by Apple/Google under their policies.

4) Sharing & disclosure

We don’t sell your personal information. We share it only with:

Service providers / processors that help us run the Services (e.g., cloud hosting, analytics, crash reporting, email delivery, customer support). These providers may access data solely to perform services for us under contract.
Platform stores (Apple, Google) to validate purchases and manage subscriptions.
Professional advisors (legal, accounting) under confidentiality.
Law enforcement or regulators when required by law or to protect rights, safety, and security.
Business transfers: if we undergo a merger, acquisition, or asset sale, your data may transfer under the same commitments.

We can provide an up-to-date list of core subprocessors upon request at privacy@openline.app.

5) International transfers

Your data may be processed outside the UK/EEA. Where we transfer personal data internationally, we use appropriate safeguards such as UK/EU Standard Contractual Clauses (and/or the UK IDTA) and implement technical and organizational measures (encryption, access controls).

6) Security

We use industry-standard measures to protect data, including encryption in transit, restricted access, logging, and regular backups. No system is 100% secure; you are responsible for safeguarding your account credentials.

7) Retention

We keep personal data only as long as necessary for the purposes above:

Account data: for the life of the account, then deleted or anonymised within 30
days.
Support tickets/attachments: 18 months after closure.
Crash/analytics logs: typically 30–26 months depending on provider settings.
Backups: retained for up to 90 days before automatic purge.

We may keep data longer if required by law or to resolve disputes.

8) Your rights

UK/EU/EEA residents (UK/EU GDPR)

You have the right to access, rectify, erase, restrict, object to certain processing, and data portability. Where we rely on consent, you may withdraw consent at any time. You also have the right to lodge a complaint with a supervisory authority (in the UK, the ICO at ico.org.uk).

California residents (CCPA/CPRA)

You have the rights to know (access), delete, correct, and to opt-out of sale or sharing of personal information. We do not sell your personal information and do not engage in cross-context behavioural advertising that would constitute “sharing” under the CPRA. You may also limit use of sensitive personal information (we do not use it for additional purposes).

How to exercise rights: email privacy@openline.app with “Privacy Request” in the subject. We may ask you to verify your email or identity.

9) Children

OpenLine is not directed to children under 13 and we do not knowingly collect personal data from them. In the UK/EEA, if you are under the digital age of consent (13–16), you need guardian consent. If you believe a child has provided data to us, contact privacy@openline.app and we will delete it.

10) Cookies & website analytics (openline.app)

Essential cookies (security, session, load balancing) — always on.
Analytics cookies (to understand usage) — used only with consent where required. You can manage cookies via your browser settings and, where applicable, our cookie banner preferences link.

11) AI/automated processing (if you use AI features)

Some in-app features may use AI services to generate responses or insights from the text you input. We may send your text to third-party AI processors only to provide the feature, with contractual controls prohibiting provider use of your data for advertising and (where applicable) model training. Do not input confidential or sensitive personal data you don’t want processed by AI systems.

12) Your choices

Account settings: update or delete your info in the app where available.
Marketing: opt out via the link in emails or in settings.
Permissions: you can disable notifications, microphone, camera, or analytics in your OS settings (functionality may be affected).

13) Changes to this Policy

We may update this Policy from time to time. We’ll post changes here and revise the “Last updated” date. Material changes may be notified in-app or by email where appropriate.

14) Contact us

Samasu Digital Ltd
71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Email: privacy@openline.app (privacy requests) or support@openline.app (general support)