Privacy Notice
Effective date: 24 October 2026 Last updated: 24 October 2026
1. Controller and contact
JITI LTD (company number 15686662), trading as Guides.app, is the controller for the Platform processing described here. Privacy contact: hello@guides.app, with "Privacy" in the subject line.
Our appointed privacy representative can be contacted through hello@guides.app.
A Publisher, payment provider, app store or other third party may separately control information for its own purposes. We identify relevant recipients below. An organisation using a genuinely processor-only service requires a separate data-processing agreement; this notice does not establish that every organisation relationship is controller-to-processor.
2. Information, purposes and lawful bases
The following table describes the information we process and the purposes and lawful bases relevant to that processing. Optional features apply only where enabled and used.
| Information | Purpose | Lawful basis for the described use |
|---|---|---|
| Account name, email, authentication data and selected profile details | Create and secure accounts, provide requested services and communicate necessary service information | Contract; legitimate interests in preventing misuse and protecting accounts |
| Organisation, team-role and business contact information | Administer authorised collaboration and business accounts | Contract with an individual customer, or legitimate interests in delivering and administering the organisation's service |
| Tour uploads, credits, creator profiles and associated permissions | Store, edit, publish and deliver the content the Publisher authorises | Contract where the individual is the contracting Publisher; otherwise legitimate interests in providing the authorised service, subject to the rights of other people represented in the content |
| Public professional names, identifiable images/voice excerpts and supplied branding in cleared Marketing Materials | Promote Guides, relevant destinations and its present/past publishing work, including permitted marketing after Tour withdrawal | For limited professional promotion, legitimate interests only after a documented purpose, necessity and balancing assessment; consent or another valid basis where required or more appropriate; no automatic reliance on contract merely because a licence exists |
| Publishing acceptances, authorised signatory, agreement version and event timestamps | Evidence of agreed rights, publication commitments and customer obligations | Contract administration and legitimate interests in maintaining reliable records and resolving disputes |
| Orders, amounts, currencies, seller identity, entitlement, refund and transaction references | Fulfil purchases, support existing customer access and reconcile payment | Contract; legal obligations for applicable accounting and tax records |
| Publisher identity, bank and tax details, and verification results received from providers | Lawful seller onboarding, payouts, fraud prevention and relevant reporting | Contract; identified legal obligations where applicable; legitimate interests in preventing fraud |
| Support communications, rights notices, reports and review appeals | Resolve requests, investigate disputes and protect users and rights holders | Contract where needed for the requested service; legitimate interests in fair and safe operation; legal obligation where a binding duty applies |
| IP address, device/browser/app version and necessary security/error logs | Deliver content, diagnose failures and protect systems | Contract where necessary to deliver the service; legitimate interests in security and reliability, subject to device-storage rules |
| Optional product analytics and interaction events | Understand usage and improve the product | Consent for optional tracking and associated personal-data processing |
| Optional marketing preferences, campaign interactions and advertising identifiers | Send permitted promotions and measure approved marketing | Consent where required; any lawful alternative for email marketing must be specifically documented and offer an effective opt-out |
| Approximate or precise location, where a location feature is enabled | Show nearby content and trigger the selected Tour's stops | Consent for optional location processing; necessary technical delivery may also rely on contract where genuinely required for the feature requested |
We do not treat the purchase of a Tour or acceptance of general terms as consent to optional marketing, tracking or unrelated AI uses. Where a feature requires data to operate, we explain the consequence of not providing it. Do not submit special-category or highly sensitive information unless necessary for an identified support or accessibility request; any such processing requires a separately assessed lawful condition.
Phone numbers, dates of birth, identity documents and precise-location histories must not be collected merely because a form can request them. Account setup collects identity/contact and profile fields, including name and date of birth where required for eligibility. Guide activation requires adult eligibility. Optional public profile fields are separate from account sign-in contact details. Stripe collects payout identity and financial verification information in its hosted flow; Guides stores provider identifiers and readiness/status information rather than copies of Stripe identity documents.
3. Location and offline features
Location access is controlled through an in-context explanation and your device settings. Background access, where enabled for an active Tour, must be separately explained; turning off the screen is not a reason to use location for unrelated advertising. Withholding permission may prevent automatic stop triggering or nearby discovery, but does not authorise denying unrelated account rights.
Web playback uses foreground browser location permission to select eligible nearby Stop narration. Turning GPS autoplay off stops its location watch; manual playback remains available. Nearby discovery sends a requested coordinate pair to the Guides API to search around that location. Those coordinates are transient search inputs, not stored as a location history or included in application logs. With analytics consent, an eligible empty nearby result can increment an aggregate daily counter for an approximately 10 km grid cell; the counter does not retain precise coordinates. The homepage location demonstration is a labelled simulation and does not request the visitor’s coordinates. Map tile requests disclose requested map areas and network information to the map provider.
An operating-system permission is not a substitute for the information and consent required by applicable law. We will not represent an on-device-only design unless engineering has verified it. Downloaded material may remain on your device until you delete it or the app removes it according to the purchase terms and disclosed behaviour.
4. Sources of information
We obtain information from you and your device, from an organisation administrator who invites or manages your business account, from a Publisher or customer involved in a transaction or support issue, and from payment, identity, security and app-store providers to the extent necessary for their integration.
Publicly available creator business information used for legitimate business prospecting must be accompanied by the required transparency notice within the applicable period and marketing-law compliance. Public availability is not automatic consent. This notice is not permission for indiscriminate scraping or bulk unsolicited messages.
5. Public content and recipients
Published Tours, profile information, selected credits and reviews may be visible to other users and the public, including search engines. Do not upload information that you have no right to publish. We do not make bank details, private identity documents or private support messages public as part of a creator profile.
We use hosting and database providers, content-delivery networks, payment and verification services, analytics providers, communications and support tools, and mapping services. Depending on the feature, these providers receive the account, device, transaction, content or support information needed to deliver it. Our services use Cloudflare and AWS for website/backend infrastructure and delivery, Neon for database hosting, Stripe for payments and payouts, PostHog for optional analytics, and Slack for operational and support communications. Support alerts may contain contact details and information you submit in a support request.
Map services, including OpenFreeMap (map tiles based on OpenStreetMap data), Photon and Nominatim, receive relevant map requests or search terms and associated network information. Mobile notification delivery uses Google Firebase and, on Apple devices, Apple Push Notification service; these services process device or installation identifiers and notification information. App stores and payment providers may also process information independently under their own notices. A provider's role depends on the service and purpose; some act on our behalf and others act as separate controllers for their own legal, security or service purposes.
The identified seller receives only the information it needs and is entitled to receive for an order, support, accounting or legal duty. Publishers are not automatically given precise travel history or permission to use a purchaser's email for independent marketing. Publisher dashboards provide aggregate Tour statistics and beneficiary-scoped financial records. They do not provide a customer email list or precise visitor travel history. Public reviews expose their authorized public author projection and review content, not account contact information.
We may share information with professional advisers, insurers and authorities where necessary and lawful, or with a genuine successor in a business transaction subject to confidentiality and protection of existing rights. We do not use a change of ownership as permission to introduce unrelated processing without a lawful basis and required notice.
6. International transfers
Third-party providers may process or store information in countries other than your own under their applicable service terms, privacy policies and global infrastructure arrangements. Those arrangements do not replace Guides’ obligations under applicable data-protection law or limit your rights; any international transfers must have the safeguards required by law.
International transfers are subject to applicable data-protection requirements, including an applicable adequacy decision or appropriate contractual safeguards and any required assessments or supplementary measures. Primary hosting location does not necessarily determine every processing location; providers may use international infrastructure, support teams and subprocessors.
You can ask hello@guides.app for information about safeguards and an appropriate copy or explanation, subject to lawful redactions. EU-facing processing may require EU arrangements as well as UK arrangements.
7. AI and automated decisions
The standard publishing licence does not permit general-purpose AI training on Tour content. Any translation, transcription, narration or other AI processing enabled for a requested feature must be explained, limited to that purpose and reflected in the supplier register. A voice-cloning permission is separate from ordinary upload permission.
The V2 website/API does not provide a live generative-AI Tour authoring service. Technical media processing, permission checks, GPS playback triggers, payment-event handling and discovery ordering are automated. These do not establish ownership of content or physically verify a visit. Content and rights complaints have human review paths. Stripe applies its own payment/verification processing under its notice; no claim is made that Guides controls all provider fraud decisions.
Where solely automated decisions have legal or similarly significant effects, we provide the required information and safeguards under the applicable law. You may ask for the review available for a significant account or payout restriction. We do not claim there is no such automation without verification.
8. Retention and account deletion
Our retention policy is to keep personal data only for a justified purpose and period, using the schedule below. Retention depends on the record, service, legal obligations and any justified legal hold. These periods describe our policy, not a guarantee that every provider backup is deleted at the same instant. Providers acting as separate controllers may retain their own records under their policies and legal duties; this does not remove our responsibilities for information processed on our behalf.
| Record | Retention policy |
|---|---|
| Ordinary account/profile information | While needed for the account or another justified purpose; deletion requests are assessed under applicable rights deadlines, with necessary financial, licensing and dispute records retained separately |
| Backup copies of deleted ordinary account data | Restricted backup copies are overwritten through the applicable backup lifecycle; deletion restrictions must be preserved if a backup is restored |
| Order, payout, invoice and tax records | Normally six years from the end of the relevant accounting period, or a different period required by applicable tax law |
| Purchase entitlements and content delivery records | For the agreed access period and any further justified dispute/legal-record period; minimise personal data as time passes |
| Publishing acceptance and licence records | While needed to evidence an active delivery or promotional permission and related obligations, then normally six years after the relevant use/obligations end, subject to a justified legal exception; minimise personal data and review periodically |
| Marketing Materials containing personal data | Only while a valid licence and lawful basis support a genuinely needed promotional use; review necessity, restrictions and accuracy at least annually and on a relevant report, rights expiry or objection; remove unnecessary personal information rather than retaining it merely because the IP licence has no scheduled expiry |
| Routine support records | 24 months after closure; material disputes are retained under the legal-evidence period below |
| Security and error logs | Normally up to 180 days; some provider logs have shorter retention |
| Analytics event data | Our policy period is 14 months for identifiable analytics. Provider storage and deletion processes may differ; contact us for information about your data or to exercise your rights |
| Precise location or location history, if stored | Precise nearby-search coordinates are processed transiently and not retained as location history. Browser playback fixes remain in the active experience. Consent-based coarse daily demand counters are aggregate statistics rather than precise location histories. |
| Rights/moderation complaints and evidence | 24 months after closure for routine complaints; material legal disputes and copyright/licensing evidence: six years after resolution or last relevant licensed use, as appropriate |
| Marketing suppression records | The minimum information needed to honour an opt-out and evidence compliance, reviewed periodically |
Tour withdrawal, a 90-day operational wind-down and personal-data deletion are different processes. A publishing commitment is not a blanket refusal of a data-rights request. We assess any lawful reason to retain specific information, minimise what remains and explain the outcome. A surviving content licence does not itself establish a lawful basis for every item of personal data embedded in the content.
9. Promotional content, marketing messages and choices
9.1 People and brands featured in marketing
The Creator and Publishing Terms may authorise continued intellectual-property use of cleared Tour/professional names, logos, images and short extracts after ordinary withdrawal or account closure. This may involve new organic or paid social posts, website articles, newsletters, advertisements and other Guides marketing, not only old posts remaining online. Public professional information and imagery may therefore be displayed to audiences and shared with the relevant creative contractors, hosting/publication providers and social/advertising platforms. The provider categories and international-processing information in sections 5 and 6 also apply to these uses.
An IP licence is not a universal lawful basis for personal data. Before use, we assess the specific purpose, what is necessary, reasonable expectations and impact, and any consent or other permission needed. For limited professional promotion we may rely on our legitimate interests in explaining and marketing Guides' work only where the required balancing assessment supports it. We do not assume that a person's image, children, sensitive information, a testimonial or an individual endorsement can be used just because a creator uploaded it. A consent-based use must stop when valid consent is withdrawn, subject to the applicable legal rules; we will not silently switch basis to defeat that withdrawal.
Contact hello@guides.app to object, seek restriction/erasure or report inaccurate association or unauthorised imagery. The applicable statutory rights and deadlines prevail over a commercial licence. We honour objections to personal-data processing for direct marketing as the law requires and assess other objections under their applicable test. Leaving Guides is not itself erasure of every justified business record, but neither is a surviving licence a reason to retain all personal data indefinitely. We may remove or replace an identifiable asset while preserving non-personal material lawfully licensed for promotion.
9.2 Messages and tracking
You can unsubscribe from marketing using the message link or by contacting us. Necessary service messages, such as purchase receipts, safety alerts and agreed contractual notices, are separate from promotions. Marketing must not be inserted into a service message to bypass your choices.
Our Cookie Policy explains device storage/access, analytics, pixels and controls. Non-essential analytics and marketing technologies remain off until valid consent. Any later reliance on a lawful limited exception requires a documented assessment, accurate information and any required objection mechanism; it is not assumed for every analytics product.
10. Your rights
Depending on applicable law and the processing, you may request access, correction, erasure, restriction, portability or objection; withdraw consent; and obtain applicable safeguards concerning significant automated decisions. Withdrawal does not make earlier lawful processing unlawful. Direct-marketing objections are honoured.
Contact hello@guides.app. We may ask for proportionate verification, not unnecessary identity documents. We respond within the applicable legal period, normally one month, subject to lawful extensions or timing rules that we explain. We will explain any refusal and available complaint rights.
You may complain to the Information Commissioner's Office at ico.org.uk or another competent supervisory authority where applicable. We welcome the opportunity to resolve a concern first, but you do not have to exhaust our process before exercising an external right.
11. Children, security and changes
Independent accounts and contracts are intended for adults. This does not by itself prove children never access public Tours or that children's privacy and online-safety obligations do not apply. We minimise children's information and do not invite children to create creator or purchasing accounts. Report a suspected inappropriate account or child-data concern to us.
We use appropriate technical and organisational measures proportionate to the data and risks. Do not rely on an absolute security guarantee. Any incident notification will follow applicable legal requirements.
We will update this notice when processing changes and provide additional notice or obtain new consent where required. A new notice does not authorise a previously undisclosed incompatible use simply because it is posted online.