This notice explains how Restart Software Ltd ("we", "us") handles personal data when you use Face Safe (the "Service").
1. Who is responsible
Restart Software Ltd is the data controller for account, usage, support and billing-related data described here. For photos of children, staff or families that you upload on behalf of a nursery, school, agency or family, you (or your organisation) are the controller and we act as your processor, handling those images only to provide the Service on your instructions.
2. How we treat children's images
- Local processing stays on your device. Blur, pixelation and solid covers do not upload the original photo. AI checks and replacement send the photo to the configured AI provider; the app does not save those originals to its library.
- Blur, pixelate and solid cover run on your own device. Those images are not sent to us.
- AI face replacement, optional child-age checks and the advanced background scan send the image to our AI provider only to create the protected copy or find identifying details. Provider retention and data-use terms apply to AI requests.
- Location and camera data (EXIF/GPS) is removed from every protected download.
- Only protected copies you choose to save are stored, in a private library on paid plans.
3. Data we collect, why, and our legal basis
- Account details (name, nursery/school/company name, phone, email, password, town and country): to create and run your account. Basis: contract.
- Google sign-in (optional): Google provides your verified email address, account identifier and basic profile. We store your Google identifier, email and name to create your account and recognise you when you sign in. We use Google's access token only during sign-in to retrieve that profile; we do not retain Google access or refresh tokens. Google sign-in does not give us access to your Gmail, Drive or contacts. We do not sell Google account data, use it for advertising, or send it to our image-processing AI provider. You can remove the connection in your Google Account and contact us to request deletion of your Face Safe account data.
- Protected images and folders you save, share links and client folders: to store, organise and share them for you. Basis: contract.
- Team and client members invited to an agency account (name, email, access level, usage limits): to give them access. Basis: contract and legitimate interests.
- Usage data (AI image allowance, top-ups, regenerations, activity dates): to apply plan limits and show your history. Basis: contract.
- Technical data (IP address, approximate location, device, browser and logs): for security, fraud prevention and improving the Service. Basis: legitimate interests.
- Payment records received from Paddle (plan, amount, status, invoice reference): to activate your plan and keep accounts. We never see your full card details. Basis: contract and legal obligation.
- Messages you send us: to respond and support you. Basis: legitimate interests.
4. Who we share data with
- Service providers who host our app, database and file storage, and the AI provider that processes images for AI features, under contracts that limit their use of the data.
- Paddle.com, our Merchant of Record, for the sale of the product, subscription management, payments, tax compliance and invoicing.
- People you choose to share with: share-link recipients, and team or client users you add to your folders.
- Professional advisers (legal, accounting), and authorities where the law requires it.
We do not sell personal data or use it for advertising.
5. International transfers
Some providers may process data outside the UK/EEA. Where they do, we rely on UK adequacy regulations or standard contractual clauses (including the UK addendum) to protect it.
6. How long we keep data
- Free plan: there is no personal library. Images are processed and downloaded, not stored by us. Photos an agency shares with you are held in that agency's paid account.
- Paid plans: saved protected images are kept until you delete them or close your account. If a subscription ends, you should download anything you want to keep.
- Share links remain valid until revoked. The image download URLs they produce expire after at most five minutes.
- Account data is kept while your account is open. Deleting your account removes your library files, folders and account details. We keep limited billing records as long as the law requires for tax and accounting.
Data is deleted or anonymised when it is no longer needed.
7. Security
We use encryption in transit, private storage, access controls on every folder, short-lived signed links, and limited staff access to protect your data.
8. Cookies and local storage
We only use essential storage to keep you signed in and remember your settings. We do not use advertising or tracking cookies, so no cookie choices are needed.
9. Your rights
Under UK GDPR you can ask to access, correct, delete, restrict or port your data, object to processing, and withdraw consent at any time. You can change your details or delete your account yourself from Account. For anything else, contact us by email at Hello@re-start.app or via our contact page. We will respond within one month. You can also complain to the Information Commissioner's Office at ico.org.uk.
If your request is about images uploaded by your nursery, school or agency, we will pass it to them as the controller and help them respond.
10. Changes
We may update this notice and will tell you about significant changes by email or in the app.