ChatPal App Privacy Policy

Effective Date

Effective date: November 2025

This version replaces all previous versions.

1. Introduction

ValPal Ltd ('we', 'our', or 'us') operates the ChatPal Service and the ChatPal mobile application ('the Service'). This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our Service, and the choices you have regarding that data.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information About Us

The ChatPal App and associated platforms are owned and operated by ValPal Ltd, a limited company registered in England and Wales (Company No. 10731745).
Registered address: Ground Floor, 1/7 Station Road, Crawley, West Sussex, RH10 1HT
Trading address: Angels House, 5 Albemarle Road, Beckenham, Kent, BR3 5HZ
VAT number: 479156450
ICO registration number: ZB836750
Data Protection Officer: Patsy Gown (team@valpal.co.uk).

3. Scope of This Policy

Where ChatPal processes data on behalf of estate agents or their customers (for example, during calls or automated messaging), ValPal Ltd acts as a **data processor** under the instructions of those clients in accordance with a Data Processing Agreement.

For ChatPal users and data collected directly through the app, ValPal Ltd acts as the **data controller**.

4. What Data We Collect

We may collect the following types of personal data:
- Name, email address, phone number, and address
- Device and connection information (e.g. IP address, browser type, operating system)
- Communication content and call metadata (e.g. message logs, call duration)
- Location data (if you grant permission)
- Usage data (interactions within the app, preferences, time spent)
- Support and feedback messages

We also collect anonymised analytical data to monitor and improve app performance.

5. How We Collect Data

We collect personal data when:
- You register or log in to the ChatPal app
- You communicate via the app (calls, texts, or messages)
- You contact us for support
- We automatically collect usage or diagnostic data

Depending on your device settings, the ChatPal app may request permission to access your **contacts**, **microphone**, or **notifications**. These permissions are used solely for the operation of the Service and can be managed or revoked in your device settings.

6. How We Use Your Data

We use your data to:
- Provide and maintain the ChatPal Service
- Enable and support AI call and messaging functionality
- Communicate with you and provide customer support
- Monitor and analyse app usage and performance
- Improve the Service and develop new features
- Send you updates, offers, or marketing communications (if you have opted in)

We rely on the following lawful bases for processing:
- **Performance of a contract** – providing and managing your ChatPal account
- **Legitimate interests** – ensuring efficient service delivery and support
- **Consent** – for marketing and optional data sharing
- **Legal obligation** – compliance with applicable laws and regulations

7. Data Retention

We retain personal data only for as long as necessary to provide our services and comply with legal obligations. Typically, ChatPal call and communication data are stored for up to three years after your last activity unless deleted sooner at your request.

8. Sharing Your Data

We may share your personal data with trusted third parties who assist in providing our services, including:
- Cloud storage and hosting providers
- CRM, analytics, and communication technology providers
- Subcontractors assisting with maintenance or support
- Marketing and communication partners (only where consent is provided)

All third parties are bound by strict confidentiality and data protection obligations. We never sell your personal data.

9. International Data Transfers

We may store or transfer personal data outside the UK. Where this occurs, we ensure that appropriate safeguards are in place under the **UK GDPR** and **Data Protection Act 2018**, including:
- UK adequacy regulations (for approved countries), or
- Standard Contractual Clauses with the UK International Data Transfer Addendum.

Where data is transferred to the United States, we only use providers certified under the **EU–US Data Privacy Framework** or equivalent safeguards.

10. Security of Your Data

We use appropriate technical and organisational measures to protect your data, including:
- SSL encryption and secure servers
- Encrypted storage and backups
- Regular security monitoring and software updates
- Restricted staff access based on role and necessity

While we take every reasonable step to protect your data, no system is completely secure. We cannot guarantee absolute security but continually improve our safeguards.

11. Analytics and Performance Monitoring

We may use third-party analytics tools such as **Google Firebase** and **Meta SDK** to help us understand how users interact with the ChatPal app, identify bugs, and measure engagement. These services collect anonymised information about app usage, device type, and performance. You can learn more from the Google Privacy Policy: https://policies.google.com/privacy.

12. Your Rights

Under the UK GDPR, you have the right to:
- Be informed about how your data is used
- Access your personal data
- Correct inaccurate or incomplete data
- Request erasure ('right to be forgotten')
- Restrict or object to processing
- Request data portability

To exercise any of these rights, please contact our Data Protection Officer using the details below. We may ask for reasonable proof of identity before fulfilling your request.

13. Children’s Privacy

The ChatPal Service is not intended for anyone under the age of 18. We do not knowingly collect personal data from children. If we discover that a child has provided us with personal data, we will delete it immediately.

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect legal, technical, or operational changes. If significant changes occur, we will notify you via the app or by email. The latest version will always be available in the app and on our website.

15. Contact Us

If you have any questions or concerns about this Privacy Policy or our handling of your data, please contact us:

Email: team@valpal.co.uk (subject: 'ChatPal App Privacy Policy')
Post: ValPal Ltd, Angels House, 5 Albemarle Road, Beckenham, Kent, BR3 5HZ
Telephone: 0208 663 4930

If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk/make-a-complaint/.