Privacy policy — Equal Access

1. Who we are

This privacy policy is for the Equal Access iPhone app and the website at equalaccess.app.

The person responsible for Equal Access (the data controller) is:

Ian Jennings
18 Les Freres, Le Chemin Des Maltieres, Grouville, Jersey, JE3 9LF

The app’s seller name on the App Store is Ian Jennings.

For privacy questions, or to exercise a right described below, email [email protected].

This policy describes the App Store version of the app (a Release build). It is a draft pending legal review.

2. Photos stay on your iPhone

When you take or pick a photo, Equal Access makes a new, smaller JPEG copy on your iPhone and analyses that copy on the device.

The check uses Apple’s Vision features that run on your iPhone: it reads text in the photo and applies a coarse image classification (for example, a label such as “door” or “stairs”). It does not use the photo to uniquely identify a person, and it does not run face recognition.

Photos are checked on this iPhone and never leave it. This version of the app does not offer cloud analysis and does not send photos to a server. Equal Access does not receive your photos.

The original photo file’s location and camera details are not kept on the copy the app stores.

3. No accounts, no tracking, and no in-app analytics

Equal Access does not ask you to create an account.

The app has no in-app analytics, crash-reporting or advertising tools, and it does not track you across other companies’ apps or websites. Taking or choosing a photo does not upload it. Tapping a guidance source link opens a public website in your browser.

Settings, such as your chosen region, the notice you accepted, and the 18-or-over confirmation, are stored on your iPhone only.

We do not include an analytics tool in the app. If we look at usage figures, we use only the aggregated App Analytics reports that Apple makes available in App Store Connect. Apple collects that usage data only from people who have agreed, in their Apple device settings, to share diagnostics and usage information with app developers.

Official source for that Apple behaviour: https://developer.apple.com/help/app-store-connect-analytics/engagement/app-usage/.

4. Scan history and PDF reports

Saved scans, photos and results are stored only in the app’s private storage on your iPhone. There is no iCloud sync of your history, and Equal Access does not keep a server copy of it.

A PDF only leaves the phone if you share or save it through the iOS share sheet. Once you share it, the copy is under your control (for example, in an email or a files app).

You can delete one screening from History, or use “Delete all screenings” in History or Settings. Deleting the app removes the app’s data from the iPhone. Standard iPhone or iCloud device backups may include app data; those backups are managed by Apple, not by Equal Access.

5. This website

This website is a static set of pages. The pages we publish do not set tracking cookies and do not include third-party or analytics scripts.

The site is hosted on Cloudflare Pages. To deliver the pages and to protect the site, Cloudflare may process technical information such as your IP address, browser type and the page you request, under Cloudflare’s privacy policy.

6. Age

Equal Access is for adults aged 18 and over. The app asks you to confirm that you are 18 or over before it opens. It stores only that yes-or-no answer on your iPhone. It does not ask for a date of birth.

We do not knowingly collect personal data from people under 18. If you believe a child has sent us personal data (for example, in an email), please write to [email protected] and we will delete what we hold.

7. The information we may hold, and why

Depending on how you use Equal Access, the following may be involved:

Photos and the notes the app shows, stored on your iPhone as described above. Equal Access (the organisation) does not receive these unless you email them to us.
Your chosen region, notice acceptance, age confirmation and settings, stored on your iPhone only.
Emails you send to [email protected], including your email address and whatever you write. We use these to reply to you and to keep a record of the request.
Technical data processed by Cloudflare when you visit this website, as described in section 5.

Photos may include people and information from which health or disability could be inferred. We do not use photos to uniquely identify a person, and we do not receive those photos in the ordinary use of the app.

Lawful bases (recommended draft — solicitor to confirm). We do not claim these as settled legal conclusions.

Emails you send us: so we can respond to your request (legitimate interests in handling support and privacy requests; or taking steps at your request).
Website hosting: legitimate interests in publishing and protecting this website. Cloudflare’s role is described in its own policy.
On-device photos and notes: these stay on your iPhone. Equal Access does not receive them in the ordinary use of the app.

A solicitor should also consider whether a Data Protection Impact Assessment is needed, and whether an EU or UK representative must be named, given a worldwide App Store listing.

8. Your rights

Depending on where you live, you may have rights in relation to personal data we hold about you. These can include the right to ask for a copy, to have it corrected or deleted, to restrict or object to certain uses, and to withdraw consent where use is based on consent. You can also complain to a regulator.

Because app photos and notes stay on your iPhone, the practical way to delete them is to delete them in History or Settings, or to delete the app. We can help with information we actually hold (for example, an email you sent us).

If you live in the United Kingdom, you can contact the Information Commissioner’s Office (ICO): https://ico.org.uk/make-a-complaint/.

If you live in Jersey, you can contact the Jersey Office of the Information Commissioner (JOIC): https://portal.jerseyoic.org/make-a-complaint. The JOIC site is https://jerseyoic.org/.

If you live in the European Economic Area, you may also complain to your local data-protection authority. [TO CONFIRM with a solicitor: whether EU GDPR applies, and whether an EU representative should be named.]

To exercise a right, or to ask a question, email [email protected].

This section is a short, information-only summary of rights under the UK GDPR and the Data Protection Act 2018, and under the Data Protection (Jersey) Law 2018. It is not legal advice.

9. Changes to this policy

We will always show the date this page was last updated.

If we make a material change (for example, if a later version of the app added a way to send a photo, or if we started using in-app analytics), we will update this page first, and we will also show an in-app notice before the new use begins.

10. Contact

Email [email protected].

We aim to reply within 5 working days (Jersey time).