PRIVACY POLICY FOR RŪNWELER LTD

Last Updated: August 2026

Rūnweler Ltd ("we", "our" or "us") is committed to protecting and respecting the privacy of our community. This Privacy Policy explains how we collect, process, use, store, and protect your personal data when you visit our website, use our mobile application (the "Platform"), or interact with our services.

For the purpose of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the Data Controller is Rūnweler Ltd, a limited company registered in England under Company Number 16374231, with its registered office at C/O Twm Solicitors Llp, 65 Woodbridge Road, Guildford, Surrey, England, GU1 4RD.

Because our Platform processes the data of children (minors under the age of 18), this policy has been co-designed to comply strictly with the Information Commissioner’s Office (ICO) Age-Appropriate Design Code (the Children’s Code).

1. Important Information and Who We Are

Our Platform operates as a secure, audio-centric local social network. New user registration is strictly restricted to individuals who are exactly 16 and 17 years old at the point of onboarding. Registered users subsequently transition through a permanent, three-bracket age-gating framework over time (Age Bracket 16-17, Age Bracket 18-21, and Age Bracket 22+).

2. The Types of Data We Collect

We collect and process various categories of personal data, which we have grouped together as follows:

• Identity Data: First name, middle name, date of birth, age, sex and your system-generated, regulated username.

• Onboarding Verification Documents (The Two-Step Veriff Check):

  • Step 1 (Age check): A digital scan of your official UK or International Passport along with a biometric liveness selfie.

  • Step 2 (Residency check): A digital scan of an official supporting document displaying your home address and postcode. Approved documents include a UK Bank or Building Society Statement, an official HMRC Letter, or an institutional School/College Enrolment Letter.

  • Data Deletion Rule: We do not store or retain images of your passport, selfie, or proof of address documents. Our identity verification vendor (Veriff) extracts the text strings required to validate your account and instantly purges the raw image files from their servers. Our backend database never stores the physical ID images.

• Contact Data: Email address and mobile phone number.

• Location Data: General residential postcode data extracted during onboarding. We verify your home address once upon registration to enforce our platform's local geo-lock. We do not track or store your live, precise continuous GPS movements around town.

• User-Generated Content (UGC): Audio recordings ("whispers" up to 75 seconds for main posts; "feels" up to 15 seconds for audio reactions) and raw, in-app photographs attached to your whispers.

• Technical & Usage Data: Internet Protocol (IP) address, device type, operating system version, and data on how you interact with the Platform.

3. How and Why We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we rely on Performance of a Contract (to provide the platform services) and Legitimate Interests (to secure our network and moderate content).

To execute our two-step onboarding check via Veriff:

• Purpose: Verifying that your age is exactly 16–17 and that your home postcode falls within our whitelisted catchment zone before allowing account creation.

• Type of Data Used: Identity Data, Passport Scan, Supporting Address Document.

• Lawful Basis for Processing: Performance of a Contract. This check is strictly required to validate local community membership before a profile can be created.

To generate your system-approved handle and calculated Age Band:

• Purpose: Creating your secure username format using your passport name details and displaying your calculated age bracket.

• Type of Data Used: Identity Data.

• Lawful Basis for Processing: Performance of a Contract.

To host, stream, and deliver your whispers and feels:

• Purpose: Allowing you to record, share, and publish your 75-second whispers and your 15-second feels reactions.

• Type of Data Used: User-Generated Content (UGC), Identity Data.

• Lawful Basis for Processing: Performance of a Contract.

To automatically strip tracking metadata from your photos:

• Purpose: Cleaning your attached raw, in-app photographs of hidden EXIF coordinates and timestamps before anyone else can see them.

• Type of Data Used: User-Generated Content (UGC), Technical Data.

• Lawful Basis for Processing: Legitimate Interests. This processing fulfills our commitment to enforcing youth privacy defaults and data minimisation.

To run manual administration and review of user-flagged content:

• Purpose: Reviewing reports submitted by the community to protect users from harm, bullying, or profile visual violations.

• Type of Data Used: User-Generated Content (UGC), Identity Data.

• Lawful Basis for Processing: Legitimate Interests. This allows us to fulfill our core child safeguarding duties and maintain platform safety.

4. Privacy by Design: Asymmetric Age Guardrails

To comply with the ICO's standards for safety and privacy by default, our system architecture enforces strict asymmetrical data filters across our age brackets to prevent adults from targeting minors:

• Default Feed Restrictions: All whispers uploaded by users in the 16-17 minor age bracket default strictly to Teenager bracket only. They are invisible to adult accounts unless the minor manually opts to toggle on a public community broadcast layout.

• The Heeding Wall: Users in adult age brackets (18+) are hard-blocked by database schema design from heeding users in the minor (16-17) age bracket. The "Heed" button is completely hidden and disabled. Minors may freely heed adult brackets.

• The Feels Wall: Adult users are strictly blocked from leaving feels or audio replies under any whisper generated by a user in the minor age bracket.

• The Shrouded Whisper Block: Users in the 16-17 minor bracket are hard-blocked from sharing "shrouded whispers" with any user who is 18 or over, and vice-versa. No hidden communication can occur across the adult-minor boundary.

• The Birthday Frozen Connection Script: On a user's 18th birthday, their profile automatically upgrades to adult status. The system applies a one-way database "freeze" to their existing connections with remaining minor users. The adult will no longer see those minor profiles in their heeding list, and is blocked from leaving feels on their public whispers or sharing shrouded whispers with them. The minor can still see and heed the graduate normally. This freeze automatically unfreezes back to active status when the younger user turns 18.

• Internal Testing Operations: Authorised company accounts (e.g., our Admin profile) and designated external Beta Testers are bound by these identical technical boundaries, maintaining total data isolation from unbroadcasted minor content.

5. Strict Geographic Whitelisting

Registration on the Platform is limited strictly to residents living within our designated, local geo-fenced catchment area. The Veriff onboarding workflow processes document text data and automatically restricts profile activation to candidates whose verified residential address matches our internal whitelisted boundaries. Registration requests from addresses sitting outside this local catchment perimeter are automatically blocked and rejected by the platform filters to secure community integrity.

6. Profile Picture Data Controls and Manual Moderation

To maintain a safe visual environment and uphold our platform's standards, we implement specific technical data controls on user profiles:

• In-App Camera Restriction: The Platform restricts profile image uploads exclusively to a live, raw, in-app camera interface. External file system access, digital editing filters, and device gallery uploads are entirely deactivated by the software interface to prevent the processing of pre-edited media.

• Administrative Processing of Flagged Images: If a profile picture is reported by the community using our in-app flagging tools for displaying an artificial or digitally altered appearance, the image data is routed directly to a secure manual administration queue for review by the Data Controller. Accounts found to violate our platform visual standards will be subject to administrative suspension.

7. Discoverability and Localised Feeds

To facilitate secure community connections between local peers, the Platform incorporates a "Nearest You" discoverability section on the user homepage.

• Postcode Partitioning: This feed partitions users strictly by their verified outward postcode sector (matching local residents within their corresponding spatial zone).

• Data Minimisation: The Platform does not compute, use, or store mathematical distance coordinates, live physical locations, or radii measurements between individual user households.

• UI Anonymisation: The location of all items rendered within this discovery feature is permanently masked under the unquantified text label "Nearest You".

8. Data Retention: How Long We Keep Your Data

We apply strict Data Minimisation principles. Your personal data and user-generated audio content will only be retained for as long as your account remains active and compliant with platform policies.

• Whispers and Feels: Retained for the life of your active account or until manually deleted by you. User-reported or policy-violating content is reviewed manually by the Admin and permanently scrubbed following administrative action.

• Media Metadata: Wiped instantly upon upload.

• Account Deletion: You can request account deletion at any time by contacting us at welcome@runweler.com. Upon deletion, all associated identity handles, contact links, and audio logs are permanently purged from our active databases.

9. Data Sharing and Third Parties

We do not sell your data. We only share personal data with specific trusted service providers who help run our platform safely:

• Identity Verification Providers: Veriff (operating under a contract mandating the immediate deletion of raw passport and proof of address files).

• Cloud Infrastructure Providers: Secure cloud storage and database providers located within the UK/EEA or operating under approved adequacy frameworks.

• Our Development Personnel: Independent software engineers working under signed Data Processing Agreements (DPAs) that mandate the strict use of non-real, anonymised dummy data throughout software testing and deployment workflows.

10. Your Legal Rights

Under the UK GDPR, you have the right to request access to your data, request corrections, object to processing, request data erasure, or restrict processing. Because our onboarding users are aged 16 and 17, they can legally exercise these privacy rights independently without requiring parental intervention.

To exercise any of these rights, please email us at welcome@runweler.com. If you feel we have not resolved an issue satisfactorily, you have the right to lodge a formal complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).