CRAGGEN — Privacy Policy

Last updated: 7 August 2026

1. Who we are

CRAGGEN is a push-to-talk (walkie-talkie) app published by I Enterprise Ltd, a company registered in

England and Wales, company number 13225768, registered office Suite 2.06b C4di @TheDock, 31-38 Queen Street, Hull, East Riding of Yorkshire, England, HU1 1UU.

We are the data controller for the limited personal data described below.

Privacy and data questions: info@craggen.com
Reporting abuse or a safety concern: info@craggen.com

We have not appointed a Data Protection Officer; we are not required to.

2. The short version

CRAGGEN is built to hold as little as possible about you.

There are no accounts. You do not give us an email address, a phone number, or a real name.
You choose a display name. It can be a nickname. If you leave it blank the app calls you "Hiker".
Your voice is relayed live, not recorded by us. Audio passes through our relay to the other people on

your channel and is not written to any disk or database by us.

We do not collect your location. On Android 11 and earlier, Android calls the permission needed to find a nearby BLE button “Location”; CRAGGEN uses it only for that local scan and never reads or sends your location.
The app has no adverts, analytics SDKs or tracking. We do not profile you in the app and we do not

sell or rent anything about you.

There are also four things you should understand before you use it, and we have set them out plainly

in section 5 rather than burying them.

3. What we process, why, and how long we keep it

What	Why we need it	Lawful basis (UK GDPR)	How long
Display name (free text, up to 24 characters — a nickname is fine)	So the others on your channel can see who is on it and who is talking	Art. 6(1)(b) performance of a contract — it is the service you asked for	Normally held in memory only while your connection is open. If you send or are named in an abuse report, the two display names are kept with that report for up to 30 days.
Channel code you type, and the fact you are connected to it	It is the address of the conversation — it is how we route your audio to the right people	Art. 6(1)(b) contract	The code itself identifies the channel, not you. Your membership of it exists only while you are connected.
Live audio while you hold the talk button	To relay your speech to the other people on that channel in real time	Art. 6(1)(b) contract	Passed through and discarded. It is held only in memory, for the fraction of a second it takes to send it on. We do not record it and we have no copy of it.
Channel PIN, if you set one on a private channel	To keep that channel locked to people who know the PIN	Art. 6(1)(f) legitimate interests — keeping private channels private	Stored against the channel code while it is active, then automatically cleared 24 hours after the channel empties.
Connection metadata — including your IP address	It is unavoidable: any internet connection reveals it. Our infrastructure provider uses it to route traffic and to defend against attacks and abuse	Art. 6(1)(f) legitimate interests — security and keeping the service available	We do not keep our own logs of it. Our infrastructure provider (Cloudflare) holds short-lived operational logs under its own retention policy.
Optional website analytics — page URL, referring page, broad region, browser/device category and interactions such as Get the app, guide, source, RSS and share clicks	To understand which website information is useful and whether it leads people towards installing the app	Art. 6(1)(a) consent	We retain Google Analytics event and user-level data for no more than 14 months. Aggregate reports may remain for longer. No analytics is loaded unless you choose “Allow on website”.
Plan tier — Free, Pro or Crew	To apply the channel capacity chosen by its host	Art. 6(1)(b) contract	Google Play holds the purchase record. The app keeps its entitlement on your phone and sends the tier label to the relay when joining. We do not receive your payment details or Google account.
Moderation report — channel code, reporter and subject display names and connection-scoped IDs, reason and time	To investigate abuse, protect users, meet applicable online-safety duties and disable a channel where justified	Art. 6(1)(f) legitimate interests — safety, abuse prevention and enforcing our terms; Art. 6(1)(c) where processing or disclosure is required by law	Up to 30 days, then automatically deleted, unless we must preserve a particular report for a legal claim, regulatory request or safeguarding report. Reports contain no audio and no account, email address, phone number or location.
Messages you send us — for example an email asking for support, making a complaint or exercising a privacy right	To answer you, keep an appropriate record of the request and meet legal or regulatory duties	Art. 6(1)(b) contract, Art. 6(1)(f) legitimate interests in support and complaint handling, or Art. 6(1)(c) legal obligation, depending on the request	Normally up to 24 months after the matter closes. We may keep a minimal record longer where reasonably needed to establish, exercise or defend legal claims or meet a legal duty.
Settings on your own phone — your display name, recent and saved channel codes, plan flag and the Bluetooth address of a paired push-to-talk button	So the app remembers your setup between uses	Art. 6(1)(b) contract	Stored only on your device. Android cloud backup is disabled for CRAGGEN. Clearing the app's storage or uninstalling it removes these settings.

What we do NOT do

We do not collect your location. We do not read your contacts, photos, files, or messages. When you choose Share, Android's own share sheet lets you choose an app or person; CRAGGEN does not receive or store your contact list. We do not

use advertising identifiers. We do not use analytics, crash-reporting or advertising SDKs — the app

contains none. We do not build a profile of you, and no automated decision-making with legal or

similarly significant effects takes place.

3.1 Website analytics — only if you choose

The website asks before loading Google Analytics. If you choose “Keep off”, it does not load and no analytics data is sent. If you choose “Allow on website”, it counts page visits and interactions such as Get the app, guide, source, RSS and share clicks. It does not receive your CRAGGEN display name, channel code, audio, contacts or app activity.

We have disabled Google Signals and advertising personalisation. Google uses an internet address transiently to derive broad location information and says individual IP addresses are not logged or stored for UK and EU traffic. Your consent choice is stored in your browser's local storage for up to 180 days so we do not ask on every visit. Google Analytics may set or read analytics storage only after you consent. You can withdraw consent at any time; withdrawal does not affect processing that was lawful before it.

4. Who your data goes to

The other people on your channel. That is the point of the app. When you talk, everyone

currently connected to that channel code hears you, and your display name appears on their roster.

Cloudflare, Inc. — our infrastructure provider. Cloudflare runs the relay that carries the audio

and sees the connection metadata. It acts as our processor and handles the data under its own

data-protection terms.

Google (Google Play). If you buy Pro or Crew, Google handles the payment and the purchase record as the

seller. Google is a separate controller for that, under Google's own privacy policy. We never see

your card details.

Google (Google Analytics). Only after you consent on this website, Google processes the limited website-use information described in section 3.1 on our behalf. Google Analytics does not run in the CRAGGEN app.

We do not sell or rent personal data. We do not “sell” or “share” personal information for cross-context behavioural advertising as those terms are used in US state privacy laws, and we do not use it for targeted advertising. Apart from the recipients above, we disclose limited information only where necessary to obtain professional advice, establish or defend legal claims, protect someone's vital interests, investigate abuse, or comply with a valid legal or regulatory requirement. Because we hold very little, there is usually very little to disclose.

5. Four things you should understand before using CRAGGEN

We would rather tell you these plainly than have you assume otherwise.

5.1 CRAGGEN is not end-to-end encrypted

Your audio is encrypted in transit using TLS, the same encryption a banking website uses — so

someone on the same Wi-Fi cannot listen in. But it is not end-to-end encrypted. That means the

audio is briefly readable as it passes through our relay. We do not listen to it, we do not record it,

and we have built no mechanism to do either — but we are not able to promise you it is technically

impossible for us, and we will not claim otherwise.

Do not use CRAGGEN for anything you would be harmed by someone else hearing. It is a walkie-talkie

for a group on a hill, not a secure communications tool.

5.2 Treat the channel code and PIN as access credentials

Generated channel codes use four readable words so people can share them accurately. Anyone who has a code can reach that channel. If there is no PIN, the code is enough to join; if the host adds a PIN, a new participant needs both. Invite links contain the channel code but never the PIN.

Everyone who joins appears on the roster, but anyone can type any display name — a name on the roster is not proof of identity. Use the generated code, add the included PIN lock, share both carefully and create a fresh channel if its details have spread beyond the intended group.

5.3 We store the channel PIN

If you set a PIN, it is saved against the channel code so the same private channel remains locked when people reconnect. The PIN is automatically cleared 24 hours after the channel becomes empty. A PIN is not linked to an account or verified identity.

5.4 Replay stays on the receiving phone

Pro and Crew can replay the last message that their own phone received. That temporary audio is held only in the app's memory, is replaced by the next received message and disappears when the user leaves the channel or the app process ends. It is never uploaded as a recording or written to our server storage.

If someone behaves badly, we therefore have no audio recording to review. A report contains the form you send, the channel and the display names involved, but no voice. We can investigate that limited information and disable a channel where justified.

6. International transfers

We are based in the United Kingdom. Cloudflare and Google are global companies, so the limited data described above may be processed outside the UK or the country where you live. Where data-protection law restricts a transfer, we use the safeguard that applies to the particular recipient and destination. This may be an adequacy regulation or decision, the UK International Data Transfer Agreement or UK Addendum, the European Commission's Standard Contractual Clauses, or an applicable data-privacy framework certification. We also assess supplementary technical and organisational safeguards where required.

You can ask info@craggen.com which mechanism applies to a particular transfer and for a copy of the relevant safeguard. We may redact confidential or third-party information, but we will provide a meaningful explanation.

7. Your rights

Depending on where you live and the reason we use the data, you may have the right to be informed; ask whether we hold personal data about you and receive a copy; correct inaccurate data; erase data; restrict processing; object to processing based on legitimate interests; receive portable data; and withdraw consent. You also have the right not to be subject to a decision based solely on automated processing that has legal or similarly significant effects. CRAGGEN does not make such decisions.

Your right to object: where we rely on legitimate interests, you may object for reasons relating to your situation. We must stop unless we can show compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed for legal claims. You can object to direct marketing at any time; we do not use your data for direct marketing.

The honest position: there is very little for us to find. We hold no account, no email address and

no identifier for you, so if you ask us for "your data" we generally will not be able to link anything

to you — and we will not ask you for identity documents just to prove a negative. What we can do:

locate or delete a recent moderation report if you can give us enough detail to identify it;
confirm exactly what the service does and does not hold (this page);
delete anything you send us in an email to us, once it is dealt with.

Email info@craggen.com to exercise a right. We normally respond within one month. We do not charge unless a request is manifestly unfounded or excessive, and we may ask for proportionate information to verify that the data is yours. A right may have legal exceptions; if we cannot comply fully, we will explain why and tell you how to complain.

You can delete everything the app has stored about you at any time by uninstalling it, or via Android

Settings → Apps → CRAGGEN → Storage → Clear data.

If you are unhappy with how we have handled your data you can complain to the UK regulator, the

Information Commissioner's Office — https://ico.org.uk/make-a-complaint/ , helpline 0303 123 1113.

We would rather you told us first so we can fix it.

Rights outside the United Kingdom

If EU or EEA data-protection law applies, you may complain to the supervisory authority where you live or work, or where the alleged infringement happened. If an applicable US state privacy law gives you rights to know, correct, delete or obtain a portable copy, or to appeal our response, you may use the same email address. CRAGGEN does not sell personal information, share it for cross-context behavioural advertising, use it for targeted advertising, or use sensitive personal information to infer characteristics. Residents of Canada, Australia and New Zealand may also contact us to request access or correction and to raise a privacy complaint; if unresolved, they may approach their local privacy regulator. These statements do not reduce any right that applies under your local law.

8. Children and young people

CRAGGEN is used outdoors by walking groups, and some of those include young people. We have deliberately

built it to hold as little as possible: no accounts, no location, no adverts, no profiling, no

tracking in the app, and high-privacy defaults.

CRAGGEN is not intended for children under 13. The app asks you to confirm that you are 13 or older the first time you

open it.

Under-18s should use CRAGGEN with the knowledge of a parent, guardian or group leader.
For group leaders (Scouts, DofE, school and youth groups): please read section 5. Anyone with

the code can attempt to reach the channel, and a channel without a PIN can be joined with the code alone.

Because roster names are not verified, use the generated code, set a PIN, keep both within your group, and

supervise use in the same way you would supervise any other open communication channel.

If you believe a child's data has been collected in a way you are not comfortable with, or you have

a safeguarding concern about someone's behaviour on a channel, contact

info@craggen.com and we will act. If a child is at immediate risk, contact the

police on your local emergency number.

9. Security

All traffic between the app and our relay uses TLS. The app is configured to refuse unencrypted

connections.

We minimise by design: no accounts, no server-stored voice, no collected location and no in-app analytics.
The relay caps channel size, drops oversized data, and strips control characters from names and

PINs.

We are not end-to-end encrypted (section 5.1) and we do not pretend to be.

If you find a security problem, please email info@craggen.com. We will not take legal action against anyone who reports a genuine vulnerability

to us responsibly and gives us a reasonable chance to fix it.

10. Changes to this policy

If we change what CRAGGEN does with data we will update this page and the date at the top, and we will

say what changed. If the change is significant we will tell you in the app before it takes effect.

This policy describes the current app and website. The Google Play Data safety declaration must remain consistent with it. We review both when the app, its permissions, its service providers or its data handling changes.

11. Contact

I Enterprise Ltd, Suite 2.06b C4di @TheDock, 31-38 Queen Street, Hull, East Riding of Yorkshire, England, HU1 1UU,

United Kingdom. Company number 13225768.

Email: info@craggen.com