CSent Privacy Policy

CSent is operated by Talarge Technologies Ltd, a company registered in the United Kingdom.

Talarge Technologies Ltd is the controller responsible for the personal information described in this Privacy Policy.

Talarge Technologies Ltd is registered as a data protection fee payer with the UK Information Commissioner's Office (ICO).

Talarge Technologies Ltd

Company number: 16806697

2 Herman Terrace

Chatham

ME4 5NX

United Kingdom

Privacy: privacy@csent.app

Support: support@csent.app

CSent is a private relationship communication service designed to help adults explore what matters to them, communicate with other people, understand each other better and keep information they deliberately choose to save.

Depending on the features you choose to use, CSent may allow you to:

• explore relationship ideas, conversation prompts, games, educational content and support resources;
• save ideas or make private plans;
• start or join a Connection and make choices privately;
• discover choices that become mutual through a Connection;
• communicate through CSent messaging features;
• create or join an Our Space with another person;
• use Check In to reflect privately and receive limited shared insights;
• use Us to answer separately and discover answers together;
• record selected boundaries or preferences privately and choose which of them to share;
• participate in Community discussions;
• keep Private Records, files and notes;
• receive notifications; and
• manage account, privacy and safety settings.

CSent is a communication, relationship and personal-record tool. It is not an emergency service, law-enforcement service, court or investigative service and is not a substitute for professional medical, legal, mental-health, relationship or safeguarding advice.

CSent does not determine whether legal consent exists, determine guilt or innocence, verify users' accounts of events, determine relationship compatibility, or guarantee that any record will be accepted as evidence in legal proceedings.

It is important to distinguish between consent between people and permission or consent for personal-data processing.

Creating a CSent account, accepting the Terms of Use, acknowledging this Privacy Policy or giving Talarge Technologies Ltd permission to process particular information does not constitute consent to sexual activity or any other interpersonal activity.

Likewise, a choice, preference, message, acknowledgement or other record in CSent should not be treated as permanent or continuing consent to future activity.

Consent between people is ongoing and may be changed or withdrawn. CSent records communications, choices and events made through the service; it does not itself determine whether legal consent exists in any particular circumstances.

The information we process depends on the CSent features you use.

Account and profile information

We may process:

• your name or display name;
• email address;
• account identifier;
• account creation information;
• email-verification status;
• confirmation that you meet CSent's minimum age requirement;
• preferences;
• notification settings;
• privacy settings; and
• account or deletion-request status.

Connections

When you create or participate in a Connection, we may process information necessary to create, join, operate and retain that Connection.

• Connection and participant identifiers;
• invitation information;
• Connection type;
• participation and status information;
• dates and timestamps;
• choices made through the Connection;
• mutual choices or outcomes;
• confirmation events;
• pause, withdrawal or ending events; and
• information necessary to provide and maintain the Connection record.

Connection Chat

If you use Connection Chat, we process messages exchanged through the Connection together with associated information such as sender, timestamp and limited read state. Messages may contain personal or sensitive information depending on what users choose to write.

Our Space

If you create or join an Our Space, we process information necessary to establish and operate that private space between its members. This may include space and membership identifiers, invitation and acceptance information, status information and information generated through the Our Space features you choose to use.

Membership of an Our Space does not automatically give another member access to information that a feature is designed to keep private.

Our Space Messages

If you use Messages within Our Space, we process the messages you send together with information necessary to deliver and display the conversation, such as sender, space, timestamps and relevant read state.

Check In

Check In allows members of an Our Space to answer selected questions separately. Your individual Check In answers are designed to remain private to you through the normal CSent interface.

When both participants complete a Check In, CSent may generate a limited shared summary based on the responses. The shared summary is designed not to reveal the other participant's individual answers.

Responses to private safety-related Check In questions are excluded from the shared summary and are not disclosed to the other participant through the Check In feature.

Us

Us allows two members of an Our Space to answer separately and then discover their answers together.

Answers are private from the other participant while the experience is in progress. Once both participants complete the relevant experience, the answers intended for mutual discovery become available to both participants through the reveal experience.

CSent may retain completed Us experiences so that participants can revisit what they have explored together.

Boundaries

Boundaries allows you to record selected preferences or boundaries for yourself and decide whether each one remains private or is shared with the other member of your Our Space.

A boundary marked Just for me is designed to remain unavailable to the other member through the normal CSent interface. When you deliberately choose to share a boundary, its current shared information becomes available to the other member. If you subsequently stop sharing it, it is removed from their current shared Boundaries view.

The recipient may use I understand to acknowledge seeing the current shared information. This acknowledgement does not mean agreement, acceptance, consent, permission or a promise to comply.

General Messages and message requests

CSent provides general Messages within My CSent in addition to Connection Chat and Our Space Messages. General messaging between users is available only after the applicable message-request process has been accepted.

We may process message-request information, conversation membership, messages, sender information, timestamps, limited read state, blocking or removal information, reports and information necessary to operate and protect the messaging service.

Where a message request originates from Community, CSent may process the information necessary to connect the request with the relevant non-anonymous Community participation. Anonymous Community participation is not made targetable for direct messaging through the normal Community interface.

Relationship Hub, Saved and Plans

Relationship Hub provides ideas, games, conversation prompts, educational content and support information.

CSent does not currently create a user-facing browsing history of every Relationship Hub item you view merely because you view it. If you deliberately save an item, we process the information necessary to associate that saved item with your account.

If you create a Plan, we may process the selected item, planned date or time, status and any optional private note you choose to add.

Private Records, files and notes

If you choose to use CSent's private record functionality, we process the information you choose to record about an incident, experience or other private matter. This may include notes, dates or times, descriptions, related files or material and other information you choose to include.

Where CSent allows you to attach or retain material, we may process the uploaded file, file information, an owner-visible file name or description, upload date, storage information, integrity information and limited information required to control or audit access.

These records are intended as private personal records. Creating a Private Record does not make a report to the police or another authority, and CSent does not investigate or verify what you record.

Post-Connection feedback

If you provide post-Connection feedback, we may process your selected response and any optional text you provide. This feedback is private to your account and is not provided to the other Connection participant through the normal CSent interface.

Community information

If you use CSent Community, we may process posts, replies, discussion activity, reports, moderation information and information necessary to operate and protect the Community.

Where you choose to post anonymously, CSent hides your displayed identity from other Community users. Anonymous posting does not mean that CSent itself has no record of which account created the content. We may retain the account association where necessary to operate, secure and moderate the Community.

Help and privacy requests

When you contact CSent or submit a privacy request, we may process account and contact details, your message, correspondence, request category, request status, internal administrative notes and information necessary to respond to and administer the request.

Notifications and push subscriptions

If you enable relevant notifications, CSent may process information necessary to deliver them, including browser or device push-subscription information. We aim to keep notification content discreet and avoid unnecessary sensitive information appearing on a device's lock screen.

Privacy Lock

CSent may provide Privacy Lock as an additional interface-level privacy control for selected areas of the service.

Privacy Lock is intended to reduce unintended access to protected CSent screens on a device. It does not replace your device's own security controls, account security or safe handling of your login credentials.

Information necessary to operate Privacy Lock may be stored locally on your browser or device. CSent's current PIN-based design verifies a derived value rather than storing the PIN itself in readable form.

Technical, security and audit information

We may process limited technical and operational information necessary to authenticate users, operate CSent, maintain security, prevent abuse, investigate technical or security issues, enforce access controls, maintain service integrity and maintain appropriate audit records.

CSent does not currently use personal information for behavioural advertising.

Most information processed by CSent is provided directly by you, generated through your use of CSent, or created as part of an interaction between CSent users.

Some shared records may therefore contain information relating to another participant. User-provided information is not necessarily independently verified by Talarge Technologies Ltd.

We only process personal information where we have an appropriate lawful basis. The basis depends on the purpose and circumstances.

Providing CSent

We process account information and information necessary to provide features that you request, including accounts, Relationship Hub features, Connections, Our Space, messaging, Community, Saved, Plans, Private Records and related functionality.

Our lawful basis is generally performance of our contract with you where processing is necessary to provide the CSent service you have requested.

Security and service integrity

We process limited account, technical, security and audit information where necessary to secure CSent, prevent misuse, investigate problems and protect the service and its users.

Our lawful basis is our legitimate interests in operating and protecting CSent, maintaining service integrity and preventing misuse, provided those interests are not overridden by your rights and interests.

Help and support

We process information submitted through Help so that we can respond to and administer your request. Depending on the circumstances, our lawful basis may be performance of our contract with you and/or our legitimate interests in supporting users and operating CSent.

Privacy requests and legal obligations

We process information necessary to handle privacy and data-protection requests and comply with applicable legal obligations. Our lawful basis may be compliance with a legal obligation and, where appropriate, our legitimate interests in administering and demonstrating compliance.

Community and moderation

We process Community content to provide the Community functionality requested by users. Our lawful basis is generally performance of our contract with you.

We process moderation, security and anti-abuse information based on our legitimate interests in protecting users and maintaining a safe and functional service.

Optional features and permissions

Some optional features require a choice or permission from you before they operate, such as browser or device push notifications. Where we rely on consent for a particular processing activity, you may withdraw that consent.

Some information users choose to record or communicate through CSent may constitute special category personal data under UK data-protection law, including information concerning a person's sex life, sexual orientation or health.

Where we process special category information, we identify an Article 6 lawful basis and an applicable condition under Article 9 of the UK GDPR.

Where explicit consent is the applicable condition for particular special-category processing, we will request that permission clearly and separately from acceptance of our Terms or acknowledgement of this Privacy Policy.

You may withdraw data-processing consent where consent is the basis on which processing depends. Withdrawal does not affect processing that was lawful before the withdrawal.

This type of data-processing permission is separate from interpersonal or sexual consent.

Visibility depends on the feature you use and the choices you make within it.

Information designed to remain private to you may include:

• private or non-mutual Connection choices;
• individual Check In answers, including private safety responses;
• Boundaries kept Just for me;
• private post-Connection feedback;
• Private Records, files and notes;
• private Plan notes; and
• other owner-only information.

Information designed to become shared in defined circumstances may include:

• mutual Connection outcomes and relevant shared Connection state;
• Connection Chat and Our Space Messages;
• completed Us answers intended for mutual reveal;
• limited Check In shared summaries;
• Boundaries you deliberately choose to share;
• relevant participation, membership or shared-space state; and
• other information that a feature clearly identifies as shared.

Another person's participation in a Connection or Our Space does not give them unrestricted access to your private information. Different features use different privacy and reveal rules, which may also be explained in the relevant interface.

CSent restricts administrative access to personal information.

Routine administrative functionality does not provide general browsing access to users' private Connection choices, private messages, individual Check In answers, private Boundaries, Private Records, files, notes or private post-Connection feedback.

Authorised personnel may access information where reasonably necessary for a specific support, security, privacy, legal or operational purpose and where an appropriate lawful basis exists.

We do not sell your personal information to advertisers.

We may make personal information available to:

• service providers that host or operate parts of CSent;
• database, authentication, storage, infrastructure or communications providers;
• professional advisers where reasonably necessary;
• regulators, courts or public authorities where disclosure is legally required; and
• another CSent user where the information forms part of functionality designed to be shared with that person.

Where service providers process information on our behalf, we require appropriate data-protection arrangements where required by law.

CSent does not automatically send your Private Records, files or notes to the police or other authorities.

CSent uses third-party technology and infrastructure providers. Our core database, authentication and storage infrastructure is currently hosted in the European Union.

Some providers or supporting infrastructure may process information outside the United Kingdom. Where UK personal information is transferred internationally and a safeguard is required, we use an appropriate transfer mechanism recognised under UK data-protection law.

You may contact privacy@csent.app for further information about applicable international-transfer arrangements.

We keep personal information only for as long as reasonably necessary for the purposes for which it is processed, subject to applicable legal, security and operational requirements.

Our current retention approach includes:

• Account and profile information: while your account remains active and for the limited period necessary to complete account closure and associated legal, privacy or security administration.
• Expired invitations: normally up to 30 days after expiry.
• Notifications: normally up to 12 months.
• Push subscriptions: until disabled, signed out, deleted, invalidated or no longer required.
• Post-Connection feedback: normally up to 12 months.
• Resolved Help requests: normally up to 24 months after resolution.
• Relevant administrative notes: normally up to 24 months after the underlying matter closes, unless longer retention is reasonably necessary.
• Security and audit information: normally up to 12 months, with longer retention where necessary for an active security, abuse, dispute or legal matter.
• Private-file access records: normally up to 12 months.
• Privacy and deletion request records: normally up to 3 years after closure of the request.
• Terms/privacy acknowledgement records: for the life of the account and normally up to 3 years after account closure.
• Community content: generally until deleted by the user, removed through moderation or dealt with as part of account closure, subject to legitimate security, moderation and legal requirements.
• Community moderation records: normally up to 24 months after the relevant matter closes, with longer retention where reasonably necessary for an ongoing or repeated abuse issue.
• Private Records, files and notes: primarily under the user's control while the relevant record and account remain active, subject to applicable deletion, security, legal and technical requirements.
• Connections and shared records: retained according to the continuing service relationship and the nature of the shared record, subject to applicable deletion and retention requirements.
• Our Space information, including messages, completed Check Ins, completed Us experiences and Boundaries: retained as necessary to provide the relevant feature and according to the continuing service relationship, user controls, the nature of shared records and applicable legal, security and operational requirements.
• Saved items and Plans: retained while needed to provide those account features, until removed by the user or dealt with as part of account closure, subject to applicable legal, security and operational requirements.

Where a fixed period is not appropriate, we consider the purpose for which information was collected, its sensitivity, whether it remains necessary, whether it relates to more than one user, applicable legal obligations, security requirements and whether deletion or anonymisation is appropriate.

You can request deletion of your CSent account through the available account/privacy controls.

Account deletion does not necessarily result in immediate deletion of every item involving your account. Some CSent information forms part of a record involving another participant.

Where information is private only to you and no longer needs to be retained, we will consider deletion or anonymisation as appropriate.

Where information forms part of another participant's shared record, we may need to consider the rights and interests of both participants, the relevant lawful basis, applicable legal obligations and the nature of the information before determining whether it should be retained, deleted or anonymised.

One participant cannot use account deletion to automatically delete another participant's independent private information. The right to erasure under data-protection law is not absolute.

We use technical and organisational measures designed to protect personal information according to its sensitivity. These include measures such as:

• authentication;
• access controls;
• database row-level security;
• participant-scoped access;
• private storage controls;
• restricted administrative access;
• trusted backend functions;
• security logging;
• integrity mechanisms for uploaded material; and
• discreet notification design.

No internet-connected service can guarantee absolute security. You are responsible for keeping your account credentials and devices secure.

Depending on the circumstances and the lawful basis involved, UK data-protection law may give you rights including:

• access to your personal information;
• correction of inaccurate information;
• erasure in applicable circumstances;
• restriction of processing in applicable circumstances;
• objection to certain processing;
• data portability where applicable; and
• withdrawal of consent where processing is based on consent.

Not every right applies in every situation. To exercise your rights, use the available CSent privacy controls or contact privacy@csent.app. We may need to take reasonable steps to verify your identity before completing a request.

Your right to object

Where we rely on legitimate interests to process your personal information, you have the right to object to that processing in applicable circumstances. Contact privacy@csent.app if you wish to object.

Depending on where you live, additional or different privacy rights may apply under local law. Nothing in this Privacy Policy is intended to limit rights that cannot lawfully be limited.

CSent is intended only for adults aged 18 or over. You must not create or use a CSent account if you are under 18.

Unless CSent expressly states otherwise, an 18+ declaration should not be understood as independent identity or age verification.

CSent does not currently make solely automated decisions about users that produce legal or similarly significant effects.

Features that generate mutual outcomes, shared summaries or conversational insights are intended to support the relevant CSent experience and are not legal, clinical or compatibility determinations.

If our use of automated decision-making changes in a way that requires additional privacy information, we will update this policy as required.

CSent uses limited cookies, browser storage and similar technologies to operate the service and remember relevant settings.

These may support authentication, invitations, app functionality, Privacy Lock, user preferences and optional push notifications.

CSent does not currently use behavioural advertising or advertising-tracking technologies. More information is available in our Cookies & Device Storage Notice.

CSent may provide links to external organisations, including health, wellbeing, relationship or support services. Some resources may be specific to a particular country or region and should be read in that context.

Those organisations operate independently and have their own privacy practices. Providing a link does not mean Talarge Technologies Ltd controls the external organisation or its processing of personal information.

We may update this Privacy Policy as CSent, our processing activities or applicable law change.

The current version, effective date and last-updated date will be displayed on this page.

Where a material change affects how we use personal information, we will take reasonable steps to bring it to users' attention before the new use begins where required.

If you have concerns about how we handle your personal information, please contact privacy@csent.app.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data-protection regulator.

If you live outside the UK, you may also have rights to contact a privacy or data-protection authority that applies in your jurisdiction.

Talarge Technologies Ltd

Company number: 16806697

2 Herman Terrace

Chatham

ME4 5NX

United Kingdom

Privacy: privacy@csent.app

Support: support@csent.app