Draft for legal review
Privacy policy
Last updated
1. Who we are
This policy explains how [Company legal name], registered at [Registered address] ("we", "us"), handles personal data in connection with CompleteVantage, a hosted digital signage service, and this website.
Contact for privacy questions: [Contact email]. [Data protection officer or EU/UK representative, if required.]
2. Our role: controller or processor
We handle personal data in two different roles.
- As processor, for our customers. Content that customers upload or connect (images, videos, documents, web pages, calendars), and data about their screens and how they play, is handled on the customer's instructions. For this data the customer is the controller and we are the processor, under our Data processing agreement. If you are, for example, an employee shown on a celebration screen, or a person whose meeting appears on a room board, contact the organization that runs those screens first.
- As controller. Data about the people who hold accounts with us, billing contacts, and visitors to this website who contact us.
3. What we collect
Account data
Name, email address, organization name, role, a password stored as a one-way hash, sign-in times, and an activity log of changes made in the admin (who changed what, and when). If you become a paying customer, billing contact details and subscription records.
Screen and device data
When a screen is paired and running, it sends us:
- device information: model, operating system version, app and player version, screen resolution and time zone;
- network information: the IP address it connects from;
- status: when it last checked in, whether the display is on, errors from the player, and app update progress;
- proof-of-play logs: which content played on which screen and when;
- screenshots, only when a person with access requests one, or while they have live view open for that screen.
Screenshots show whatever is on the screen at that moment, which may include Customer Content.
Customer Content
Files, text, layouts, playlists, schedules, web page addresses and calendar links that customers add. Calendar events are fetched by our server and cached so room boards can show them. Events marked private are shown as "Busy". Access keys for web pages are stored so they can be sent to screens; they are not shown back in the admin.
Website contact form
If you contact us through the website, we collect your name, email address, organization and message, to reply to you.
Payments
Payments are handled by Stripe. We receive the status of your subscription and payments, and identifiers for your customer and subscription records. We do not receive or store full card numbers.
4. Why we use it, and our legal bases
| Purpose | Data | Legal basis (where GDPR applies) |
|---|---|---|
| Providing the service and signing you in | Account data | Contract |
| Running screens, showing status, alerts and reports | Screen and device data | Contract (for the customer, as its processor) |
| Billing and accounting | Billing data | Contract; legal obligation |
| Security, preventing abuse, rate limiting | Account data, IP addresses, activity log | Legitimate interests |
| Replying to enquiries | Contact form data | Legitimate interests |
| Service emails (alerts, password resets, notices) | Email address | Contract |
We do not sell personal data, and we do not use it for advertising.
5. Cookies
This website and the admin use one session cookie, which keeps you signed in and protects forms against cross-site request forgery. It is strictly necessary and is removed when the session ends.
We do not use analytics cookies, advertising cookies or third-party tracking on this site.
The browser player may store content in the browser's cache and local storage so screens can keep playing offline. This stays on the screen's device.
6. Sub-processors
We use the following service providers to run CompleteVantage.
| Sub-processor | Purpose | Location |
|---|---|---|
| [Hosting provider] | Servers, database and file storage | [Location] |
| [Email provider] | Sending alert, password reset and service emails (SMTP) | [Location] |
| Stripe | Payment processing and subscription billing | [Location] |
| Open-Meteo | Weather data for the weather widget | [Location] |
Note: The weather widget is fetched directly by the screen from Open-Meteo, using the location set in the layout. Open-Meteo receives the screen's IP address and that location, not account data.
Customers may also point screens at third-party services themselves, for example web dashboards, YouTube videos, video streams and RSS feeds. Those services receive requests from the screen or our server under the customer's control, and their own privacy policies apply.
7. How long we keep data
| Data | Default retention |
|---|---|
| Proof-of-play logs | 400 days |
| Activity (audit) log | 2 years |
| Screens that start pairing but never finish | 7 days |
| Database backups | 14 days |
| Account data and Customer Content | While the account is active, then deleted as described in our Terms |
| Contact form messages | [Retention period] |
| Billing records | As required by tax and accounting law, [Number] years |
Only the latest screenshot of each screen is kept; each new one replaces the previous file. [Confirm deletion when a screen is removed.]
8. How we protect data
Data is separated per organization, and every query is limited to the signed-in organization. Passwords and screen device tokens are stored only as hashes. Uploads live at private, unguessable paths. Sign-in and pairing are rate-limited. More detail is on our security page.
9. International transfers
[Describe where data is hosted.] Where personal data is transferred outside the UK or European Economic Area, we rely on [adequacy decisions / Standard Contractual Clauses / other safeguard], and you can ask us for a copy of the relevant safeguards.
10. Your rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you;
- correct it if it is wrong;
- have it deleted;
- restrict or object to certain processing;
- receive it in a portable format;
- withdraw consent where we rely on consent;
- complain to a data protection authority, for example [Supervisory authority].
To use these rights, email [Contact email]. If your request concerns data we hold as a processor for a customer, we will pass it to that customer and help them respond.
11. Children
CompleteVantage is a business service and is not directed at children. We do not knowingly collect personal data from children through the admin or this website.
12. Changes to this policy
We will post changes on this page and update the date at the top. For material changes we will also notify organization owners by email.
Contact: [Company legal name], [Registered address], [Contact email].