Repair Workshop

Privacy Policy

1. ABOUT THIS PRIVACY POLICY

The legal entity is referred to in this Privacy Policy as “Repair Workshop,” “the Provider,” “we,” “us,” or “our.”

1.1 Scope

This Privacy Policy explains how Repair Workshop handles personal data in connection with:

a. the Repair Workshop iOS and iPadOS application;

b. Apple App Store subscriptions to the App;

c. subscription management through RevenueCat;

d. customer-support communications;

e. technical or diagnostic information that may be made available to us; and

f. privacy, legal and security enquiries.

1.2 Business-only application

Repair Workshop is designed for use by repair workshops, technicians and other businesses acting in the course of a trade, business or profession.

The App is not intended for personal, family or household use.

1.3 Separate workshop responsibilities

Businesses using Repair Workshop may use the App to process information about their own:

customers;
employees and contractors;
devices and repair jobs;
suppliers;
trade-ins;
invoices and payments; and
other workshop activities.

Each business using the App is responsible for its own privacy notices and legal obligations concerning that information.

This Privacy Policy is not a substitute for the privacy notice that each workshop must provide to its own customers, staff members and other individuals.

1.4 Public booking forms

Any separate public online-booking page or booking service is governed by the privacy notice displayed at the point where the booking is submitted.

Once a booking has been delivered to the selected workshop and stored inside the App, it is treated as part of that workshop’s Workshop Records under this Policy.

A public booking service must have a separate or supplementary notice if booking information passes through infrastructure controlled by Repair Workshop before delivery to the workshop.

2. DEFINITIONS

2.1 App

“App” means the Repair Workshop application for compatible iPhones and iPads.

2.2 Business User

“Business User” means the repair workshop, sole trader, company, partnership or other business using the App.

2.3 End Customer

“End Customer” means a customer, potential customer or other person whose information a Business User records in the App.

2.4 Local Data

“Local Data” means Workshop Records stored locally on a device on which the App is installed.

2.5 CloudKit Data

“CloudKit Data” means Workshop Records stored or synchronised through the private CloudKit database associated with the Apple Account used for the workshop.

2.6 Manual Backup

“Manual Backup” means an encrypted .rwbackup file generated through the App.

2.7 Provider Data

“Provider Data” means the limited information Repair Workshop actually receives or can access, including subscription-management information, support communications and certain technical information.

2.8 Workshop Records

“Workshop Records” means information entered, generated, imported or stored by a Business User through the App, including customer, repair, device, photograph, invoice, staff, trade-in, booking and business information.

3. PRIVACY SUMMARY

Repair Workshop is designed around the following principles:

Workshop Records are stored on the Business User’s devices.
When enabled, Workshop Records synchronise through the private CloudKit database associated with the workshop owner’s Apple Account.
Repair Workshop does not operate a central database containing Workshop Records.
Repair Workshop cannot ordinarily remotely view, search, retrieve, edit, export, restore or delete Workshop Records.
Manual Backup files are encrypted and remain under the Business User’s control.
Apple and RevenueCat separately process limited information required for App Store purchases and subscription administration.
RevenueCat is assigned a random pseudonymous identifier and is not provided with the Business User’s name, email address, telephone number, business name or Workshop Records.
The App does not contain an advertising SDK, behavioural analytics SDK or third-party crash-reporting SDK.
Repair Workshop receives identifiable information primarily when a person voluntarily contacts us for support, privacy or legal purposes.
We do not sell personal data or use App data for third-party advertising or cross-app tracking.

4. WHO IS RESPONSIBLE FOR PERSONAL DATA?

4.1 Provider Data

For Provider Data that we determine how and why to process, the legal provider identified at the beginning of this Policy is the data controller.

This includes information used to:

administer subscriptions;
provide support;
answer privacy enquiries;
prevent fraud or misuse;
protect the App;
comply with legal obligations; and
establish or defend legal claims.

4.2 Workshop Records

The Business User determines:

which Workshop Records are collected;
why the information is collected;
how it is used;
who among its staff may access it;
how long it is retained;
when it is corrected;
when it is exported; and
when it is deleted.

The Business User is responsible for its own privacy and data-protection compliance concerning those Workshop Records.

4.3 End Customer requests

An End Customer who wants to access, correct or delete information held in a workshop’s records should contact the relevant repair workshop directly.

Repair Workshop ordinarily cannot fulfil such a request because it cannot access the contents of the workshop’s Local Data or private CloudKit database.

4.4 RevenueCat

RevenueCat provides subscription-management services to us and processes limited subscription and purchase information for this purpose.

RevenueCat describes its role as a processor where it handles end-user information on behalf of an app developer. (RevenueCat)

4.5 Apple

Apple separately controls the App Store, Apple Accounts, iCloud, CloudKit, device backup, payment processing and Apple diagnostic systems.

Apple’s handling of information through those services is governed by Apple’s own privacy policies and service terms.

5. WORKSHOP RECORDS STORED THROUGH THE APP

5.1 Types of Workshop Records

Depending on how a Business User uses the App, Workshop Records may include:

a. customer names, telephone numbers and email addresses;

b. device brand, model, serial number and IMEI information;

c. repair tickets, fault descriptions, notes and technical findings;

d. photographs and attachments;

e. device passcodes or access information where entered by the Business User;

f. estimates, invoices, receipts and payment statuses;

g. warranty and repair-history information;

h. trade-in and device-purchase records;

i. booking and appointment information;

j. staff names, roles, permissions and internal profiles;

k. workshop prices, services and business settings; and

l. any other information entered or generated by the Business User.

This list describes information that the Business User may store in the App. It does not mean that Repair Workshop receives or can view that information.

5.2 Local storage

Workshop Records are stored locally on each device on which the relevant workshop is used.

5.3 Private CloudKit storage

When iCloud and the relevant App functionality are enabled, Workshop Records are stored and synchronised through the private CloudKit database associated with the workshop owner’s Apple Account.

Apple states that a CloudKit private database is available through the user’s iCloud account and, by default, only the user can access the private database. (Apple Developer)

5.4 No central Repair Workshop database

Repair Workshop does not operate a central database containing the Business User’s:

customer list;
repair tickets;
photographs;
device information;
invoices;
trade-in records;
staff information; or
other Workshop Records.

5.5 No ordinary Provider access

Under the current App architecture, Repair Workshop cannot ordinarily:

a. remotely view or search Workshop Records;

b. browse the Business User’s private CloudKit database;

c. retrieve customer names or contact details;

d. inspect repair photographs;

e. edit or delete Workshop Records;

f. create a data export on the Business User’s behalf; or

g. recover data from a Provider-controlled server backup.

5.6 No automatic transfer to us

Workshop Records are not automatically transmitted to Repair Workshop merely because the Business User creates, stores, synchronises, exports or deletes them through the App.

5.7 Information voluntarily sent to us

Repair Workshop will receive Workshop Record content only where the Business User deliberately sends particular information to us, for example by attaching a screenshot or file to a support request.

Such information is then handled as support information under Section 9.

6. ICLOUD, CLOUDKIT AND DEVICE BACKUP

6.1 Cross-device synchronisation

Compatible iPhones and iPads using the same workshop Apple Account may synchronise Workshop Records through CloudKit.

6.2 Apple-controlled service

Apple, rather than Repair Workshop, operates iCloud and CloudKit.

We do not control:

Apple service availability;
Apple Account access;
iCloud authentication;
iCloud storage allowances;
Apple’s backup schedules;
Apple’s encryption arrangements;
Advanced Data Protection settings; or
Apple’s data-recovery procedures.

6.3 Encryption claims

We do not claim that Apple is technically unable to access all iCloud or CloudKit information in every configuration.

Apple’s encryption and access arrangements can depend on the data type, App configuration, account settings and whether the Apple Account has Advanced Data Protection enabled. (Apple Support)

6.4 CloudKit is a synchronisation system

CloudKit synchronises changes between devices, including deletions.

It should not be treated as a permanent historical archive of every previous version of a record.

6.5 Standard Apple device backup

The App does not intentionally exclude eligible Local Data from Apple’s standard device-backup processes.

Depending on the Business User’s settings and Apple’s current rules, eligible App data may be included in an iCloud or device backup.

Repair Workshop cannot confirm that a specific file:

was included in a backup;
remains available;
is complete;
is compatible with a replacement device; or
will restore successfully.

6.6 Replacement devices

Where Workshop Records have successfully synchronised to the private CloudKit database, installing the App on a compatible replacement device using the same Apple Account is designed to allow the records to synchronise to that device.

Repair Workshop cannot directly retrieve the records from Apple or perform that restoration on the Business User’s behalf.

7. MANUAL BACKUPS AND EXPORTS

7.1 Encrypted Manual Backups

The App allows the Business User to create an encrypted .rwbackup Manual Backup.

Manual Backup files use AES-256-GCM encryption, with the encryption key derived from the workshop owner’s PIN.

7.2 Business User control

The Business User chooses:

when to create the backup;
where the backup is stored;
whether it is copied to another service or device;
who can access it; and
when it is deleted.

7.3 No Provider copy

Repair Workshop does not automatically receive or retain a copy of a Manual Backup.

7.4 No master recovery key

Repair Workshop does not retain a master key capable of opening every Manual Backup.

If the required PIN or recovery information is lost, Repair Workshop cannot guarantee that the backup can be decrypted or restored.

7.5 Backups sent for support

Where a Business User deliberately sends a Manual Backup or exported file to us for technical support, it becomes support information and is handled under Sections 9 and 14.

Business Users should not send an entire Workshop Record database unless it is genuinely necessary and has been agreed with support.

7.6 Separate copies

Deleting data inside the App does not automatically delete Manual Backup files previously saved in Files, iCloud Drive, external storage, email or another location.

The Business User is responsible for deleting those separate copies.

8. APP PERMISSIONS AND ON-DEVICE PROCESSING

8.1 Camera

Where the Business User grants camera permission, the App may use the camera to:

photograph a device;
document device condition;
attach an image to a repair ticket;
scan a QR code; or
perform another function selected by the Business User.

Images captured for Workshop Records are stored locally and, where enabled, through the private CloudKit database. They are not automatically sent to Repair Workshop.

8.2 Photos and files

Where permission is granted, the App may allow the Business User to:

select an image;
import a file;
save an invoice;
export a report; or
create or restore a Manual Backup.

These actions are initiated by the Business User.

8.3 iCloud

iCloud access is used for private CloudKit storage, synchronisation and related Apple recovery functions.

8.4 Communication applications

The App may use Apple share sheets or third-party applications to prepare or transfer information through:

WhatsApp;
email;
printing services;
messaging applications; or
another service selected by the Business User.

The Business User initiates the transfer. Once transferred to another service, that service’s privacy practices apply.

8.5 Permission control

The Business User can review or revoke App permissions through the device’s iOS or iPadOS settings.

Revoking a permission may prevent the relevant App feature from operating.

8.6 Apple App Privacy treatment

Apple’s App Privacy guidance states that data processed only on the device is not treated as “collected” for the App Store privacy questionnaire unless something derived from it is transmitted off-device to a developer or integrated third party. (Apple Developer)

9. INFORMATION REPAIR WORKSHOP ACTUALLY RECEIVES

9.1 Subscription and purchase information

The App uses Apple In-App Purchases and RevenueCat to administer subscription entitlements.

RevenueCat automatically generates a random pseudonymous App User ID when its SDK is initialised without a custom user identifier.

A new random identifier may be generated after the App is deleted and reinstalled. Purchase restoration may associate or merge anonymous subscription records so that the Apple purchase can be recognised. (RevenueCat)

RevenueCat may process:

a. the random RevenueCat App User ID;

b. App Store purchase receipts;

c. transaction and order identifiers;

d. the purchased subscription product;

e. purchase, renewal and expiry dates;

f. trial and entitlement status;

g. cancellation, refund or revocation status;

h. subscription ownership or restoration information;

i. store, platform and App version information;

j. locale and currency information; and

k. transaction country or a country derived from a temporarily processed IP address.

RevenueCat states that it does not persist the full IP address after using it to determine country. (RevenueCat)

9.2 Information not supplied to RevenueCat

Under the App’s current configuration, Repair Workshop does not supply RevenueCat with:

the Workshop Owner’s name;
email address;
telephone number;
business name;
postal address;
Apple Account identifier;
advertising identifier;
customer list;
repair tickets;
photographs;
invoices;
staff records; or
other Workshop Records.

9.3 Subscription analytics

RevenueCat uses purchase history to:

validate receipts;
prevent purchase fraud;
enable subscription entitlements;
show customer purchase history under pseudonymous identifiers; and
provide aggregated subscription metrics such as revenue, renewals and cancellations.

This is subscription analytics, not behavioural tracking of how a person uses repair tickets or Workshop Records.

RevenueCat’s current Apple privacy guidance requires purchase history to be declared for App Functionality and Analytics. It states that purchase history may be marked as not linked to identity where anonymous IDs are used and the developer has no means of identifying the individual. (RevenueCat)

9.4 Subscription Support ID

The App may display a RevenueCat Subscription Support ID.

A Business User may voluntarily provide that ID when asking us to investigate a purchase, renewal or entitlement problem.

Until a Business User supplies the Support ID together with a support enquiry, we ordinarily cannot associate the anonymous RevenueCat record with a particular person or workshop.

9.5 Payment-card information

Subscription payments are processed by Apple.

Repair Workshop and RevenueCat do not receive the Business User’s complete payment-card number or Apple Account password.

9.6 Support communications

When a person contacts us, we may receive:

a. their name;

b. email address;

c. telephone number, if provided;

d. workshop or business name;

e. the contents of their message;

f. the Subscription Support ID;

g. App and operating-system version;

h. device model;

i. screenshots or screen recordings;

j. error descriptions;

k. exported files or sample records voluntarily supplied; and

l. correspondence concerning the support request.

Providing support information is generally voluntary. However, we may be unable to investigate a problem without enough information to understand it.

9.7 Redaction requirement

A Business User should remove or obscure customer information that is not necessary before sending a:

screenshot;
screen recording;
invoice;
database;
photograph;
ticket;
Manual Backup; or
other support attachment.

9.8 Credentials that must not be sent

A Business User must not send us:

an Apple Account password;
an Apple authentication code;
a device passcode;
a customer’s device passcode;
an online-banking credential;
a payment-card number; or
a Manual Backup PIN.

Repair Workshop will not require the Business User’s Apple Account password.

9.9 Apple crash and diagnostic information

The App does not include:

a third-party crash-reporting SDK;
a behavioural analytics SDK;
an advertising SDK; or
a user-session recording SDK.

Apple may independently collect crash and diagnostic information according to Apple’s systems and the device owner’s privacy and analytics settings.

Where the device owner permits diagnostic sharing with developers, Apple may make limited technical information available to us, such as:

App version;
operating-system version;
device model;
time of the event;
exception or stack-trace information; and
technical state associated with a crash.

The App is designed not to include customer names, repair tickets, photographs, invoices or other Workshop Record content in its debug logging.

However, no software provider can guarantee that an unexpected operating-system or technical report could never contain incidental information.

9.10 Terms-acceptance record

The App may create a record showing:

the authorised person’s typed name;
business name;
acceptance date and time;
accepted Terms version;
App version; and
a local installation or device reference.

This acceptance record is stored as Local Data and, where enabled, as private CloudKit Data.

It is not automatically transmitted to Repair Workshop.

We receive it only if the Business User deliberately exports or sends it to us.

10. INFORMATION WE DO NOT COLLECT OR USE

Under the current App configuration, Repair Workshop does not:

a. operate a Provider-accessible database of Workshop Records;

b. collect customer contact lists from the App;

c. remotely access repair tickets or photographs;

d. receive Apple Account passwords;

e. receive complete payment-card information;

f. use the Apple advertising identifier for App tracking;

g. include an advertising network;

h. include a behavioural analytics SDK;

i. include a third-party crash-reporting SDK;

j. sell personal data;

k. use Workshop Records for advertising;

l. track Business Users across unrelated apps or websites for advertising; or

m. create behavioural profiles from Workshop Records.

We do not use support contact details for unrelated marketing unless the person has separately and expressly requested such communication.

11. WHY WE PROCESS PROVIDER DATA

We rely on the following purposes and lawful bases where the GDPR applies.

Processing activity	Purpose	Lawful basis
Subscription and entitlement administration	To verify purchases, enable paid features, restore subscriptions and apply read-only access when required	Performance of a contract where the subscriber is the contracting individual; otherwise our legitimate interest in administering the business subscription
Subscription support	To investigate missing entitlements, renewals, refunds and purchase-restoration issues	Performance of a contract and our legitimate interest in providing effective support
Subscription analytics	To understand active subscriptions, revenue, renewals, cancellations and product performance using pseudonymous purchase information	Our legitimate interest in operating and improving the subscription service
Fraud and misuse prevention	To detect invalid receipts, refunded purchases, entitlement bypassing and security misuse	Our legitimate interest in protecting the App, customers and revenue
Technical support	To investigate and answer a support request	Performance of a contract, steps requested before or during service delivery, and our legitimate interest in providing support
Crash and diagnostic review	To identify technical failures, security problems and compatibility issues	Our legitimate interest in maintaining a secure and reliable App
Privacy requests	To identify, assess and respond to a data-protection request	Legal obligation and our legitimate interest in demonstrating compliance
Legal and accounting records	To comply with tax, accounting, regulatory and legal duties	Legal obligation
Disputes and claims	To establish, exercise or defend legal claims	Our legitimate interest in protecting our legal rights
Optional communications based on consent	To send a communication where we specifically ask for consent	Consent

11.1 Contractual necessity

Where the Business User is a company and the person using the App is an employee or representative rather than the contracting party, we may rely on legitimate interests rather than contractual necessity for processing that representative’s information.

11.2 Legitimate interests

Our legitimate interests include:

administering App subscriptions;
providing customer support;
maintaining App reliability;
preventing fraud;
protecting systems and users;
understanding subscription performance; and
establishing or defending legal rights.

We consider the limited and pseudonymous nature of most Provider Data when balancing these interests against individual privacy rights.

11.3 Consent

We do not rely on acceptance of the Business Terms as blanket consent for all personal-data processing.

Where we rely on consent for a particular optional purpose, the consent may be withdrawn without affecting processing that took place before withdrawal.

12. WHEN WE SHARE PROVIDER DATA

12.1 RevenueCat

We share or permit access to the limited subscription information described in Section 9 so RevenueCat can validate purchases and administer entitlements.

RevenueCat does not receive Workshop Records through this integration.

12.2 Apple

Apple handles information associated with:

the App Store;
In-App Purchases;
Apple Accounts;
payment processing;
CloudKit;
iCloud;
device backup; and
Apple diagnostics.

We do not control Apple’s independent processing.

12.3 Email and support-service providers

Our email, website or hosting providers may process information necessary to deliver and secure support communications.

They may receive:

sender and recipient addresses;
message content;
attachments;
time and delivery information; and
routine security or mail-server logs.

12.4 Professional advisers

We may disclose limited information to professional advisers, including:

solicitors;
accountants;
auditors;
insurers; and
security consultants,

where reasonably necessary and subject to professional or contractual confidentiality obligations.

12.5 Legal requirements

We may disclose Provider Data where reasonably necessary to:

comply with law;
comply with a court order;
respond to a lawful authority;
investigate fraud;
protect security;
protect the rights of another person; or
establish, exercise or defend legal claims.

12.6 Business reorganisation

If the App or relevant business is sold, merged, transferred or reorganised, limited Provider Data may be disclosed to professional advisers and the proposed recipient under appropriate confidentiality and data-protection safeguards.

Workshop Records cannot be transferred by us as part of such a transaction because we do not possess them.

12.7 No sale or advertising sharing

We do not sell personal data.

We do not disclose Provider Data to advertising networks or data brokers.

13. INTERNATIONAL DATA TRANSFERS

13.1 RevenueCat processing in the United States

RevenueCat states that information it processes is stored using Amazon Web Services infrastructure in the United States. (RevenueCat)

Where EEA personal data is transferred to a country that does not benefit from an applicable adequacy decision, we use contractual safeguards available under our arrangement with RevenueCat.

RevenueCat’s Data Processing Addendum incorporates the European Commission’s Standard Contractual Clauses for relevant EEA restricted transfers. (RevenueCat)

13.2 Apple

Apple may process information through its international infrastructure according to its applicable terms, privacy policy and legal safeguards.

13.3 Other providers

A support, email, hosting or professional-service provider may process Provider Data outside Ireland or the EEA.

Where legally required, we will use an appropriate transfer mechanism, such as:

an adequacy decision;
approved Standard Contractual Clauses;
another legally recognised contractual safeguard; or
a specific legal exception.

13.4 Workshop Records

This international-transfer section does not mean that Repair Workshop receives Workshop Records.

CloudKit and iCloud storage are supplied by Apple under the Business User’s Apple Account and Apple’s own terms.

14. HOW LONG WE RETAIN INFORMATION

We retain personal data only for as long as reasonably necessary for the relevant purpose, legal obligation or dispute.

The GDPR does not impose one universal retention period. Organisations must set periods according to purpose and applicable legal duties and must not retain personal data longer than necessary. (Homepage | Data Protection Commission)

14.1 Retention schedule

Information	Retention period
Local Workshop Records	Until deleted by the Business User, removed with the App from the device, or deleted through the Close Workshop function
Private CloudKit Data	Until deleted by the Business User through the App or otherwise removed under Apple’s systems and terms
Manual Backup files	Until deleted by the Business User from every location in which a copy was saved
Active RevenueCat subscription and entitlement information	For the duration of the subscription and while required to restore, validate or administer the entitlement
Expired pseudonymous subscription records	Ordinarily up to 12 months after the subscription ends, unless required longer for transaction reconciliation, fraud prevention or a dispute
Transaction, tax and accounting records	Up to six years from the end of the relevant accounting period, or longer where a Revenue inquiry, audit, dispute or legal requirement remains open
Routine support correspondence	Up to 12 months after the support request is closed
Support screenshots, exported records and other attachments	Ordinarily deleted within 90 days after the support request is closed, unless required for an unresolved technical, security or legal matter
Apple crash or diagnostic reports separately retained by us	Up to 12 months, unless needed for an unresolved security issue or legal claim
Privacy-rights request records	Up to three years after the request is closed, to demonstrate how the request was handled
Legal disputes and claims	Until the dispute is resolved and any relevant limitation or appeal period has expired
Terms-acceptance record stored in the App	Until deleted by the Business User with the Workshop Records
Terms-acceptance record deliberately supplied to us	Up to six years after the relevant business relationship ends where required to establish or defend contractual rights

Irish Revenue currently states that businesses must generally retain relevant tax records for six years. (Revenue Ireland)

14.2 Earlier deletion

We may delete or anonymise information sooner where:

it is no longer required;
the purpose has ended;
deletion is requested and no lawful reason for continued retention applies; or
continued retention would be disproportionate.

14.3 Extended retention

We may retain information longer where reasonably necessary because of:

a legal obligation;
litigation;
a complaint;
an investigation;
suspected fraud;
a security incident; or
a lawful authority request.

14.4 Third-party retention

Apple and RevenueCat may retain information according to their own contractual and legal requirements.

Deleting information from our own records does not necessarily delete an Apple App Store transaction record or purchase history held by Apple.

15. SECURITY

15.1 Privacy-focused architecture

The App reduces Provider-side data exposure by not maintaining a central Provider-accessible database of Workshop Records.

15.2 Manual Backup encryption

Manual Backup files are encrypted using AES-256-GCM with a key derived from the workshop owner’s PIN.

15.3 Provider security measures

For Provider Data that we receive, we use reasonable technical and organisational measures appropriate to its nature, which may include:

access controls;
strong passwords;
multi-factor authentication where supported;
restricted staff access;
secure service providers;
data minimisation;
software updates;
backup and recovery controls;
retention and deletion procedures; and
confidentiality obligations.

15.4 Business User responsibilities

Business Users are responsible for protecting:

their Apple Account;
device passcodes;
workshop owner PIN;
Staff Profile PINs;
devices;
Manual Backups;
exported documents;
iCloud recovery information; and
staff access permissions.

15.5 No absolute guarantee

No device, internet service, cloud system, email system or encryption process can be guaranteed to be completely secure or continuously available.

15.6 Security incidents

Where we become aware of a security incident affecting Provider Data that we control, we will investigate and take the steps required by applicable law.

A lost workshop device, compromised Apple Account or exposed Manual Backup may constitute a data-protection incident for the Business User. The Business User is responsible for assessing and responding to incidents involving its own Workshop Records.

16. USER CONTROLS, DELETION AND ACCOUNT CLOSURE

16.1 Deleting the App

Deleting the App from a device removes the App and its Local Data from that device.

Deleting the App does not necessarily delete Workshop Records stored in the private CloudKit database.

16.2 Reinstallation

If CloudKit Data remains available and the App is reinstalled using the same Apple Account, the Workshop Records may synchronise back to the device.

16.3 Close Workshop function

The in-App Close Workshop Account, Close Workshop or Delete Workshop Data function is designed to:

close the local Workshop Profile;
delete associated Local Data; and
request deletion of the associated data in the App’s private CloudKit storage.

Deletion may be permanent and irreversible.

16.4 Manual Backups unaffected

Closing the workshop does not automatically delete Manual Backup files saved outside the App.

16.5 Subscription unaffected by data deletion

Deleting the App or closing the workshop does not automatically cancel an Apple App Store subscription.

The subscription must be cancelled separately through Apple’s subscription settings.

16.6 Data unaffected by subscription cancellation

Cancelling a subscription does not automatically delete Workshop Records.

After the applicable grace period, the App may enter Read-Only Mode, but existing records remain under the Business User’s control.

16.7 Deleting RevenueCat subscription data

A Business User may contact us to request deletion of a pseudonymous RevenueCat user record.

To locate the correct record, we may require:

the RevenueCat Subscription Support ID;
an Apple transaction or order identifier; or
other information reasonably necessary to identify the subscription record.

Deleting a RevenueCat record does not delete the underlying purchase history held by Apple.

Deletion may also affect the App’s ability to recognise or restore a subscription until the purchase is restored again.

16.8 Deleting support information

A person may ask us to delete support correspondence or attachments.

We will comply where the information is no longer required and no legal, contractual, fraud-prevention or security reason requires continued retention.

16.9 Apple-held information

Requests concerning Apple Account information, iCloud, App Store purchase history or Apple diagnostics should be directed to Apple through the controls and rights provided by Apple.

17. DATA-PROTECTION RIGHTS

Depending on applicable law and circumstances, an individual may have the right to:

a. obtain confirmation that we process their personal data;

b. request access to that personal data;

c. request correction of inaccurate information;

d. request deletion;

e. request restriction of processing;

f. object to processing based on legitimate interests;

g. receive portable data where the portability right applies;

h. withdraw consent where processing is based on consent;

i. lodge a complaint with a supervisory authority; and

j. receive information about relevant international-transfer safeguards.

17.1 Rights apply to Provider Data

These rights apply to personal data that Repair Workshop actually controls.

We cannot provide access to, correct or delete Workshop Records that we cannot access.

17.2 Pseudonymous subscription records

Because RevenueCat subscription information is not deliberately connected to a name or email address, we may be unable to locate a record from a name alone.

A person requesting access to or deletion of RevenueCat data may need to provide their Subscription Support ID or relevant transaction identifier.

17.3 Identity verification

We may request reasonable information to verify:

the requester’s identity;
the requester’s authority to act for another person; and
the connection between the requester and the relevant Provider Data.

We will not request more identification than is reasonably necessary.

17.4 Response time

Where GDPR time limits apply, we will respond without undue delay and ordinarily within one month.

That period may be extended by up to two additional months for a complex request or multiple requests, but we will explain the extension within the initial one-month period. (Homepage | Data Protection Commission)

17.5 Exercising rights

Requests should be sent to:

Email: support@repairworkshop.net
Subject: Privacy Rights Request

The request should explain:

the right being exercised;
the information concerned;
the Subscription Support ID, where relevant; and
any other details reasonably required to locate the information.

17.6 Complaints

A person may raise a concern with the Irish Data Protection Commission:

Data Protection Commission
6 Pembroke Row
Dublin 2
D02 X963
Ireland

Email: info@dataprotection.ie

The Data Protection Commission recommends first raising the concern directly with the organisation where possible. (Homepage | Data Protection Commission)

A person may also complain to another competent supervisory authority where applicable.

18. END CUSTOMERS OF REPAIR WORKSHOPS

18.1 Contact the workshop

An End Customer whose information has been entered into Repair Workshop should direct privacy enquiries to the repair workshop that collected the information.

18.2 Repair Workshop cannot search workshop databases

We cannot ordinarily search workshops’ devices or private CloudKit databases to determine whether a particular workshop has recorded someone’s information.

18.3 Information sent to us by mistake

If an End Customer sends a privacy request to us concerning a workshop’s records, we may:

explain that the workshop controls the record;
direct the person to the workshop;
ask for enough information to identify the workshop, where appropriate; and
delete information sent to us once it is no longer required.

We will not request the End Customer’s device passcode, account password or other unnecessary sensitive information.

19. CHILDREN

19.1 Business application

The App is intended for adults acting for a business and is not directed to children.

A person accepting the Business Terms must be at least 18 years old.

19.2 Workshop Records concerning minors

A Business User may sometimes have a legitimate reason to record information relating to a customer under 18.

The Business User is responsible for:

determining whether that processing is lawful;
providing appropriate privacy information;
obtaining parental or guardian involvement where required;
applying additional safeguards; and
avoiding unnecessary collection.

Repair Workshop does not automatically receive those records.

19.3 Support contact from a minor

If we become aware that a child has directly provided unnecessary personal information to us, we will take reasonable steps to delete it where no lawful reason requires retention.

20. AUTOMATED DECISION-MAKING AND PROFILING

Repair Workshop does not use Provider Data to make solely automated decisions that produce legal or similarly significant effects concerning an individual.

Subscription entitlement checks are automated so that paid App functions can be enabled, renewed, restricted or restored according to Apple purchase information.

These entitlement checks do not analyse Workshop Records or create behavioural profiles.

21. COOKIES AND TRACKING

21.1 The App

The native App does not use browser cookies for advertising or cross-app tracking.

21.2 No advertising tracking

The current App configuration does not use:

IDFA for advertising;
advertising networks;
cross-app tracking;
remarketing tools; or
third-party behavioural analytics.

RevenueCat states that it does not inherently use purchase history to track users across different apps for advertising. (RevenueCat)

21.3 Website

This Policy primarily concerns the App and related support services.

If repairworkshop.net uses non-essential cookies, website analytics, advertising tools or additional contact forms, those activities must be described in an appropriate website privacy or cookie notice.

22. CHANGES TO THIS PRIVACY POLICY

22.1 Policy updates

We may update this Privacy Policy to reflect:

App changes;
new functionality;
changes to Apple or RevenueCat services;
changes to our providers;
security improvements;
legal developments; or
changes to how we handle Provider Data.

22.2 Material changes

Where a change materially affects how we use personal data, we will provide reasonable notice through:

the App;
our website;
an updated acceptance screen; or
another appropriate method.

22.3 Current version

The current version number and last-updated date will appear at the beginning of the Policy.

22.4 No retrospective consent

Updating this Policy does not retrospectively create consent for processing that required consent when it occurred.

23. CONTACT US

Questions, concerns and privacy-rights requests should be sent to:

Repair Workshop
Email: support@repairworkshop.net
Website: repairworkshop.net

For subscription enquiries, include the anonymous RevenueCat Subscription Support ID where available.

Do not send:

an Apple Account password;
authentication codes;
a device passcode;
a customer’s device passcode;
a complete payment-card number; or
a Manual Backup PIN.