Legal

Privacy Policy

Last updated: 10 August 2026

This policy covers Certifyd websites and services, including CodeWords for Personal Use and CodeWords for Business.

1. Who we are

Certifyd Ltd (Certifyd, we, us or our) is responsible for the personal data described in this policy. We are registered in England and Wales and our registered office is at Aldwych House, 71-91 Aldwych, London, England WC2B 4HN.

For privacy questions or requests, contact team@certifyd.io.

2. Data used by Certifyd CodeWords

Account data includes your name, email address, account status and the information needed to authenticate and support your account.

Device and security data includes registered public keys, operating system and app version, device capability and integrity signals, registration time, notification tokens, IP address and security events. Private device signing keys remain in platform-protected storage where the phone supports it and are not sent to Certifyd.

Trusted relationship data includes the accounts and registered devices in a relationship, display labels, creation and revocation events, and the assurance information produced during direct device setup.

Challenge data includes the request type, exact request text and any amount, recipient or detail that you choose to include, together with timestamps, expiry, status and signed responses. Do not add information that is not needed to check the action.

The app requests camera access to scan changing QR frames and nearby-device access to discover the matching Bluetooth service during setup. QR camera images are not retained. CodeWords does not need your address book, call audio, microphone recordings or precise location for this flow.

Biometric approval is handled by your phone's operating system. Certifyd receives the result needed to unlock a protected action, not your fingerprint or face template.

3. Website, support and business data

When you visit our website or contact us, we may process your IP address, browser and device information, pages viewed, cookie choices, messages and contact details. If an organisation runs a controlled CodeWords pilot, we may also process its name, administrator details, policy choices and support records.

4. Why we use data

We use personal data to create and protect accounts, register and revoke devices, establish trusted relationships, deliver exact-request challenges, show signed results, support recovery and deletion, prevent abuse, investigate security events and provide customer support.

We also use limited website and service data to operate, measure and improve Certifyd, communicate service changes and meet legal obligations. We do not sell personal data.

5. Legal bases

Under UK data protection law, we rely on contract where processing is needed to provide a service you request; legitimate interests to secure, support and improve the service; legal obligation where the law requires processing; and consent for optional marketing or similar uses. You may withdraw consent at any time, without affecting earlier lawful processing.

6. When data is shared

We share data with service providers that help us host, secure, monitor, notify and support the service, under appropriate contractual safeguards. A trusted relationship necessarily shares the challenge and response information with the participants in that relationship.

For a business account, an authorised organisation administrator may see account, device, policy and challenge audit information allowed by the organisation's service agreement and product controls. We may also disclose data when required by law, to protect people or the service, or as part of a business transfer subject to appropriate safeguards.

7. Retention and deletion

We keep account, device, relationship and challenge data only for as long as needed to provide and secure the service, resolve disputes and meet legal obligations. Retention can vary by data type and by an organisation's configured policy.

When account deletion completes, registered devices are revoked and trusted relationships end. Associated data is deleted or de-identified, except for limited records that must be retained for fraud prevention, dispute handling or legal obligations. We will explain any required retention when confirming a deletion request.

8. International transfers

If personal data is processed outside the United Kingdom, we use an approved transfer mechanism or another lawful safeguard, such as the UK International Data Transfer Agreement or the UK Addendum to standard contractual clauses, where required.

9. Your rights

Depending on the law that applies, you may ask for access, correction, deletion, restriction, portability or an objection to certain processing. You may also withdraw consent and complain to the UK Information Commissioner's Office.

Contact team@certifyd.io to make a request. We may need to verify that the request concerns your account. You can also start account deletion in CodeWords Settings or on our account deletion page.

10. Security and product limits

We use technical and organisational controls intended to protect data, including encrypted transport, access control, protected device keys where supported, signed challenge messages and security monitoring. No service can promise absolute security.

A valid CodeWords confirmation means a previously enrolled phone approved the displayed request. It does not prove a voice, email address, video image or legal identity; prevent coercion; or guarantee that the requested action is safe.

11. Children

CodeWords is not intended for a child to create and manage an account independently where parental consent is required by law. Family use must be supervised by a parent or guardian and must not replace emergency or safeguarding procedures.

12. Changes and contact

We may update this policy as the service, law or our suppliers change. We will post the revised date and give additional notice when a change materially affects your rights or how we use data.

Contact Certifyd Ltd at team@certifyd.io or Aldwych House, 71-91 Aldwych, London, England WC2B 4HN. You can find independent information and complaint routes at ico.org.uk.