Privacy Policy — Opalite

Effective Date: August 11, 2025

Contact: contact@opalitenational.com

This Privacy Policy explains how Opalite (“we”, “us”, “our”) processes personal data of users of the Opalite mobile application for insurance inspectors on iOS and Android (the “App”).

1) Who We Are

Data Controller: Opalite, Email: contact@opalitenational.com.

2) Data We Collect

• Account data: name, corporate email/Apple ID for granting access (including via TestFlight).
• Device identifiers and diagnostics: device ID, crash logs, performance data, OS/app version.
• Usage data: in-app events, session duration, preferences.
• Location data (with consent): GPS coordinates to record inspection site locations.
• Camera/Photos (with consent): images/videos of insured objects, documents, damage.
• Microphone (with consent): voice notes for reports.
• Files/Documents (with consent): attachments for inspection reports.

We do not collect sensitive categories of personal data unless required for the work process and explicitly consented to.

3) Sources of Data

• Data you provide directly in the App.
• Data automatically generated during your use of the App (analytics, logs).
• Data provided by the insurance company (if you work within their project).

4) Purpose of Processing

• Provide access to the App and its features.
• Create and manage inspection reports, capture GPS coordinates of inspections.
• Ensure quality, support, and security (error detection, access audit).
• Fulfill contractual obligations with the insurer and comply with legal requirements.
• Improve the product (aggregated/anonymized analytics).

5) Legal Bases

• Performance of a contract (providing the service/access).
• Legitimate interests (security, prevention of abuse, service improvement).
• Consent (camera, photos/videos, microphone, location — where required).
• Legal obligations (for record-keeping/compliance where applicable).

6) Third-Party Access and Data Sharing

We may engage data processors for:

• Cloud infrastructure/storage (e.g., data center providers).
• Analytics and diagnostics (e.g., crash reporting services).
• Authentication/email services (for access and notifications).

All processors act under data processing agreements and do not use data for their own purposes. A list of key processors is available upon request: contact@opalitenational.com. Data transfers outside the EEA (if applicable) are made with appropriate safeguards (e.g., standard contractual clauses).

7) Data Retention

Data is retained only for as long as necessary to fulfill the purposes described above, or for the period required by contract with the insurer or by law. After retention periods expire, data will be deleted or anonymized.

8) Security

We apply technical and organizational security measures, including encryption in transit, access controls, audit logs, and access minimization for staff.

9) Your Rights

Depending on your jurisdiction, you may have the right to request access, correction, deletion, restriction of processing, object to processing, and data portability. Requests can be sent to contact@opalitenational.com. We may request proof of identity.

10) Children

The App is not intended for individuals under 16 years old and does not knowingly collect data from children.

11) Permissions Required by the App

Before using Camera, Photos, Microphone, or Location features, the App will request system permission. Denying permission may limit certain features (e.g., adding inspection photos or GPS location).

12) Tracking and Advertising

The App does not use data for targeted advertising. If tracking features subject to App Tracking Transparency (ATT) are introduced in the future, we will request your consent via the iOS system prompt.

13) International Data Transfers

If data is transferred outside your country, we will ensure an adequate level of protection in accordance with applicable law.

14) Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be available at this link. The effective date is listed at the top.

15) Contact Information

Privacy inquiries: contact@opalitenational.com

You also have the right to lodge a complaint with your data protection authority (where applicable).