Central Privacy Policy

This policy describes how Central collects, uses and protects users' personal data, in accordance with Regulation (EU) 2016/679 ("GDPR").

1. Data controller

Mattia Granito
Via XI Febbraio 15, Parabiago (MI)
Email: legal@getcentral.net

2. What data we collect and why

3. Who we share data with

Some external providers process data on our behalf, as data processors:

For providers outside the EU, transfers take place on the basis of the European Commission's Standard Contractual Clauses and/or participation in the EU-US Data Privacy Framework, where applicable. We do not sell or transfer personal data to third parties for marketing purposes.

Note on Mapbox and map usage telemetry: in addition to providing the map display service on our behalf, Mapbox independently collects — for its own service improvement purposes, as an independent controller for this specific data — anonymised location and usage information generated by interaction with the maps. You can specifically turn off this collection by tapping the information icon (ⓘ) shown on map screens, which opens Mapbox's telemetry settings. For more details on this independent processing, see Mapbox's privacy policy.

3.1 Voice communications (WebRTC) and TURN/STUN servers

To enable real-time audio communication sessions (WebRTC technology) to be established, properly maintained and optimised, Central uses the TURN/STUN server network and infrastructure service provided by Metered (Metered.ca).

• Purpose and limitation of IP address processing: the processing of the user's IP address is strictly limited to the technical and security purposes essential for the proper functioning of the system. The IP address is processed solely to determine the optimal network path for data transmission and to ensure the stability and cybersecurity of the infrastructure.
• Nature of the processing and technical necessity: this processing is an essential technical requirement for providing the service requested by the user. Without the temporary processing of the IP address, establishing a direct or relayed connection between users' devices would be technically impossible. The data is not used for commercial profiling, tracking or marketing purposes.
• Performance optimisation and local routing: the service uses dynamic routing technology based on geographic proximity ("geo-routing"), which automatically directs voice traffic to the available server closest to the user. For users located in the European Union, communication flows are consequently routed and handled mainly through nodes and infrastructure located in Europe, reducing network latency.
• Security and confidentiality measures: although the service uses local routing servers to maximise technical performance, signalling data or system logs strictly necessary for diagnostics and abuse prevention may be processed on the provider's global infrastructure. The actual audio streams travel encrypted (DTLS-SRTP, native to the WebRTC protocol) and are never recorded, listened to or stored on the routing servers.

4. How long we keep data

• Account and messages: for the entire life of the account, until deleted by the user.
• Safety perimeter location data (Geofence): automatically deleted after 3 days.
• Trip location data ("Safe Trip"): automatically deleted 24 hours after the trip ends.
• Consent log: kept even after the account is deleted, for a maximum of 5 years, as proof that the policy was accepted in case of legal need.

5. How we protect data

Messages, calls and shared boards are protected by end-to-end encryption (X25519 + AES-256-GCM): the content cannot be read by the data controller or by infrastructure providers. Passwords are stored using bcrypt hashing and never in plain text. You can remotely revoke the access of a lost or stolen device from the "Devices" section of the app.

6. Your rights

You can exercise the rights provided for by Articles 15-22 of the GDPR at any time. Three of them don't require writing to anyone and involve no waiting time, because they are available directly in the app and the web dashboard:

For any request you can in any case write to legal@getcentral.net: we reply within one month, as required by Art. 12.3. You also always have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it).

7. Exporting your data

You can download, by yourself, a complete copy of the data linked to your account: profile, consent records, conversations, shared boards, gallery, communities, SOS contacts, links with your guardians, safety perimeters, check-ins, trips, linked devices and call log. The file is in JSON format, structured and machine-readable, as required by Art. 20.

Two channels, one copy

• From the app (Profile → My data): in addition to the JSON file, you receive a readable transcript of your conversations. This is the recommended channel, because the encryption key is already on your phone and the content is opened automatically.
• From the web dashboard (“Privacy and data” tab): useful if you no longer have your phone. To get your messages in plain text you must enter the recovery passphrase you chose in the app; without it, the file arrives complete but with the content still encrypted.

In both cases you are asked for your account password: a file containing all your data together must not be downloadable by anyone who happens upon a session left open.

The limit imposed by encryption

The content of conversations is end-to-end encrypted and the controller does not hold the keys: it therefore cannot hand it over in plain text. This is not a limitation of the export but a direct consequence of the protection applied to your messages. Decryption takes place on your device, before the file is saved. In the exported file, the original encrypted content remains alongside the plain text, so you can verify it independently with your key.

If you have lost both your phone and your recovery passphrase, the exported messages can no longer be opened by anyone, the controller included. This is the price of end-to-end encryption, and it is why the app insists that the passphrase be set and kept safe.

Group conversations and other people's data

Exported conversations also contain messages written by other participants, together with their name and public key: this is the same content the app already shows you on your phone, and without it an exported conversation would be incomprehensible. The file is provided to you for personal use: if you decide to share it or to process it for other purposes, you become the controller of that processing and are accountable for it under the GDPR. Data concerning other people's choices rather than yours is not included — for example, the list of anyone who may have blocked you.

For technical reasons, very long conversations may be truncated to the most recent messages: when this happens, the file states it explicitly.

8. Minors

Central is not intended for people under 14 years of age: this is the age of digital consent set by Italian law (Legislative Decree 101/2018, Art. 2-quinquies), which the GDPR allows each Member State to set between 13 and 16. During registration, an explicit declaration that you are at least 14 years old is required.

We do not ask for your date of birth: it would be one more piece of personal data to store without offering any greater guarantee than the declaration, and the data minimisation principle (Art. 5.1.c) requires us to collect only what is truly needed. If we become aware of an account created by a person below the minimum age, we will delete it.

If you register from another European Union country, the age of digital consent may be higher (16 in Germany and Ireland, 15 in France): in that case, authorisation from the holder of parental responsibility is required.

No advertising identifier

Central does not collect the device's advertising identifier (Advertising ID), does not share it with third parties, contains no advertising and does not carry out profiling for marketing purposes. The push notification service processes only the token needed to deliver notifications.

9. Changes to this policy

In the event of substantial changes, the new version will be made available at this same address with an updated version number, and a new explicit acceptance may be requested at the next login.

This policy has been prepared as a basis for GDPR compliance and does not constitute professional legal advice. Review by a professional is recommended before final publication.