Purple Door Privacy Notice

Ostrum Tech Limited, Crawley Innovation Centre, Fleming Way, Crawley, RH10 9QL, United Kingdom (Company number 13003511) (“we”, “our”, “us”), provides the Purple Door mobile application (“App”).

Capitalised terms used in this Privacy Notice have the meanings given in the Purple Door Terms & Conditions, unless otherwise defined in this Privacy Notice.

This Privacy Notice explains how your Personal Data is processed when you use the App. This Privacy Notice applies only to Personal Data processed by Ostrum Tech Limited. It does not apply to Personal Data processed by Assistance Providers.

Data Controller: under UK Data Protection Law, the Data Controller is the person or organisation that determines the purposes and means of processing Personal Data.

Personal Data: any information relating to an identified or identifiable individual, as defined under UK Data Protection Law.

Purple Profile: information that is relevant to assist you (e.g. disabilities, mobility impairments, wheelchair details, and other access needs) that you choose to store in the App. This does not include personal identifiers such as your name, email address, phone number, or profile picture. You may choose to share this information with others via a QR code (or directly on your phone’s screen). This information is used as default values when completing assistance booking details within the App and may be updated based on the most recent assistance booking you make through the App.

Special Category Data: Your Purple Profile and assistance booking may include health-related information about your assistance needs. Where this information is stored in the App, we do not use it for any purpose other than allowing you to view and share it (for example, via QR code). Where this information is shared with an Assistance Provider as part of an assistance booking, we process it only with your explicit consent, which is obtained through a clear confirmation step in the App each time you submit a booking.

UK Data Protection Law: the UK GDPR and Data Protection Act 2018.

1.    What Personal Data we collect

While using our App, we may require you to provide us with certain Personal Data, including but not limited to:

      Name;

      Email address;

      Mobile number;

      Profile picture;

      Assistance requirements (which may include disability type, mobility impairment and other access needs), including information you choose to store in your Purple Profile;

      Flight booking reference;

      Chat messages;

      Feedback on App, Airport Information or Assistance Services; and

      Real-time location data (based on the location services available on your device, such as GPS, WiFi etc.)

Real-time location data is collected only while you are on or around the relevant airport in connection with an active assistance booking shown on the App, or where you have explicitly agreed to share your location in response to a request from the Assistance Provider via chat. In these cases, we will notify you on the App home page that location data is being collected, and you can switch it off at any time.

2.    How your Personal Data is collected

We use different methods to collect Personal Data from and about you including through:

      Your interactions with the App: this includes Personal Data you provide through the App when you create a profile or account, submit or update an assistance booking, share real-time location data, communicate via chat or provide feedback.

      Automated technologies: as you interact with our App, we may automatically collect technical data about your device, usage, logs and interactions. We collect this Personal Data using cookies, server logs and similar technologies.

      Google and Apple: we use data provided by Google and Apple to operate the App on your device and to send you notifications through the App.

3.    Our legal basis for processing

The law requires us to have a legal basis for collecting and using your Personal Data. We rely on one or more of the following legal bases:

      Consent: where we rely on your consent, including explicit consent for processing Special Category Data and sharing it with Assistance Providers. You can withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.

      Contract: performance of the contract between you and us, where we need to provide the App and its functionality to you.

      Legal obligation: where we need to process or share Personal Data to comply with a legal requirement.

      Legitimate interests: to maintain and secure the App, prevent misuse, troubleshoot issues, understand performance and improve the App. We balance these interests against your rights and you can object.

4.    How we use your Personal Data and how long we keep it

We only use your Personal Data for the purposes described below. We retain it only for as long as necessary to fulfil those purposes, comply with legal obligations, resolve disputes, maintain system security and prevent misuse of the App, subject to your rights under Section 13. After the applicable retention period set out below, your Personal Data will be securely deleted or anonymised, subject to legal, security and misuse-prevention requirements.

Purpose

Data We Use

Legal Basis

Retention Period

Register you and create your account.

Name, email, mobile number, profile picture.

Contract

Until you delete your account, subject to limited retention required for legal, security or misuse-prevention purposes.

Create or update assistance booking requests and transfer it to the relevant Assistance Provider.

Name, profile picture, flight details, assistance requirements (Special Category Data).

Contract; Consent (for Special Category Data).

Retained until 3 years from the scheduled date of the flight.

Facilitate communication between you and the Assistance Provider.

Name, profile picture, chat messages.

Contract

Retained until 90 days from the date that the chat message was sent.

Provide your feedback to Assistance Providers on Assistance Services or Airport Information published on App. Provide your feedback about the App to us.

Name, profile picture, assistance booking details (if relevant), feedback.

Contract; Legitimate interests

Retained for 3 years from the creation date.

Verifying that you are physically at the airport and for facilitating the meeting between you and the Assistance Agent.

Real-time location data using location services available on your device (e.g. GPS)

Contract; Consent (for location sharing via chat)

Only the last known location on or around the airport is stored. Where this is collected in connection with an assistance booking, it will be deleted within 7 days after the scheduled flight date. Where this is collected following a location-sharing request via chat, it will be deleted within 7 days after the location is shared.

Improve and secure the App (including troubleshooting and analytics).

Technical data, log data.

Legitimate interests; Legal obligation.

Up to 24 months for security and analytics purposes.

5.    Disclosures of your Personal Data

We share your Personal Data with the relevant Assistance Provider where necessary to enable them to deliver Assistance Services to you, including when you submit an assistance booking or otherwise interact with them through the App.

Ostrum Tech Limited acts as a Data Controller in respect of the Personal Data it processes in providing and operating the App. Assistance Providers act as independent Data Controllers in respect of the Personal Data they receive or collect in connection with the Assistance Services.

Once your Personal Data has been shared with an Assistance Provider, that provider is responsible for its own processing of that data in accordance with its own privacy notice. This includes any Personal Data collected directly from you during your interactions with them.

We do not control the processing of Personal Data by Assistance Providers. You should review the relevant Assistance Provider’s privacy notice for further information about how your Personal Data is handled.

Details of the Assistance Provider for a specific airport are available in the “Assistance Provider and Data Protection” section on the relevant Airport Information page in the App.

The App acts solely as a digital communication channel between you and the relevant Assistance Provider, and does not control or provide the Assistance Services.

6.    International Data Transfers

If we need to transfer your Personal Data outside the UK, we use appropriate legal safeguards to keep your data protected, including:

      Standard Contractual Clauses (SCCs): These are official legal terms approved by regulators that require the recipient of your Personal Data to protect it to the same high standards as in the UK.

      UK Transfer Addendum: This is an additional document that works with the SCCs to ensure transfers from the UK comply with UK Data Protection Law.

      Adequacy Regulations: transfers to countries that have been deemed by the UK Government to provide an adequate level of protection for Personal Data.

7.    Log and technical data

We want to inform you that whenever you use our App, in case of an error in the App, we collect data and information (through third-party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the App when utilizing our App, the time and date of your use of the App, and other statistics.

8.    Cookies, local storage and similar technologies

This App uses cookies and local storage to store small amounts of information on your device, such as user and session details. These are used to help the App work properly and provide a smooth user experience. You can delete this data by clearing the App’s cache on your device. If you do so, some parts of the App may not work properly.

9.    Third-party service providers

We use trusted third-party providers (acting as data processors) to help us operate, maintain, and improve the App. These providers support us in areas such as cloud hosting, security, analytics, and technical support.

For example, they may assist us to:

      Publish and distribute the App via the Apple App Store and Google Play Store;

      Host the App and provide the underlying infrastructure and managed security controls;

      Provide technical support, maintenance, monitoring, log analysis, and cybersecurity services;

      Carry out operational activities on our behalf; and

      Analyse how the App is used so we can improve performance and user experience.

These third parties process your Personal Data only on our behalf and in accordance with our instructions. We do not permit them to use your Personal Data for their own purposes.

We require all third-party providers to respect the security of your Personal Data and to handle it in accordance with applicable data protection laws.

10.    Security

We value your trust in providing us your Personal Data, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11.    Children’s Privacy

The App is intended for users aged 18 and over. A minor may use the App only under the supervision of a parent or guardian, and the parent or guardian is responsible for the minor’s use of the App and for providing any required consent on their behalf. We do not knowingly collect Personal Data from children without appropriate parental or guardian involvement. If you are a parent or guardian and believe that a child has provided us with Personal Data without your consent or supervision, please contact us so that we can take appropriate action.

12.    Open source licences

This App uses open source licenses. The list of such licenses can be provided on request. Please contact us using the email ID provided under the contact details.

13.    Your rights under Data Protection Law

You have the following rights regarding your Personal Data:

      Access: Obtain a copy of your Personal Data we hold.

      Rectification: Correct inaccurate or incomplete data.

      Erasure: Request deletion of your Personal Data where legally permissible. We may retain limited information where necessary for legitimate purposes, such as preventing misuse of the App, maintaining system security, complying with legal obligations, or resolving disputes.

      Restriction: Limit processing under certain circumstances.

      Portability: Request the transfer of your data to you or to a third party.

      Objection: Object to processing based on legitimate interests.

14.    Complaints

If you have any concerns about how we handle your Personal Data, please contact us using the details shown in section 16. You have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):

      Website: https://ico.org.uk

      Phone: +44 (0) 303 123 1113

15.    Changes to this Privacy Notice

We may update our Privacy Notice from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Notice on this page.

This notice is effective as of 1 May 2026.

16.    Contact us

You may exercise your rights under UK Data Protection Law with respect to Personal Data we control by contacting us via the “Contact Us” link on our website at www.ostrumtech.com, or Purple Door app, Ostrum Tech Limited, Crawley Innovation Centre, Fleming Way, Crawley, RH10 9QL, United Kingdom.

For Personal Data held by an Assistance Provider, please contact them directly.

 

Copyright © 2026 Ostrum Tech Limited.