1code Privacy Policy
Last updated: 10 November 2026 · Version 3
If you accepted an earlier version, this version applies to you from 10 December 2026. This policy explains what personal information 1code collects when you use 1code Studio and its apps, why we collect it, who helps us handle it, where it goes, how long we keep it and what you can do about it. 1CODE X LTD, a company in the United Kingdom, is responsible for your information wherever you live. You sign in with 1code ID, not a password. Your content is yours: we keep it to give you the service, and we do not sell it, advertise with it or use it to train AI. If you connect your own AI agent, it can do only what you allow, sensitive actions wait for your approval on your phone, and you can read everything it did for a year. The first part of this policy applies to everyone. The country sections after it add only what is different or extra where you live.
Who we are
This policy lives at 1code.uk/privacy. It covers 1code Studio (1code.studio), 1code ID, 1code Mail and the 1code phone app. The part for everyone applies to you wherever you live, and the section for your country adds what is different there.
1CODE X LTD is a company registered in England and Wales, company number 12828341, at 2 Centurion Way, Credenhill, Hereford HR4 7FF, United Kingdom. It operates 1code ID and 1code Mail for everyone, runs 1code Studio, and publishes the 1code phone app on Google Play. It decides what personal information is collected and why. That makes it the controller of your information, wherever you live.
You contract with 1CODE X LTD for 1code, wherever you live. Selling on 1code Store has its own terms and its own privacy policy, which you accept when you set up your store. They say who you contract with and pay for selling, and who is responsible for what you give Store to sell: your identity checks, payout account, Store subscription and payouts.
In this policy, "1code", "we" and "us" mean 1CODE X LTD. "You" means the person using 1code.
This policy applies to all of 1code: Docs, Sheets, Slides, Pdf, Drive, Mail, Channels, Rooms, Calendar, Project, Store, Books, 1code ID and the 1code phone app. It also covers the 1code connector and the developer API.
When you are in charge of the information
Sometimes you, not we, decide what happens to other people's information. Then you are the controller and we handle that information for you, only on your instructions. Our Terms of Service contain the data processing agreement for this, under Article 28 of the GDPR and the UK GDPR.
This applies to:
- Company mailboxes. Addresses like name@company.1code.email belong to the company. The company can see and close them.
- Your audience in Rooms. The people who sign up for, join or pay for your presentations, meetings and rooms, and the people who watch what you share.
- Your shoppers in Store. The people who buy from your online store, sign up for your events or fill in forms on your website.
- Your clients in Books. The people and businesses you send invoices to.
- Your workspace. The people you invite and the content they add, where you run the workspace for your organisation.
If you are in someone else's audience, mailbox, store or client list and have a question about your information, ask them first. If they do not answer, write to us and we will help.
What we collect
We collect only what each app needs to work. Here it is, app by app.
Your 1code account and 1code ID
You sign in to every 1code app with 1code ID. There is no password. In the 1code phone app, you sign in with your phone and your fingerprint or face. The app does not create accounts. To set it up, you can enter your username and the email address your account is registered under, and then the code we email to that address. On the web, you may get a one-time code by email, or a request to approve the sign-in on your phone.
- Account: your name, and your 1code address (such as name@company.1code.email), which is also your username. The name of your company, or "Just me" (the company then takes your name), or, if you were invited, the company you join. An email address, which you confirm with a code when you create your account. The country you are based in: when you create your account on the web, the sign-up page suggests one from your browser's language settings, or from where your connection appears to come from, and you confirm or change it. It decides which country section of our policies applies to you. The app shows it but does not change it. Your language and time zone: the phone app sends your phone's settings each time you save your profile in the app. You can change them on your account page on the web. Your name appears on invitations you send.
- Your profile, if you fill it in: your surname, a postal address and a company name. Only you see them, in the app and on your account page.
- Checks on new names: every new username and company name, and every address a company asks 1code Mail to create, is checked by an AI model for names that try to pass as 1code, a bank or a system mailbox. The model sees only the name. If it flags one, a person on our team decides whether to clear it, suspend the account or close it.
- Your phone: the public half of the key your phone creates, the certificate we issue for it (serial number and dates), the type of phone, and what protects the key. The app also sends the name, model and system version your phone reports (for example "Galaxy A24 · SM-A245F · Android 14"), and we use them as the phone's name. You see it in your list of phones. A company's owners may see it when you change that company's people, leave it, or delete your account while you are its admin or owner (see "Your company's people" below). The private key never leaves your phone.
- Sign-in approvals: which app or website asked, when, which of your phones approved it (or that it came from a sign-in with an email code), the identifier we released for you, and what you agreed to share. We also record which phone approved each AI agent you connect, which phone answered each request from an AI agent, and which phone approved each admin you invite to a company. When you remove a phone, every sign-in and AI connection it approved ends at once.
- Connections: the people you are connected with. You send a request to someone's username, and they accept or decline it. They see your username and email address as soon as you send it. Once they accept, you each see the other's. You choose your key holders from your connections.
- Recovery: the people you choose as key holders, the invitations you send, and any recovery requests with who confirmed them and when. We give you and each of your key holders the other's username and email address. When a recovery of your account starts, we warn every phone on your account, and we email the address your account shows (the email address you confirmed, or your 1code Mail inbox) with a link that can only stop the recovery. We keep only a one-way fingerprint of that link. If you refuse a recovery on your phone, we keep the reason you type there, or the one the app suggests, with the request.
- When you use the app: when you last used it, and when you last answered the weekly check-in. We use this to keep your account reachable for recovery. If you are someone's key holder, their app shows only whether you last used the app in the last 7 days, 7 to 30 days ago, or 30 days ago or more. You are told this when you become one.
- Security and activity records: the time, device and action for sign-ins and important changes, such as adding or removing a phone, choosing a key holder or starting a recovery. Some changes need a fresh fingerprint on one of your phones, such as removing a phone, choosing or removing a key holder, adding an email address, or making someone a company admin or owner or removing one. For these we keep which change it was and a one-time number, so the approval can never be used twice. When a browser asks to remove a phone, we keep the request, how that browser was signed in, and which phone said yes or no. We also keep when your account first used a phone, and whether each phone has used its key yet, to decide when a phone may be added as your account's first phone.
- Where a sign-in comes from: each time a browser shows a code to sign in, to your account page or to an app, we record the country, city and network (internet provider) its connection appears to come from, the kind of browser (such as "Chrome, Mac"), a scrambled form of part of its network address, and the random number in that browser's short sign-in cookie. This happens before anyone signs in. We use them to spot a sign-in code passed on from somewhere else, and to limit how many codes one browser or network can ask for. When your phone approves, we compare them with where your phone's connection appears to be at that moment. We do not keep your phone's. Your phone receives the browser's kind, city and country, and the app shows the kind of browser once you are signed in. When a browser asks to remove a phone, we record its country, city and kind of browser, and show them on your phone.
- Places: the places (a country with a city and a network) where you confirmed a sign-in, by saying it was you or by matching its number. A browser in one of these places is not asked for the number. A place stops counting, and leaves your list, 90 days after you last confirmed it. You can see and remove the places that still count in the app. Saying a sign-in was not you removes its place.
- Identity checks: the app photographs your identity document, and you holding it, only when a business registered with 1code ID asks you through 1code ID to prove who you are. Today the only business registered to ask is our own store service, 1code Store, when you set up selling. The app first shows the name and web address the business is registered under, and sends the photos straight to it. 1code ID keeps no copy on its servers. The app deletes its own copy once the photos are sent, or the next time it opens. Store keeps the photos as "Store and free sites" below says.
- Your company's people: if you are in a company, your role in it, and its history. The history records every person added or invited, every change of role, everyone who is removed, leaves, or closes their account and so leaves, and everyone in it when the company is closed: who did it, to whom, the roles before and after, when, and how it was done, such as "their phone “Galaxy A24 · SM-A245F · Android 14”", "a browser signed in by their phone", "an email-code sign-in", "1code Mail" or "1code". Only the company's owners can read it. Every owner also gets a phone notification and an email when someone is added or invited, when anyone's role changes, and when an admin or an owner is removed, leaves or closes their account. Anyone removed or lowered by someone else is told too, by phone notification and email. If 1code support closes an admin's or an owner's account, the owners are told that.
- Apps you register as a developer: if you register an app to sign people in with 1code ID, its name, its web addresses, and that it is yours.
We never receive your fingerprint, or the face your phone checks when you unlock it. See "The 1code phone app" below.
Docs, Sheets, Slides, Pdf, Drive and Project
- Your content: documents, sheets, decks, PDFs, videos, recordings, pictures, notes, boards and Kanbans, with their titles, folders, comments, checklists, due dates and earlier versions.
- Sharing: who you share with and what they may do.
- Storage use: how much room your files take.
- Workspaces: your workspaces, their members and their roles, and your settings.
- Account: your 1code ID identifier, your name and your addresses.
- Your mail: messages you send and receive, attachments, drafts, scheduled and snoozed mail, labels, filters, signatures and templates.
- Searches: what you type to search your mail. We use it to find your messages and do not keep it with your mail. It appears in our service's technical logs, which are kept for 7 days.
- Address suggestions taken from your own mail, and your settings (time zone, language, region).
- Sender checks: the results of SPF, DKIM and DMARC checks on incoming mail, spam reports and the senders you block.
- A sending record for each message: when it was sent, from which address, how many recipients were inside and outside 1code, and whether it was delivered. For mail sent outside 1code, also the sender's 1code ID identifier. We do not keep recipient addresses in this record. We use it to stop abuse and to apply the sending limits in our Acceptable Use Policy.
- Contacts: the name and address of people who write to an address in a workspace, when the sender checks show the mail really came from them, and addresses members add by hand. Addresses on 1code.email write only inside 1code. Addresses on your own domain can write outside 1code only to these Contacts, or reply to an email someone sent them.
- Vacation replies: which senders got your automatic reply, so each gets it only once in a while.
- Companies: the company's name and subdomain, its people and roles, invitations (including the personal email an invitation is sent to), aliases, groups, shared-mailbox access and a log of admin actions.
- Keys for mail apps and AI agents: stored only as one-way fingerprints that cannot be turned back into the key.
- Imports: if you bring old mail across, read-only access to your Google or Microsoft account, stored encrypted and deleted when the import ends, or a mail file you upload, also deleted when the import ends.
- DMARC reports that other mail providers send us about mail using our domains. They include the addresses of sending servers.
Channels
- Your messages, replies and reactions, the files you share, the channels you belong to and who else is in them, and which messages have been read.
- What you type to search channels and their posts. We use it to find the results.
Rooms
- Sessions: the rooms you open, the names people type to join, when they joined and left, the chat and questions in the session, and a recording when the host records.
- Your audience: sign-ups (name, email and the answers to questions you set), which session they signed up for, and unsubscribes.
- Paid rooms: who paid, for what and when, and whether the payment went through. Card details go straight to our payment provider. We never see full card numbers.
- Viewing numbers: when someone watches a video you share, we count the view without storing anything on their device. We record the page it was watched on, which parts were played, and the country their connection appears to come from. No name or account is attached.
- Camera, microphone and screen: used only while you are in a meeting with them on, or while you record after pressing record. Everyone in a session is shown when it is being recorded. Live sound and video pass through our provider's real-time network. When a session is not recorded, any short pieces of it that passed through our storage are deleted within a day. When a presenter shows a web page to the room, the page passes through our servers and we keep nothing of it.
Calendar
- Your calendars and events (titles, times, places, notes, repeats and reminders), your settings, and the dates other 1code apps put there for you, such as due dates and scheduled rooms.
- Calendars you add by web address. We fetch them every few hours and show them to you.
- If you turn on a calendar's subscribe link, anyone with that link can see that calendar's events. Replace the link to stop the old one.
Store and free sites
- Your business: your name, email, phone number and business details.
- Identity checks before you can sell: you must pass identity checks (KYC) and add a payout account before you can sell. We ask for an identity document, a company registration certificate where you trade as a company, a bank letter and proof of address. When we ask for it through 1code ID, you can also photograph your identity document, and yourself holding it, in the 1code phone app. These are kept in private storage. Only you and our compliance staff can see them. 1code Store's payment provider, Paystack, never receives them or a link to them. To check your bank account and pay you, it receives only the account number, the bank code, the account holder's or company's name, the company registration number where you trade as a company, and your store's name.
- How identity documents are checked: you type in the details from your documents (your name, ID number, company and bank details). Fixed rules then check those details against each other. A person on our team checks your documents by eye and approves every application, so no decision about selling is made by a computer alone. No AI reads your documents.
- Your shoppers' orders: name, email, delivery address and what they ordered. You are in charge of this information (see above).
- Your event attendees: name, email, the tickets they take and, if they give it, a mobile number, so you can send them messages about the event by email or SMS. You are in charge of this information (see above).
- Free sites at
<name>.1code.host: what you publish. Anyone can see a published site. We count visits from Cloudflare's own server records, without scripts or cookies in your visitors' browsers. If your site collects information from visitors, such as through a form, you are in charge of that information.
Books
- The invoices you create: your clients' names, contact details, billing addresses and tax numbers, what you sold, the amounts and whether they are paid. You are in charge of your clients' information (see above).
Domains
- If you buy a domain for your store in 1code Store, Store passes your name and contact details to the registrar (domains.co.za) and the registry for that domain. Some of it may be published in public domain records where the registry's rules require it.
Billing
- Your plan, your invoices, your billing name and address, and whether each payment went through. Paid 1code plans are not on sale yet; when they are, card details will go straight to Stripe. A 1code Store subscription, or a domain bought for your store, is billed by 1code Store under its own terms, and card details go straight to Paystack. We never see full card numbers.
When you contact us, give feedback or accept a policy
- Contact form: your name, email, company if you give one, your message, and the country your connection appears to come from.
- Feedback: what you post, the name shown with it, and your votes.
- Acceptance records: which version of each policy you accepted, the country you gave, and when. In 1code ID, also the network (IP) address and the browser or app you accepted from. In Store, also the network (IP) address.
Security records and connection data
- Records of sign-ins, failed attempts and changes to your account.
- Where a sign-in appears to come from: the country, city and network, the kind of browser, and a scrambled form of part of the network address, recorded each time a browser asks for a sign-in code, even before anyone signs in. For a request to remove a phone, only the country, city and kind of browser. We keep them with the record of the sign-in or request. Where your phone's connection appears to be is compared at that moment and not kept.
- To limit repeated attempts: a scrambled form of part of the network address that asks for an email code or checks names at sign-up, and the full network address of a phone that enters a code to add itself to an account. "How long we keep it" says for how long.
- Our hosting provider sees connection details (IP address, browser, time) as it delivers and protects the service, and keeps them only briefly.
- Our service writes technical logs as it runs, such as part of an account's identifier, a company's name and what happened. In Mail they also hold the web address of each request, which can name the mailbox, the folder or label, your time zone and the words of a search. Our hosting provider keeps them for us for 7 days.
- Until you give your country, we use the country your connection appears to come from to choose which country section and prices to show. We do not store it, except where this policy says so.
Cookies and your browser
We set only what 1code needs to work:
- a sign-in cookie, for up to 30 days unless you sign out;
- a short cookie while you sign in, for up to 10 minutes;
- a cookie that holds the access a shared link gives you, for up to 12 hours;
- a marker that tells a page you are signed in;
- your theme, language and similar choices, kept in your browser.
These do not track you across other websites and are not shared with anyone. We have no advertising or analytics cookies and no tracking scripts from other companies. We count views of shared videos without storing anything on your device. The Cookie Policy (1code.uk/cookies) lists every cookie we use and everything our apps keep in your browser.
Where we get it from
Most of it comes from you. We also get information:
- from other people on 1code, when they share something with you, invite you, add you to a company, change your role in it or remove you, send you a connection request, or choose you as a key holder;
- from people who write to you, when their mail or messages reach your 1code address;
- from services and AI agents you connect, such as Google, Microsoft or Slack;
- from Paystack, for 1code Store: whether a payment or payout went through, and whether its checks on a seller are complete. Once paid 1code plans are on sale, also from Stripe: whether a payment went through;
- from domain registrars and registries, about domains you buy through us;
- from other mail providers: sender checks, bounce notices and DMARC reports;
- from your phone and browser, as you use 1code (see "Security records and connection data" and "Cookies and your browser").
Do you have to give it to us?
You choose what you give us. Some things are needed for a service to work:
- An account needs your name, your 1code address, your company's name (or "Just me", or the company that invited you), the country you are based in, and an email address you confirm with a code. Without them we cannot give you an account. To use the 1code phone app, you also need a phone with a fingerprint, or a face unlock that the phone rates as strong.
- Paying for a plan or a domain needs billing details. Without them you cannot buy.
- Selling needs identity checks and a payout account. Without them you cannot sell.
- A domain needs true contact details, because the registry requires them.
Everything else, such as your surname, a postal address or a connected service, is up to you. Leaving it out only means the feature that needs it will not work.
Why we use it
Some laws ask us to name a legal reason (a "lawful basis") for each use. These are ours.
| What we do | Our reason |
|---|---|
| Run your account, sign you in, keep and deliver your content, mail, rooms, calendar, store and invoices | To carry out our agreement with you |
| Bill you and take payment | To carry out our agreement with you |
| Register domains you buy through us, and pass your details to the registrar and registry | To carry out our agreement with you; the registry's rules |
| Send phone notifications, unless you turn them off, and security notices by email and to your phones, such as a recovery starting, a request to remove a phone, or a change to your company's people | To carry out our agreement with you |
| Keep tax and accounting records | The law requires it |
| Identity checks before you sell, and payout details | To carry out our agreement with you, and our legitimate interest in preventing fraud and money laundering and meeting our payment providers' requirements (they have their own legal duties to check sellers). A legal duty only where a law applies to us directly. |
| Security records, where sign-ins come from, the places you confirmed, which phone approved each sign-in, checking new names, spam and malware checks, sending limits, scanning free sites, stopping abuse | Our legitimate interest, and yours, in keeping 1code safe |
| Keep the activity log of connected AI agents and apps | To carry out our agreement with you, and our legitimate interest, and yours, in being able to check what was done in your name |
| Keep a company's history of its people, and tell its owners about changes | Our legitimate interest, and the company's, in keeping its accounts safe and knowing who changed what |
| Show the person you hold a key for how recently you used the app | Our legitimate interest, and theirs, in a recovery that works |
| Deliver phone notifications through Google Firebase Cloud Messaging, once notifications are allowed on your phone | Our legitimate interest in an app that works. You can turn notifications off at any time |
| Viewing numbers for your videos | Your legitimate interest in knowing how your videos are watched, and ours in running the service |
| Answer the contact form and read feedback | Our legitimate interest in answering you and improving 1code; steps you ask for before an agreement |
| Optional profile details (surname, postal address, company), connected services and connected AI agents | Your choice, which you can withdraw at any time |
| Record which policy version you accepted | Our legitimate interest in showing what was agreed |
| Information about other people you put in your audience, mailboxes, store or invoices | Your instructions; you choose the reason |
| Disclose information to authorities | Only where the law requires it |
Where we rely on legitimate interests, we weigh them against your rights, and you can object (see "Your right to object" below). Where we rely on your choice (consent), you can withdraw it at any time. That does not undo what we did before you withdrew it.
What we do not do
- We do not sell or rent personal information.
- We do not show ads or use your information for advertising.
- We do not use your content to train AI, and we do not let our providers train on it.
- We do not add tracking scripts from other companies. The 1code phone app reads codes with an open-source part that works entirely on your phone and sends nothing anywhere. It uses Google Firebase Cloud Messaging only to deliver notifications, and only once notifications are allowed on your phone (see "The 1code phone app").
- We do not make decisions about you by computer alone that have legal or similarly serious effects. Automated checks may block a single message, file or page that matches known malware, phishing or child sexual abuse material. A person reviews every pause or removal, and you can always ask a person to look again.
- We do not send marketing or bulk email, and we do not let anyone send it through 1code. Emails to a Rooms audience are limited to confirmations, links and reminders, and 1code Studio has no way to connect an email-marketing service.
- People at 1code do not read your content, unless you ask us to (for support), we must look into abuse or a security problem, or the law requires it. Automated systems check mail for spam, fake senders and malware.
AI agents you connect, and the activity log
You can connect your own AI agent, such as Claude, ChatGPT or Gemini, to 1code. You do this through the 1code connector (MCP) or our developer API, using your own subscription or your own keys.
- Your AI account stays yours. We never ask for, store or pass on the sign-in details of your AI account.
- You choose what it can do. Nothing is connected until you connect it. You choose its access, for example read, draft or send. You can disconnect it at any time.
- What your AI provider receives. Your AI provider receives what you let your agent read, and handles it under its own terms. It is your provider, not ours, so its privacy policy applies to what it receives.
- Sensitive actions wait for you. When an agent asks to send something outside 1code, pay, publish something publicly, or delete something for good, we ask you to approve it on your phone first. This is on by default. Sending inside 1code and moving something to Trash do not ask by default. You can change each of these settings.
- The activity log. We keep a log of what each connected agent did, when, and what you approved or refused. You can read it at any time. We keep it for one year.
- Keys. The keys we issue for a connection are stored only as one-way fingerprints.
The same rules apply to apps that developers build on our API. An app gets only the access you approve, and you can remove it at any time.
Our own AI features
Where 1code itself offers an AI feature, it runs on our own API keys with our AI providers. It never uses your personal AI subscription. Our AI providers act only on our instructions and may not train on your information. We name them on request.
The 1code phone app
The 1code phone app is published on Google Play and operated by 1CODE X LTD, which is the controller of the information in it.
- Fingerprint and face. Your phone checks your fingerprint or face itself. The app asks only "is this the right person?" and receives yes or no. What your phone checks never leaves it: we never see or store your fingerprint, or the face your phone uses to unlock. A photo of you holding your identity document is something else: see "Identity checks" above.
- Your key. The private key that approves your sign-ins is made on your phone, kept in its protected storage behind your fingerprint or face, and never leaves it.
- Notifications. If you allow notifications, we send them through Google Firebase Cloud Messaging. Google receives a token for your phone and the notification itself. A notification carries only what is needed to show it, such as a sender's name and the subject of new mail. "Remove a phone?" and "Someone is recovering your 1code ID" name no phone and no person. A notice to a company's owners carries the line that describes the change, with the people's addresses and the phone it was made from.
- Camera. Used only to scan codes (to pair a phone, approve a sign-in or confirm a recovery) and, if a business asks you to prove who you are, to photograph your identity document and you holding it. Never in the background.
- Meetings. Join meeting opens the meeting in your phone's browser. The app itself never uses your microphone.
- What the app does not touch. The app does not look through your phone's address book, text messages, photos or files. It opens a file on your phone only when you pick it in Docs or Sheets, shows it there, and sends nothing of it to us. When you edit a file from your Drive in Docs or Sheets, the app saves your changes back to your Drive. Apart from that, the only files it sends are the photos it takes for an identity check (see "Identity checks" above).
- Google's part of the app. The app reads codes with an open-source part that works entirely on your phone and sends nothing anywhere. It gets notifications through Google Firebase Cloud Messaging, and registers with it once notifications are allowed on your phone: they are on by default in the app; Android 13 and later asks you first, older Android allows them unless you turn them off. Firebase Cloud Messaging then receives an identifier for this installation of the app, and the make and model of your phone and the versions of its system and of Google's part, to deliver notifications. Google does this for us, as our processor. Turning notifications off, or signing out, removes this phone from it.
- Google Play. Google collects its own information when you download the app, under its own policies. An iPhone app is planned.
Services you connect
You can connect other services to 1code. Each one is your choice, and you can disconnect it at any time. Each handles your information under its own terms.
- Google Calendar (in Calendar). We read the list of your calendars and the events of the calendars you choose, and show them to you. If you ask, we keep your 1code events in one calendar named "1code Calendar" that we create in your Google account. We touch nothing else. Unlinking removes that calendar, ends our access and deletes what we hold.
- Google or Microsoft mail (to import old mail into Mail). Read-only, and only while the import runs.
- Slack (in Project). We keep your Slack workspace's name, the key Slack gives us (encrypted) and which Slack person is which 1code account. We read a Slack message only when you choose to make a card from it.
- Your AI agent. See above.
We keep the keys these services give us encrypted. We never sell what we receive from them, use it for advertising or train AI on it.
1CODE X LTD's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The use of raw or derived user data received from Google Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements.
Who processes it for us
These providers handle personal information for us, or for 1code Store where the row says so, only on instructions. Each does so under a written data processing agreement.
| Provider | What for | Where |
|---|---|---|
| Cloudflare, Inc. | Hosting, database, file storage, video conversion, live rooms, live sound and video, receiving, routing and sending email, and the AI model that checks new names | Stored in Western Europe; served from the location nearest each person |
| Resend | Sending email. It keeps a message and the address it went to for up to 30 days. | United States |
| Google Cloud (Key Management) | Holds the key that signs 1code ID's phone certificates | Johannesburg, South Africa |
| Google Firebase Cloud Messaging | Phone notifications | United States and worldwide |
| Paystack | Payments, payouts and seller bank checks for 1code Store, under Store's own terms | South Africa, and where Paystack processes |
| SMSPortal | Text messages for 1code Store, under Store's own terms: the code that checks a seller's number, sale alerts and security alerts the seller switches on, and event messages an organiser chooses to send by SMS. It receives only the number and the message. | South Africa |
| Stripe | Payments for paid 1code plans, once they are on sale. Not in use yet | United States and Ireland |
| domains.co.za | Registering domains for 1code Store, under Store's own terms | South Africa |
| Name.com | Registering domains, once 1code sells them. Not in use yet | United States |
| AI providers for our own AI features | See "Our own AI features" | We name them, and where they are, on request |
Paystack, Stripe, the domain registrars and registries also use some information for their own legal duties, such as fraud checks, anti-money-laundering checks and registry rules. For that use they decide what happens to it themselves, under their own privacy policies.
We also share information:
- with the people you share content with, and the services you connect;
- with the business you are dealing with, when you buy from a store or join a room;
- with the owners of a company you are in: the company's history, which names you when you add, invite, change or remove someone, when someone does that to you, and when you leave or close your account, with the phone or kind of sign-in used. Every addition, invitation and change of role, and every removal, leaving or closed account of an admin or owner, also reaches the owners by phone notification and email;
- between you and your connections and key holders: each other's username and email address (the person you send a connection request to sees yours as soon as you send it), and, for the person a key holder protects, whether that key holder used the app in the last 7 days, 7 to 30 days ago, or 30 days ago or more;
- with authorities, only where the law requires it. We push back on requests that are not lawful, and we tell you unless the law forbids it.
We will tell business customers at least 30 days before we add or replace a provider that handles the information they put in our care.
Transfers between countries
Your information is stored in Western Europe. 1CODE X LTD is in the United Kingdom. Our team works from South Africa. Some providers are in the United States. So your information crosses borders. This is how we protect it:
| From | To | Why | Protection |
|---|---|---|---|
| United Kingdom | European Union | Storage in Western Europe | UK law recognises the European Economic Area as giving adequate protection |
| European Union | United Kingdom | We are a UK company | The EU recognises the United Kingdom as giving adequate protection |
| United Kingdom and European Union | South Africa | Our team works from there; Paystack, SMSPortal, domains.co.za and Google Cloud Key Management are there | For Google Cloud, the EU Standard Contractual Clauses (2021/914), with the UK Addendum to them. Paystack, SMSPortal and domains.co.za work for 1code Store, under its own terms and theirs |
| United Kingdom and European Union | United States | Cloudflare, Resend, Stripe, Google (Firebase Cloud Messaging) and Name.com | The EU–US Data Privacy Framework and its UK Extension, where the provider is certified to it; otherwise the EU Standard Contractual Clauses with the UK Addendum |
You can ask us for a copy of these safeguards at privacy@1code.email. We may hide business details in it that are not about your information.
How long we keep it
We keep information only as long as we need it. When you close your account, we delete your data 30 days later, except what the table below keeps longer: what the law requires, records kept in case of a claim, records kept for security and to prevent fraud and abuse, and the names that are never given out again. The table names each one.
| What | How long |
|---|---|
| Your 1code ID account, with your profile, when you use the app, and when it first used a phone | While it is open; removed 30 days after you delete it. Your username, your 1code addresses and the name of any company you set up are then kept as closed names, so they are never given to anyone else |
| Checks of new names | While your account is open; removed 30 days after you delete it. A check of an address a company asked 1code Mail to create is deleted 12 months after it was made, once it is cleared or decided |
| Retired or revoked phone certificates | 12 months, so revocation checks keep working |
| Security and activity records, including where sign-ins and requests to remove a phone came from | 12 months |
| Places you confirmed | Deleted 90 days after you last confirmed it, or with your account. You can remove one sooner in the app |
| Recovery requests and confirmations | 12 months after they end |
| 1code ID sessions | 8 hours, then removed at the next daily clean-up |
| The one-time number that stops a phone's approval being used twice | Up to a day |
| Sign-ins to the apps | Up to 30 days after the app last renews the sign-in, then removed at the next daily clean-up |
| Your files and content, including Channels messages, calendars, projects, store orders and invoices in Books | Until you delete them or your account closes |
| Event and webinar sign-ups and attendee details: names, email addresses, phone numbers, check-ins, answers to the organiser's questions, promo-code use and the names of door volunteers | 12 months after the event ends, then only the counts are kept. Deleted at once if the store is deleted. A paid ticket is also an order, and the order follows the row above |
| Anything in Trash, in every app, Mail included | 30 days, then deleted for good |
| While your account is open | |
| Closed Mail addresses | Never given to anyone else |
| Mail sending records, the sending log and DMARC reports | 13 months |
| Bounce notices | 30 days |
| Vacation-reply records | 30 days |
| Email codes: the address a code went to, why and when, and a scrambled form of part of the network address that asked for it. The code itself is kept only as a one-way fingerprint | 2 days |
| Resend's copy of a message it sent | Up to 30 days |
| Large-file download links in Mail | 30 days |
| One-time links to open an attachment | A day after they expire |
| A company's admin log | While the company's account is open |
| A company's history of its people (1code ID) | 12 months. Entries made by you or naming your account go 30 days after you delete your account. |
| Workspace Contacts | While the workspace exists; a contact reported as spam is removed |
| Unrecorded live pieces of a session | Within a day |
| Chat, notes and attendance of an unrecorded meeting | 12 months after it ends |
| Recordings | Until the host deletes them |
| Your audience's sign-ups | Until you delete them or your account closes |
| Viewing numbers | While the video exists |
| Connected services (Google, Microsoft, Slack) | Until you disconnect them |
| Your AI agent connections, ended ones too, with the phone that approved each | While your account is open; removed 30 days after you delete it |
| Your key holders and connections, the apps you have signed in to, and the invitations you send (with the email address each went to, and the phone that approved an admin's), ended ones too | While your account is open; removed 30 days after you delete it |
| Apps you register as a developer | Until you remove them. They are switched off when your account is deleted |
| Phone notification tokens | Until you turn notifications off, sign out, remove the phone or delete your account. If you remove the app, until a notification to it next fails |
| Details of a domain you bought through us | While we manage the domain for you, and after that as long as the registry's rules require |
| AI agent activity log | One year |
| KYC documents, including the photos you take in the 1code phone app | 5 years after your selling relationship on 1code Store ends, however it ends, then deleted, except a record of who reviewed them and when, which we keep. The identity document and the photo of you from an application we turn down, or one left unfinished, go sooner: see the next row |
| The identity document and the photo of you from an application we turn down, or one left unfinished | Deleted 90 days after we turn it down, or after 90 days with no activity on it |
| Billing, invoices we issue, and tax records | 6 years after the end of the financial year they belong to, as UK tax law requires |
| Invoices for 1code Store subscriptions and domains, which 1code Store issues under its own terms | 7 years, as the company law they are issued under requires |
| Acceptance records | While your account is open, and 6 years after it closes, the time within which a claim about the agreement can usually be brought |
| Contact-form messages | 12 months |
| Feedback | Until you or we delete it |
| Scrambled network address used to limit how fast names are checked at sign-up | Removed by the next name check from anyone, a minute or more later, and at the latest by the next daily clean-up |
| The network address of a phone that enters a code to add itself to an account, used to limit repeated attempts | A day |
| Our service's technical logs, including the words of a search in Mail | 7 days |
| The one-tap undo link in a "phone added" email | A day after it expires (it works for 48 hours) |
| The messages we pass on to other 1code apps for you (sign-outs, answers to your AI agents' requests, new and changed 1code addresses, ended workspaces and AI connections, removed phones) | 30 days after they were delivered; one never delivered, 90 days after it was made |
| A request to delete your account sent by email (the address it came from, when, and the one-time link's one-way fingerprint) | 30 days after its link expires, or with your account |
| Backups | Up to 30 days, so deleted data is gone from them after that |
We delete data on these schedules automatically.
Security
- Everything is encrypted on its way to and from us, and our storage provider encrypts it at rest.
- There are no passwords to steal. You sign in with your phone or a one-time code, and your phone's private key never leaves it.
- Keys that other services give us are kept encrypted. Keys we issue to apps and AI agents are kept only as one-way fingerprints.
- Private videos are served only through short-lived links.
- KYC documents are kept in private storage that is never public.
- Only people who need it for their work can reach systems holding your information.
- If a breach puts your information at risk, we tell you and the authorities your law requires, in the time it requires. If it affects information you put in our care, we tell you so you can tell the people concerned.
If you find a security problem, please tell us at privacy@1code.email.
Scanning and pausing
To keep people safe, we scan published free sites for phishing, malware, impersonation and other harm. We may pause an account, site or app that causes harm. When we do, we tell its owner why, unless the law or a safety risk stops us, and we tell people who use an app we pause that it is paused. A person reviews every pause or removal. If we pause something at once to stop harm in progress, a person reviews it straight after. Nothing with serious effects is decided by a computer alone.
Children
1code is for people aged 18 or over and is not designed for children. You must be 18 or over to have a 1code account. We do not knowingly collect children's information for an account. If we learn a child has an account, we delete it.
Rooms audiences who join without an account are not targeted at children. If you invite anyone under 18 to a room, you are responsible for having their parents' or school's consent. If you sell to children in your store, you are responsible for any consent their law requires.
If you think a child's information is in 1code without that consent, write to privacy@1code.email.
Your rights and how to use them
Wherever you live, you can ask us to:
- tell you whether we hold information about you, and give you a copy;
- correct it;
- delete it;
- give it to you, or to another service, in a common format;
- stop or limit using it, where the law allows;
- stop using it where we rely on legitimate interests;
- withdraw a choice you made, at any time;
- have a person look again at a decision made by computer, hear your view and let you challenge it.
Your right to object. Where we rely on legitimate interests, you can object at any time, for reasons about your own situation. We then stop, unless we have strong legitimate grounds that outweigh your interests, rights and freedoms, or we need the information to make or defend a legal claim.
You can also do much of this yourself: download a copy of your files and of your 1code ID account, remove a phone, remove a place, disconnect a service or AI agent, and close your account. The download does not hold everything we keep: for the rest, write to us.
Closing your account. In the 1code phone app, go to Settings, then Delete account, and confirm with your fingerprint or face. You are signed out on every phone and in every app at once, and your key holders, connections and AI agents end. We delete your data 30 days later, except what "How long we keep it" says we keep longer. If you are the only owner of a company that other people are in, make someone else an owner first. If you no longer have your phone, the app no longer opens, or you prefer not to use it, write to privacy@1code.email from your account's own email address, with the subject "Delete my account". Your account's own email address is the one you confirmed, or a 1code Mail address your account holds. We confirm it is you before we delete anything, and we answer within one month. We then delete your data 30 days after we confirm it is you, except what "How long we keep it" says we keep longer. To check it is you, we send a one-time link to that address, or, if you still have a phone on the account, ask you to approve on it. The page 1code.uk/delete-account explains these steps.
How to ask. Write to privacy@1code.email. It is free. We may ask you to confirm it is you by approving on your phone with 1code ID. We answer within one month, or sooner where your law requires. If a request is complex, we may need longer, and we will tell you why within that month.
If your information is in a company mailbox, an audience, a store or an invoice, we may pass your request to the business in charge of it, and help them answer.
If we cannot do what you ask, we tell you why.
Complaints
Please tell us first at privacy@1code.email. We acknowledge a complaint within 30 days and tell you what we did about it.
You can also complain to a regulator at any time:
- United Kingdom: the Information Commissioner's Office.
- European Union: the data protection authority where you live, work or where the problem happened.
- Elsewhere: your national data protection authority, where there is one.
Contact details are in the country sections below.
Changes to this policy
When we change this policy, we change the date and version at the top. We tell you by email or in 1code at least 30 days before a significant change applies. We keep a record of which version and which country section you accepted. Accepting this policy means you have been shown it. It is not consent, and we do not rely on it as consent. Where we need your consent, we ask for it separately.
This policy lives at 1code.uk/privacy.
Contact
1CODE X LTD, 2 Centurion Way, Credenhill, Hereford HR4 7FF, United Kingdom.
- Privacy, security, reports of abuse or illegal content, appeals and authorities: privacy@1code.email
- Help, billing and complaints: support@1code.studio
We have not appointed a data protection officer, because the law does not require one for what we do today.
By country
United Kingdom
This section adds what is different or extra if you live in the United Kingdom.
The law. We are a UK company. The UK GDPR and the Data Protection Act 2018 govern everything we do with your information, wherever you live. The Privacy and Electronic Communications Regulations (PECR) govern cookies and electronic marketing.
Who is responsible. 1CODE X LTD is the controller. We do not need a UK representative.
Our reasons. Carrying out our agreement with you (Article 6(1)(b)), legal duties (Article 6(1)(c)), legitimate interests (Article 6(1)(f)), and your consent (Article 6(1)(a)), as shown in "Why we use it". We do not process special category data, unless you choose to put it in your own content.
Your rights. You have the rights in Articles 15 to 22 of the UK GDPR: access, correction, deletion, restriction, portability, objection, and not being subject to a decision made by computer alone with legal or similarly serious effects. We answer within one month. For complex requests we may extend this by up to two more months, and we tell you within the first month.
Cookies (PECR). We use only cookies and browser storage that are strictly necessary for the service you asked for, or that keep your own choices. So we do not ask for consent. We count views of shared videos without storing anything on your device.
Marketing (PECR). We do not send you marketing email or texts. Messages about your account, your security or a change to our terms are not marketing.
Transfers. See "Transfers between countries". Transfers to Google Cloud in South Africa use the UK Addendum to the EU Standard Contractual Clauses. Transfers to the United States use the UK Extension to the EU–US Data Privacy Framework where the provider is certified, and otherwise the UK Addendum.
Breaches. We tell the ICO within 72 hours of learning of a breach that puts people at risk, and we tell you without undue delay when the risk to you is high.
Children. 1code is for people aged 18 or over and is not designed for children. Rooms audiences who join without an account are not targeted at children. A host who invites anyone under 18 is responsible for having their parents' or school's consent.
Complaints. Information Commissioner's Office: ico.org.uk, 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
European Union
This section adds what is different or extra if you live in the European Union or the wider European Economic Area.
The law. The General Data Protection Regulation (GDPR) applies. Where we host what you publish or share, the Digital Services Act (DSA) also applies.
Who is responsible. 1CODE X LTD, in the United Kingdom, is the controller. We have no office in the EU.
Representative. We have not yet appointed a representative in the EU under Article 27 GDPR, or a legal representative under Article 13 of the Digital Services Act. We will appoint and name them before we market to people in the EU. Until then, write to privacy@1code.email.
Our reasons. The same as in the United Kingdom section, under Article 6 GDPR.
Your rights. You have the rights in Articles 15 to 22 GDPR, the same as listed in the United Kingdom section. We answer within one month.
Transfers. Your information is stored in the EU. The EU recognises the United Kingdom as giving adequate protection. Transfers to Google Cloud in South Africa use the EU Standard Contractual Clauses (2021/914). Transfers to the United States use the EU–US Data Privacy Framework where the provider is certified, and otherwise the Standard Contractual Clauses.
Reports and decisions about content (DSA).
- Anyone can report content on 1code they believe is illegal, by writing to privacy@1code.email or using the report link where we show one. We use the reporter's name and email only to handle the report and tell them what we decided.
- If we remove, restrict or pause your content or account, we tell you why and how to challenge the decision.
- Our point of contact for users and authorities under the DSA is privacy@1code.email, in English.
- We show no ads, so no ads are ever targeted at you, whatever your age.
Business users (P2B). Where the EU or UK platform-to-business rules apply to a service (such as a future app marketplace), we follow them. If you sell through 1code Store, we do not use your shoppers' information for our own purposes, we do not give it to other sellers, and you can export it at any time.
Complaints. You can complain to the data protection authority in the EU country where you live, work, or where the problem happened. The list of authorities is at edpb.europa.eu.
Everywhere else your region
The policy above applies to you in full, wherever you are. If your country's law gives you more rights, you have those too. Where your law asks us to name a privacy officer, data protection contact or grievance officer, write to privacy@1code.email. If you are not happy with our answer, you can complain to your national data protection authority, where there is one. If you live in South Africa, the Protection of Personal Information Act, 2013 also protects your information, and you can complain to the Information Regulator (inforegulator.org.za).

