Privacy Policy

1. Introduction

This Privacy Policy explains how Centora Ltd (“Centora”, “we”, “us”, or “our”) collects, uses, stores, and protects your personal data when you use the ILR Tracker website and services at ilrtracker.com (the “Service”). It also explains your rights under UK data protection law and how to exercise them.

This Policy is provided in accordance with:

the UK General Data Protection Regulation (UK GDPR); and
the Data Protection Act 2018.

ILR Tracker is a tool to help you track absences, eligibility, and applications for Indefinite Leave to Remain and British citizenship. It is not a substitute for legal advice. See our Terms of Service for the terms governing your use of the Service.

2. Data Controller

For the purposes of the UK GDPR, the data controller responsible for your personal data is:

Company: Centora Ltd
Company number: 17218097 (registered in England and Wales)
ICO registration: ZC161507
Registered office: 124 City Road, London, United Kingdom, EC1V 2NX
Data privacy contact: hello@centora.uk

We are not required to appoint a Data Protection Officer, and we have not appointed one. Privacy enquiries are handled by Centora at the contact address above.

3. Information We Collect

3.1 Account information

We use Google Sign-In (OAuth) for authentication. When you create an account, Google provides us with your name and email address. We never receive or store your Google password.

3.2 Immigration and travel information you enter

To provide our tools, we store the information you choose to enter, which may include:

travel history (trip dates, destinations, and reasons);
visa type, immigration status, and key dates;
application and decision dates you record (for example, ILR or naturalisation submission, biometrics, and decision dates);
Life in the UK test practice attempts and application-document progress; and
any other details you enter into our calculators, planners, or forms.

This information relates to your immigration circumstances. While it is not “special category” data under Article 9 of the UK GDPR, we recognise it is sensitive and we handle it with particular care.

If you use the paste-your-trips import feature, the text you paste is sent to our AI provider, Anthropic, to extract trip dates and destinations, and is not used to train Anthropic's models.

3.3 Family members you add

If you use family tracking, you can add household members (for example, a partner or adult dependant) to your account and record their name, relationship to you, visa details, and travel history. Only add someone's details with their knowledge and agreement: you are responsible for having their permission. Family member information is visible only within your account, is handled with the same care as your own immigration data, and is shared only with the processors listed in section 6 as part of operating the Service. You can remove a family member at any time from within the app; removal permanently and immediately deletes their visa details and travel history. Deleting your account deletes all family member data with it.

3.4 Subscription and payment information

Payments are processed by Stripe. We do not collect or store your full card details. We receive and store a record of your transactions and subscription status (for example, plan, billing period, and renewal or cancellation state) to provide and manage your access.

3.5 Usage, analytics, and device data

When you use the Service we (and our analytics providers) may automatically collect usage data such as IP address, approximate location, browser and device type, pages visited, features used, referral or campaign (UTM) information, and error reports. With your consent, our analytics provider may also record anonymised session replays of how the app is used to help us diagnose problems and improve the product; input fields are masked where this feature is enabled.

3.6 Support communications

If you contact us, we collect your email address, the content of your message, and any information you choose to share. We use this solely to provide support.

4. How We Use Your Data and Legal Basis

We only process personal data where we have a lawful basis under the UK GDPR:

To provide the Service: creating and managing your account, storing your trips and visa data, running calculations, generating reports, and providing notifications you enable. Legal basis: performance of a contract (Art. 6(1)(b)).
To keep the Service secure and working: authentication, fraud and abuse prevention, debugging, and core product improvement. Legal basis: our legitimate interests in operating and securing the Service (Art. 6(1)(f)).
For analytics, session replay, and marketing: non-essential analytics cookies, session replay, advertising pixels, and any marketing emails. Legal basis: your consent (Art. 6(1)(a)), which you can withdraw at any time.
To meet legal obligations: for example, keeping transaction and tax records. Legal basis: legal obligation (Art. 6(1)(c)).
Service and account emails: important updates about your account, security, or material changes to the Service. Legal basis: performance of a contract and our legitimate interests (Art. 6(1)(b) and (f)).

5. Cookies and Tracking

We use essential cookies to keep you signed in and to remember your preferences. With your consent, we also use non-essential cookies and similar technologies for analytics and marketing. Non-essential cookies are not set unless and until you consent through our cookie banner, and you can change your choice at any time.

We also use tracking pixels and link tracking in the emails we send you, to measure whether a message was opened and which links were clicked. This helps us understand which emails are useful and send fewer of the ones that are not. You can prevent open tracking by disabling remote images in your email client, and you can unsubscribe from our emails at any time using the link in any message.

For a full description of the cookies and third-party services we use, please see our Cookie Policy.

7. International Data Transfers

Your account and immigration data are stored in the EU (Supabase, PostHog). Some of our providers, in particular Google Analytics, the Reddit advertising pixel, Anthropic (for the paste-your-trips import feature), and, for the mobile app, RevenueCat, Apple, and Google (for in-app purchases and sign-in), process data in the United States. Sentry (crash and error reporting on the mobile app and the website's servers) may also process data outside the UK and EU, depending on the hosting region configured for our account. Where data is transferred outside the UK, we rely on appropriate safeguards recognised under UK law, such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or the UK Extension to the EU-US Data Privacy Framework, depending on the provider.

8. Data Retention

We keep personal data only for as long as necessary for the purposes set out in this Policy:

Account, visa, and travel data: retained while your account is active, and deleted within 30 days of account closure. Residual copies in encrypted backups are overwritten within 90 days.
Transaction and tax records: retained for up to 6 years to comply with UK tax and accounting law.
Analytics data: retained for up to 14 months; session replays are retained for a shorter period.
Support communications: retained for up to 24 months.
Consent records: retained as evidence of your cookie and marketing choices.

9. Data Security

We use appropriate technical and organisational measures to protect your data, including encryption in transit and at rest, row-level access controls so users can only access their own records, secure authentication, and industry-standard hosting. No method of transmission or storage is completely secure, and we cannot guarantee absolute security, but we work to protect your data and to notify you and the ICO of any qualifying personal data breach as required by law.

10. Your Rights

If you are in the UK or EU/EEA, you have the right to:

Access: request a copy of the personal data we hold about you;
Rectification: request correction of inaccurate or incomplete data;
Erasure: request deletion of your data (the “right to be forgotten”);
Restriction: request that we limit how we process your data;
Objection: object to processing based on our legitimate interests;
Portability: receive your data in a structured, machine-readable format;
Withdraw consent: withdraw consent at any time where processing is based on consent (for example, analytics or marketing cookies); and
Complain: lodge a complaint with the Information Commissioner’s Office (see Section 15).

You can exercise most rights directly: access and export your data from your account settings, edit records in the app, and delete your account and data from Settings. For anything else, email hello@centora.uk. We respond to requests within one month, free of charge, and may ask you to verify your identity first.

11. Data Deletion Requests

You can request complete deletion of your data at any time:

In-app: delete your account from Settings, which removes your account and associated data.
Email: send a request to hello@centora.uk with the subject line “Data Deletion Request”.

On a verified request we will delete or anonymise your personal data within 30 days and confirm by email, except where we are required to retain certain records (for example, transaction records for tax purposes).

12. Children’s Privacy

The Service is intended for adults managing their own UK immigration journey and is not directed at children. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, please contact us at hello@centora.uk and we will delete it.

13. Automated Decision-Making

Our calculators and planners produce estimates and guidance based on the information you enter. These are tools to assist you: they do not make decisions about you that produce legal or similarly significant effects, and we do not carry out automated decision-making within the meaning of Article 22 of the UK GDPR. Always verify results with GOV.UK or a qualified immigration adviser.

14. Changes to This Policy

We may update this Policy from time to time. We will post changes on this page and update the “Last updated” date above, and we will notify you of significant changes by email or in-app notice where appropriate.

15. Supervisory Authority (ICO)

If you are unhappy with how we handle your data, you have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner’s Office (ICO)
Website: ico.org.uk
Helpline: 0303 123 1113

We would, however, appreciate the chance to address your concerns before you approach the ICO.

16. The ILR Tracker Mobile App

This section describes how the ILR Tracker mobile app (iOS and Android) collects and uses data, in addition to the rest of this Policy, which applies to the app as well as the website.

16.1 Importing trips from your photos

If you use photo import, the app reads the date and location tags already stored on geotagged photos on your device to suggest past trips abroad for you to review. Your photos are never uploaded or sent to our servers, only the date and coordinates are read on the device. Photos stored only in iCloud and not downloaded to your device are skipped rather than downloaded. To work out the country for a cluster of photos, the coordinate is sent once per place visited to your device's built-in reverse geocoding service (provided by Apple or Google, depending on your device), not to a separate third party we contract with directly.

16.2 Importing trips from your calendar

If you use calendar import, the app reads events from the calendars on your device to find flight bookings and turn them into candidate trips. This happens on your device: event text is not sent to our servers or to any third party, only the trip dates and destinations you confirm are saved to your account.

16.3 Pasting trips as text

If you use the paste-your-trips import feature in the app, the text you paste is sent to our AI provider, Anthropic, to extract trip dates and destinations, in the same way as the website feature described in section 3.2. It is not used to train Anthropic's models.

16.4 Background location (opt in)

You can optionally turn on background location tracking so the app can notice when you cross into or out of the UK, to help you build up your trip history over time. The app does not record a continuous location trail: it stores only the fact that you crossed the border and, for a departure, one coordinate so the country can be named. The device only wakes to check your location after around 25 kilometres of travel. This data stays on your device, and you review and confirm any candidate trips it suggests before anything is saved to your account. You can turn tracking off, and clear this on-device log, at any time in the app.

16.5 Sign in with Apple

On iOS, you can sign in using Sign in with Apple. Apple gives us a stable identifier for your account and, only the first time you sign in, the name and email address (or a private relay email address that forwards to your real one) you choose to share. We store this in the same way as a Google sign-in, described in section 3.1.

16.6 In-app purchases

Purchases made in the app are handled by RevenueCat, which manages subscriptions and purchases on our behalf, and processed by the Apple App Store or Google Play, who are the merchant of record for the transaction. We never see or store your card details. We receive an app user identifier tied to your account, the product you bought, and the purchase and expiry dates, so we can give you access to paid features.

16.7 Analytics and crash reporting

The mobile app uses PostHog to record anonymous usage events tied to your account's user id, such as screens viewed, onboarding steps completed, the number of trips you have added, and purchase funnel events. This never includes your name, email, travel dates, or visa details. The app can also use PostHog session replay, a recording of your taps and navigation on screen, to help us find usability problems and bugs. This is off by default and controlled by a remote setting we manage, and it only runs when your "Share anonymous usage data" switch is on. All text inputs and images are masked in these recordings, so they never show your name, email, travel dates, visa details, or other personal or trip information, and recordings are never shared with advertisers. PostHog is hosted in the EU and keeps this data for up to 30 days. You can stop this at any time with the "Share anonymous usage data" switch in the app's Settings.

The app also uses Sentry to collect crash reports when something goes wrong, so we can fix bugs. A crash report can include a stack trace, your device model, operating system version, and app version. Crash reporting is not gated by the usage-data switch above and does not include personal data such as your name, email, or immigration information.

The app has no push notifications; reminders and updates appear only in the in-app notification inbox when you open the app.

16.8 Deleting your account from the app

You can delete your account from the app in the same way as on the website: from Settings, as described in section 11.

17. Contact Us

For any questions about this Privacy Policy or your data, contact us:

Email: hello@centora.uk
Post: Centora Ltd, 124 City Road, London, United Kingdom, EC1V 2NX

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