Granwel Technologies LTD — FarLink Privacy Policy. Version 1.2. Effective 24 October 2026. Last updated: 24 October 2026.
This policy explains how Granwel Technologies LTD collects, uses, shares, protects and deletes personal information when you use FarLink. FarLink means:
- the FarLink apps for iPhone, iPad, Mac, Windows and Linux;
- the host features of the FarLink app for Mac;
- FarLink Helper for Windows and Linux;
- FarLink Cloud (accounts, sync, the device list and access from anywhere); and
- FarLink Pro subscriptions.
It is written to meet the transparency requirements of:
- Articles 12 to 14 of the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018;
- the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR); and
- the main privacy laws of other places where FarLink is available, which Part XIX covers.
This policy sits alongside the Granwel Privacy Policy, which covers the Granwel website, general enquiries and our other products. Where the two differ on a FarLink matter, this policy applies. It also sits alongside the FarLink Terms of Service. The Terms are the contract between us; this policy is not a contract and does not change your rights under the law.
Part I — SummaryLink to this section
1. The key points in briefLink to this section
1.1 FarLink lets you see and control your own computers from your other devices. Granwel Technologies LTD ("Granwel", "we", "us", "our") is the controller of the personal information described here. That means we decide why and how it is used, and we are responsible to you for it.
1.2 You can use FarLink on your local network without an account. Without an account, the computers you save, their passwords, their screen thumbnails and your settings stay on your device, and nothing about them is sent to us. The app talks only to the computers you choose, directly over your network.
1.3 A FarLink account uses Sign in with Apple on every platform, including Windows and Linux, where sign-in happens in your browser. We receive from Apple:
- an identifier Apple creates for FarLink; and
- your email address, unless you hid it.
We keep:
- the computers you link to your account; and
- a record of each device you are signed in on.
1.4 Synced computers are end-to-end encrypted. When you turn on sync, each saved computer, including its name, address, username, password and settings, is encrypted on your device. The key is held only by your devices and your recovery phrase. We store the encrypted record and cannot read it, change it or recover it for you.
1.5 Access from anywhere passes through FarLink Cloud when your device and computer are on different networks. The screen image, clipboard text and your keyboard and mouse input pass through our relay servers in the United Kingdom in transit only. We do not record, store, view or analyse what is on your screens or what you type.
1.6 Subscriptions are sold by Apple. Apple takes your payment and handles billing, renewals and refunds. We receive information about your subscription, such as the plan, the renewal date and whether a free trial applies. We never receive your card details.
1.7 We protect free trials from abuse. To stop the same person taking repeated free trials, we keep one-way keyed hashes of:
- your app installation;
- your computers' hardware identifiers; and
- the network range you connect from.
We also use Apple's DeviceCheck service. A network used for four free trials on different accounts is permanently refused further trials. These records contain no names or readable identifiers. They are kept after you delete your account, because otherwise deleting and re-creating accounts would defeat them. Part VI explains this fully, including your right to have a person review any refusal.
1.8 No advertising, no tracking, no selling. FarLink contains no advertising, no third-party analytics or crash reporting, and no tracking across apps or websites. We never sell, rent or trade personal information.
1.9 You are in control.
- Download a copy of everything we hold about you, including our server logs for your IP address, from Settings › Privacy & data in the app.
- Delete your account from the app at any time, which deletes your account data straight away, apart from the fraud-prevention hashes described above.
- Correct your information, restrict or object to how we use it, ask for a review of a trial decision, and complain to the Information Commissioner's Office.
- If you cannot use the app, use the privacy portal at https://farlink.granwel.com/privacy-requests.
Most requests are carried out automatically, straight away.
Part XV explains every right and how to use it.
2. What we never doLink to this section
It matters as much to say what does not happen as what does, because a vague policy can suggest collection that never takes place.
- We never sell, rent or trade personal information, and never share it for cross-context behavioural advertising, targeted advertising or profiling for advertising.
- We never use FarLink data to build advertising profiles, train artificial-intelligence models, or create datasets for third parties.
- We never record, store, view or analyse the content of your remote sessions, meaning what is on your screens, what you type, or what is on your clipboard.
- We never receive your computers' passwords in readable form. They stay on your devices or inside end-to-end encrypted sync records that only your devices can open.
- We never receive your payment card, bank or billing details. Apple processes all payments.
- We never collect your location, contacts, photos, camera, microphone, health data, browsing history or advertising identifier.
- We never ask for special category information, such as health, ethnicity, religious or philosophical beliefs, political opinions, trade-union membership, genetic or biometric data, or sex life or orientation, or for criminal offence information.
- We never make a decision about you based solely on automated processing that has a legal or similarly significant effect on you. Part VI explains the one automated decision FarLink makes, refusing a free trial, and the safeguards around it.
3. Where to find the detail you needLink to this section
- Using FarLink only on your home or office network: Part IV section 11, Part VII and Part IX.
- Using a FarLink account: Part IV sections 12 to 17, Part V and Part XIV.
- Subscribing to FarLink Pro: Part IV section 18 and Part XI.
- A free trial was refused: Part VI.
- Letting your own computer be controlled: Part VIII.
- Exercising a right or complaining: Parts XV and XXII.
- Outside the UK: Part XIX.
- Technical, legal or procurement review: the appendices.
4. How to reach us about privacyLink to this section
4.1 The quickest way to exercise a privacy right is Settings › Privacy & data in the FarLink app, or the privacy portal at https://farlink.granwel.com/privacy-requests (section 60.3). You can also email contact@granwel.com with "FarLink privacy" in the subject line, use the contact form at granwel.com, or write to us at the address in section 5.1, marked for the attention of the privacy contact.
4.2 You do not need to use any particular form of words, know which system holds your information, or explain why you are asking. A clear sentence saying what you want and that it is about FarLink is enough. If we need anything more, we will ask.
Part II — Who we are, our role, and how to contact usLink to this section
5. The controllerLink to this section
5.1 FarLink is provided by Granwel Technologies LTD, a private company limited by shares, registered in England and Wales under company number 17419846. Our registered office and correspondence address is Suite RA01, 195-197 Wood Street, London, E17 3NU, United Kingdom.
5.2 For the processing in this policy we are the controller within the meaning of Article 4(7) of the UK GDPR.
6. Our privacy contact and data protection officerLink to this section
6.1 We are a small company and are not required to appoint a data protection officer under Article 37. A named person at Granwel is responsible for privacy matters and handles every request and complaint. Contact them using the details in section 4.1.
7. FarLink is not offered in the European Economic AreaLink to this section
7.1 FarLink is not offered to people in the European Economic Area (the European Union, Iceland, Liechtenstein and Norway). The apps and FarLink Pro are not available on the App Store in those countries, we do not market FarLink there, and we do not monitor the behaviour of people there. Because we do not offer goods or services to, or monitor, people in the EEA, Article 3(2) of the EU GDPR does not bring our processing within its scope, and we are not required to appoint a representative in the Union under Article 27.
7.2 If you nevertheless use FarLink while in the EEA (for example while travelling with an account created elsewhere), we apply this policy and the UK GDPR to your information, and you can use every right in Part XV by contacting us using section 4.1.
8. When we are not the controllerLink to this section
8.1 Apple. Your Apple Account, Sign in with Apple, the App Store, iCloud Keychain and DeviceCheck are Apple's services. Apple is the controller for them under its own privacy policy at apple.com/legal/privacy. Your App Store purchase history, payment details and Apple Account belong to Apple.
8.2 The computers you connect to. When you use FarLink to control a computer, its contents and its screen-sharing software (such as macOS Screen Sharing, TightVNC, UltraVNC, RealVNC, TigerVNC, x11vnc or wayvnc) are under the control of whoever owns or runs that computer. FarLink is a tool you use. We do not act as controller for what is on your screens.
8.3 Your own use. If you use FarLink to access computers containing other people's personal information, for example at work, you or your organisation may be a controller of that information. You are responsible for using FarLink lawfully. Part VIII says more.
8.4 Our website. The Granwel website and general enquiries are covered by the Granwel Privacy Policy.
Part III — DefinitionsLink to this section
9.1 In this policy:
- "Account" means a FarLink account created with Sign in with Apple.
- "App" means any FarLink app on any platform, including FarLink Helper.
- "Computer" or "host" means a Mac, Windows PC or Linux machine you view or control with FarLink.
- "Device" means the phone, tablet or computer on which you run a FarLink app.
- "FarLink Cloud" means our online services: accounts, sign-in, sync, the device list, the relay, subscription verification and trial protection.
- "FarLink Helper" means the separate host app for Windows and Linux. On a Mac, the FarLink app itself includes the host features.
- "Hash" means a one-way keyed cryptographic digest, specifically HMAC-SHA-256 with a secret key held only by us in a key vault. A hash cannot be reversed into the value it was made from.
- "Linked computer" means a computer registered to your account so that it can be reached from anywhere.
- "Personal information" or "personal data" means information relating to an identified or identifiable living person, as defined in Article 4(1).
- "Processing" means anything done with personal information, including collecting, storing, using, sharing and deleting it.
- "Recovery phrase" means the words the app shows you to restore your vault key.
- "Relay" means the part of FarLink Cloud that connects an app to a computer when they cannot reach each other directly.
- "Session" means a remote connection from an app to a computer.
- "Vault key" means the encryption key, created on your device, that encrypts your synced computers.
Part IV — The information we collect, feature by featureLink to this section
10.1 For each FarLink feature, this Part sets out:
- what information is involved;
- where it comes from;
- whether you have to provide it; and
- what happens if you do not.
Part V gives the purposes and lawful bases, and Part XIV the retention periods.
11. Using FarLink without an accountLink to this section
11.1 What we collect: nothing. When you add a computer, discover computers nearby, connect on your local network, change settings or view thumbnails, all of it happens between your device and your computers. None of it is sent to us.
11.2 Nearby discovery uses your local network's multicast DNS (Bonjour). Computers and FarLink hosts on the same network announce themselves, and your device listens. These announcements stay on your local network and never reach us.
11.3 Wake-on-LAN sends a wake packet from your device to your local network. It never reaches us.
12. Your FarLink accountLink to this section
12.1 Where it comes from. When you choose Sign in with Apple, Apple authenticates you and gives us a signed identity token. On iPhone, iPad and Mac this happens in Apple's built-in sheet. On Windows and Linux, FarLink opens Apple's sign-in page in your web browser. Apple then returns to our server, which hands a one-time, short-lived code back to the app on your computer, protected by a PKCE code verifier that only the app holds.
12.2 What we receive and store:
- Account identifier. Apple gives each developer a different, stable identifier for you. We store a hash of it as your FarLink account ID. We use it to recognise you each time you sign in, on any platform.
- Email address. Apple shares your email address, or a private relay address if you chose "Hide My Email". We store it so that you can see which account you are using and so that we can contact you about your account, security or service changes. If you hid your email, our messages reach you through Apple's relay and we never learn your real address. Apple may share a changed address when you next sign in.
- Dates. When your account was created and last updated.
12.3 What we do not receive. Your name (FarLink does not request it), your Apple Account password, your phone number, your Apple ID, your payment details, or anything else in your Apple Account.
12.4 Is it required? Only for FarLink Cloud features. Without an account you can still use FarLink on your local network.
13. Sign-in sessionsLink to this section
13.1 Each device you sign in on creates a session. We store:
- the device name shown in the app (for example "Reece's iPhone" or "Mac mini"), which comes from your device's name and helps you recognise sessions;
- when the session started, when it was last renewed and when it expires;
- a hash of its refresh token, so that a stolen database copy could not be used to sign in.
13.2 Access tokens last 15 minutes and are not stored. Refresh tokens rotate each time they are used and expire 60 days after last use. Signing out, deleting your account or revoking a session ends it everywhere.
14. Linked computersLink to this section
14.1 When you let a Mac be controlled with the FarLink app for Mac, or link a Windows or Linux PC with FarLink Helper, we store:
- Name, chosen by you or taken from the computer's name, which you can rename.
- Platform (macOS, Windows or Linux), the screen-sharing port and the app version.
- When it was linked, and when it was last online, which the computer reports roughly every minute while it is running.
- A hash of its device credential, which proves the computer is the one you linked.
- A hash of its hardware identifier, described in Part VI.
14.2 How a Mac links. When you are signed in to FarLink on your Mac and turn on "Allow this Mac to be controlled", the Mac links itself to your account. A Windows or Linux PC shows an 8-character code, which you approve in the app on another device. The code expires after a few minutes and can be used only once.
14.3 Removing a computer from your account deletes its record and its credential immediately, and ends any connection to it through FarLink Cloud.
15. Synced computers (end-to-end encrypted)Link to this section
15.1 If you turn on sync, the app creates a vault key on your device and keeps it in your device's secure storage:
- on Apple devices, your iCloud Keychain, so that it is available on your other Apple devices;
- on Windows and Linux, the operating system's credential store.
The vault key is never sent to us. The app shows you a recovery phrase that can restore it.
15.2 For each saved computer, the app encrypts the name, address, port, username, password, operating system, colour, quality and resolution settings, Wake-on-LAN address and link to FarLink Cloud. It uses authenticated encryption (AES-GCM with a fresh random nonce). The app then sends us:
- the encrypted record;
- a random record identifier;
- a version number; and
- the time it changed.
15.3 What this means:
- We cannot read, search, change or use the contents of your synced computers.
- If someone obtained a copy of our database, they could not read them without your vault key.
- If you lose all your devices and your recovery phrase, we cannot recover your synced computers. Keep your recovery phrase safe.
- We can see how many synced records your account has and when they changed.
16. Relay connections (access from anywhere)Link to this section
16.1 When your device and your computer cannot reach each other directly, FarLink connects them through our relay. It processes two kinds of information.
16.2 Connection metadata:
- which of your linked computers you asked to connect to;
- a single-use session ticket that is valid for 30 seconds;
- when the session opened and closed, and how it ended;
- the IP addresses of your device and the computer, which are needed to carry the connection; and
- technical measurements such as data volumes, used to keep the service working and enforce fair use.
16.3 Session content in transit:
- the screen image the computer sends;
- your keyboard and mouse input;
- clipboard text you copy between devices; and
- the screen-sharing protocol's own messages, including authentication challenges.
16.4 How session content is handled. Session content is forwarded between the two connections as a stream of bytes, held in memory only as long as needed to pass it on, and then discarded. It is never written to disk, logged, cached, inspected, analysed or kept. Our staff have no tool to view it. Connections between your devices and FarLink Cloud are encrypted with TLS. The screen-sharing protocol inside the tunnel may have its own encryption, depending on the computer's software. Sessions end after 10 minutes of inactivity, or when either side disconnects.
17. Automatic resolutionLink to this section
17.1 When FarLink resizes a computer's display to fit your screen, your device sends its screen size and scale to the computer, directly on your local network (or through screen-sharing protocol messages). The computer changes resolution and puts it back afterwards. This information does not go to FarLink Cloud. Pairing your device with a computer for automatic resolution uses a 6-digit code shown on the computer, and creates a pairing key stored on both devices.
18. SubscriptionsLink to this section
18.1 FarLink Pro is an auto-renewable subscription sold through the App Store. Apple is the merchant of record: Apple charges you, issues receipts, handles renewals, cancellations and refunds, and holds your billing information.
18.2 What we receive: signed transaction information from Apple, either when the app verifies a purchase or through App Store Server Notifications (version 2), which Apple sends to our server when a subscription changes. It includes:
- the product (plan) and environment (live or test);
- the original transaction identifier and the latest transaction identifier;
- purchase, renewal and expiry dates, and grace-period dates;
- whether an introductory free trial or other offer applies;
- auto-renewal status, refunds and revocations; and
- an account token the app attaches to the purchase, so that it is linked to your FarLink account.
18.3 We verify each transaction's signature against Apple's certificates. We do not receive your name, payment card, bank account or billing address.
18.4 Is it required? Only to use FarLink Pro. The free plan needs no purchase.
19. Trial protection signalsLink to this section
19.1 When you check whether a free trial is available, and when a subscription purchase is verified, the app sends:
- DeviceCheck token (iPhone, iPad and Mac). A short-lived token from Apple's DeviceCheck service that lets our server read and set two bits Apple keeps for your device. It does not identify you to us.
- Install identifier. A random value the app creates the first time it runs. On iPhone and iPad it is kept in the device keychain, so it survives reinstalling the app. On Windows and Linux it is kept in the app's data folder and the system credential store.
- Hardware identifier. On Mac, the hardware UUID; on Windows, the MachineGuid; on Linux, the machine-id. FarLink Helper and the FarLink app for Mac also send it when they link to your account.
- Network. The IP address your request comes from, which we reduce straight away to its network range (the first 24 bits of an IPv4 address, or the first 56 bits of an IPv6 address).
19.2 We keep only hashes of these values (Part VI). We never keep the raw identifiers or your IP address as part of trial protection.
20. Server logsLink to this section
20.1 Our servers write technical logs for every request:
- the time;
- the HTTP method and path, with any query string removed;
- the response code and timing;
- a random request identifier; and
- the IP address the request came from.
Authorisation headers, cookies, tokens, tickets and request bodies are removed before anything is written. Logs are stored in Azure Log Analytics in the UK and deleted after 30 days.
21. Support and correspondenceLink to this section
21.1 If you contact us, we use your contact details, your message and anything you send us to reply and resolve your request. We may ask for your account email address to find your account. We never ask for passwords, recovery phrases or verification codes. Correspondence is handled as the Granwel Privacy Policy describes.
22. Information we do not collectLink to this section
22.1 For the avoidance of doubt, the FarLink apps do not collect:
- location;
- contacts, calendars or photos;
- camera or microphone input;
- health or fitness data;
- browsing or search history;
- advertising identifiers;
- other apps you use;
- usage analytics or crash reports; or
- the files or documents on your computers.
Part V — Why we use information, and our lawful basesLink to this section
23. Purposes and lawful basesLink to this section
23.1 We use personal information only where the law allows. For each purpose, the table gives the lawful basis under Article 6(1) of the UK GDPR.
<!-- generated:purposes (src/privacy/info/register.ts; run npm run privacy:policy) -->
| # | Purpose | Information | Lawful basis |
|---|---|---|---|
| P1 | Create and run your account; sign you in on your devices; keep your sessions secure | Account, sessions | Contract — necessary to provide the service you asked for (Art. 6(1)(b)) |
| P2 | Register and show your linked computers; tell you whether they are online | Linked computers | Contract (Art. 6(1)(b)) |
| P3 | Carry remote sessions through the relay | Relay metadata; session content in transit | Contract (Art. 6(1)(b)) |
| P4 | Store and deliver your encrypted sync records | Synced computers | Contract (Art. 6(1)(b)) |
| P5 | Verify purchases, unlock FarLink Pro, apply plan limits, handle renewals, refunds and grace periods | Subscriptions | Contract (Art. 6(1)(b)) |
| P6 | Prevent free-trial abuse; enforce plan limits, suspensions and bans | Trial protection signals; account; linked computers; subscriptions | Legitimate interests in preventing fraud and protecting our service and paying customers (Art. 6(1)(f); recital 47) |
| P7 | Keep FarLink secure and working; detect, investigate and stop abuse, attacks and faults | Server logs; relay metadata; account | Legitimate interests in network and information security (Art. 6(1)(f); recital 49) |
| P8 | Send service messages about security, your account, your subscription or changes to FarLink, these terms or this policy | Email address | Contract; legitimate interests in keeping you informed |
| P9 | Respond to your requests, questions, complaints and rights requests, including verifying who is asking and keeping a record of each request | Correspondence; privacy request records; any relevant records | Legitimate interests; legal obligation for rights requests (Art. 6(1)(c)) |
| P10 | Comply with the law, respond to lawful requests from authorities, and establish, exercise or defend legal claims | Any relevant records | Legal obligation (Art. 6(1)(c)); legitimate interests in protecting our legal position |
| P11 | Run, sell, merge or reorganise our business, including due diligence | Any relevant records, minimised | Legitimate interests in managing our business |
<!-- /generated:purposes -->
24. Legitimate interestsLink to this section
24.1 Where we rely on legitimate interests (P6 to P11), we have carried out and recorded a legitimate interests assessment, which Appendix D summarises. In each case we concluded that our interests are not overridden by yours, because:
- the processing is what you would reasonably expect from a subscription service;
- we use hashed or minimised information;
- we keep it no longer than needed;
- we never use it for marketing or profiling; and
- you keep the right to object (section 67).
25. ConsentLink to this section
25.1 We do not rely on consent for any FarLink processing, because FarLink has no optional analytics, advertising or marketing. If we ever introduce something that needs consent, we will ask first, make it easy to refuse, and let you withdraw at any time.
25.2 The permissions you grant on your devices (Part IX) are controls in your operating system that let the app do what you ask. They are not a lawful basis we rely on, and you can revoke them in your device settings at any time.
26. What happens if you do not provide informationLink to this section
26.1 Information needed for an account, sync, the relay or subscriptions is a contractual requirement for those features. If you do not provide it, we cannot provide those features. You can still use FarLink on your local network without giving us anything.
27. MarketingLink to this section
27.1 We do not send marketing messages about FarLink or other products. If we ever want to, we will comply with PECR and ask for your consent where required, and every message will include a way to opt out. Service messages (P8) are not marketing, so we may send them whatever your preferences are.
28. Changing purposesLink to this section
28.1 We will not use personal information for a new purpose that is incompatible with the purpose we collected it for. If we want to use it for a new compatible purpose, we will update this policy and tell you first.
Part VI — Fraud prevention, trial protection, bans and automated decisionsLink to this section
29. Why trial protection existsLink to this section
29.1 FarLink Pro includes a 3-day free trial for new subscribers. Free trials are easy to abuse: by creating new Apple Accounts, deleting and re-creating FarLink accounts, or using several devices. Abuse costs us money, distorts our service and is unfair to paying customers. Apple limits each Apple Account to one introductory offer per subscription group. Our checks add limits per device, per computer and per network.
30. What we recordLink to this section
30.1 When a free trial starts on your account, we record a trial claim for each signal available at that time. Each claim contains only:
- a hash of the signal (your install identifier, a hardware identifier of your device or of a linked computer, or your network range);
- what kind of signal it is;
- a hash of your account identifier;
- a hash of the subscription's original transaction identifier, so that the same trial is never held against itself (for example if you restore it on a new device); and
- the date.
30.2 We ask Apple's DeviceCheck service to set a bit for your Apple device recording that a FarLink trial was used. Apple stores two bits per device for each developer. They contain nothing about you and persist until we reset them, including if you reinstall FarLink.
30.3 Your account record also keeps the most recent hashed signals your app reported, so that a claim can be recorded when your trial is confirmed.
30.4 We never record raw identifiers, raw IP addresses or anything else that would let us, or anyone who obtained the records, identify a person or device from them directly.
31. How we decideLink to this section
31.1 Before showing a free trial, and again when a trial purchase is verified, we check whether any of these signals already has a claim belonging to a different account:
- this device's DeviceCheck bit;
- this installation;
- this device's hardware;
- any computer linked to your account;
- your account itself; or
- your network range.
A network range that has been used for four free trials on different accounts is permanently refused further trials.
31.2 If a trial is refused:
- the app shows the same FarLink Pro plans without a free trial, and tells you the reason;
- you can still subscribe, use the free plan and use FarLink on your local network;
- if a trial was started by getting round the app (for example from your Apple Account settings), we withhold FarLink Pro features until the first paid period begins. Apple's own rules decide whether you are charged; and
- where we have reason to believe there is deliberate or repeated abuse, we may suspend or close the accounts involved, as the Terms of Service allow.
32. Automated decision-making and your safeguardsLink to this section
32.1 Refusing a free trial is decided automatically. We do not consider it a decision with a legal or similarly significant effect under Article 22, because it does not stop you using FarLink, buying a subscription or using it on your local network. Even so, we apply the Article 22 safeguards voluntarily. You can:
- obtain a review: ask for one in Settings › Privacy & data or the privacy portal. We first re-evaluate the decision automatically with fresh signals. If nothing matches any more, we reverse it straight away. If the only match is a shared network (section 32.2) and nothing else matches, we lift the network limit for your account automatically. Anything not resolved automatically goes to a person at Granwel, who decides before the deadline in section 60.2 and tells you why. This also applies to a withheld trial, a suspension or a ban;
- express your point of view: tell us anything you think we should take into account;
- contest the decision: if we got it wrong, we will reverse it, correct our records and tell you; and
- get an explanation: of the factors that led to the decision, such as which kind of signal matched. We will not reveal details that would help someone defeat fraud prevention.
32.2 Shared networks. Offices, schools, universities, mobile networks, hotels and public Wi-Fi can share one network range among many people. You may be refused a trial because of other people's trials. If that happens, ask for a review: when the network is the only reason, the limit is lifted for your account automatically.
32.3 We do not use any of this information to profile you, score you, predict your behaviour or make any other decision about you.
33. Bans and suspensionsLink to this section
33.1 Where the Terms of Service allow us to suspend, restrict or close an account, or refuse service to a device, computer or network, we may keep the hashed signals of the account, devices and computers concerned, and a short note of the reason. We keep them for as long as the restriction is in force and reasonably needed to stop it being evaded. Section 32.1's safeguards apply to these decisions too. Unless the law prevents it, we will tell you why.
34. Why these records survive account deletionLink to this section
34.1 If deleting an account also deleted its trial claims, anyone could take unlimited trials by deleting and re-creating accounts. Trial claims and ban records are therefore kept after account deletion, for the periods in Part XIV. We have weighed this against your interests. They contain only hashes that do not directly identify you, are used for nothing but fraud prevention, are protected like the rest of our data, and expire.
34.2 Objecting to trial protection. You can object to trial protection (section 67). If no free trial was ever taken on your account, we erase the trial-protection hashes stored for your account and its linked computers, and never record trial claims for it again. Your account then cannot have a free trial, which we explain before you confirm. If a trial was taken, the claims are needed to prevent repeated free trials, so we keep them and send you a statement of our compelling legitimate grounds.
Part VII — Information that stays on your devicesLink to this section
35. What stays localLink to this section
35.1 The following stay on your devices. They are sent to us only where stated, and only inside end-to-end encrypted sync records you have turned on:
- Your saved computers: names, addresses, ports, usernames, operating systems, colours, quality and resolution settings, Wake-on-LAN addresses and the order of your library. Included in sync if you turn it on.
- Passwords for your computers. On iPhone and iPad they are stored in the Apple Keychain. On Mac, in a private file in the app's support folder that only your user account can read. On Windows, in Windows Credential Manager. On Linux, in the Secret Service keyring, or a private file if none is available. Included in sync, encrypted, if you turn it on.
- Screen thumbnails: small screenshots of each computer's screen, taken when you disconnect so that your library shows what it looks like. Never synced or sent to us.
- Pairing keys for automatic resolution and host pairing records on computers you let be controlled.
- Your settings, such as input mode, default quality and resolution, and remote pointer.
- A cached copy of your last trial eligibility answer, so that the paywall can show the right plans offline.
- The install identifier (section 19).
36. Thumbnails can contain personal informationLink to this section
36.1 Thumbnails are screenshots, so they may show anything that was on screen, including other people's information. They stay on the device that made them. They are deleted when you delete the computer from FarLink or delete the app, and you can turn them off by deleting them from a computer's menu.
37. Deleting local informationLink to this section
37.1 Deleting the FarLink app deletes most local information. Some items in secure storage, such as keychain passwords on iPhone and iPad, the install identifier, or credentials in Windows Credential Manager or a Linux keyring, can remain until you remove them in your device's settings, reset the device, or delete them in the app before uninstalling it.
Part VIII — Hosting a computer, and other people on your screensLink to this section
38. Letting a computer be controlledLink to this section
38.1 When you turn on "Allow this Mac to be controlled" in the FarLink app for Mac, or install FarLink Helper on Windows or Linux, the computer:
- advertises itself on your local network, so that your devices can find it;
- reads its display list and screen modes, so that viewers can fit the resolution. It changes the resolution only during a session you approve, and always puts the original back, including after a restart if a session ended unexpectedly;
- checks whether screen-sharing software is listening on the computer, and which one, to help you set it up;
- stores pairing keys for devices you approve with the 6-digit code; and
- if you link it to your account, reports to FarLink Cloud that it is online, roughly every minute, and accepts relay connections you start from your other devices.
38.2 The screen sharing itself is done by the computer's own screen-sharing or VNC software, which has its own settings, passwords and privacy policy.
39. Other people's information on your screensLink to this section
39.1 Your remote screens may show other people's information, such as emails, documents, chat messages or a colleague's work, and FarLink's relay carries it to your device. We do not look at, store or use it (section 16.4). You are responsible for:
- having the right to access each computer you connect to;
- complying with the law and with any workplace or school rules when you view other people's information; and
- not using FarLink to monitor anyone secretly. The Terms of Service forbid it.
39.2 If you are a person whose information appeared on someone else's screen during a FarLink session, we hold no record of it. Contact the person or organisation that controls the computer. If you believe FarLink is being used to watch you without your knowledge, tell us and we will act under the Terms of Service.
Part IX — Platform permissions and what each one is used forLink to this section
40. iPhone and iPadLink to this section
- Local Network: to discover and connect to computers on your network. You can turn this off in Settings › Privacy & Security › Local Network.
- Sign in with Apple: to create or use a FarLink account.
- App Store: to buy and restore FarLink Pro.
- Keychain: to keep passwords, tokens, the install identifier and the vault key secure.
- DeviceCheck: to read and set FarLink's trial bits.
FarLink does not request location, photos, camera, microphone, contacts or tracking permission.
41. MacLink to this section
41.1 Viewing uses the same permissions as iPhone and iPad.
41.2 Letting your Mac be controlled also uses:
- Local Network and incoming network connections;
- Screen Sharing in macOS settings, which you turn on yourself;
- the ability to change display modes for automatic resolution; and
- Login Items, if you choose to start FarLink at login.
FarLink does not need Screen Recording or Accessibility permission, because macOS Screen Sharing does the capture and input.
42. WindowsLink to this section
42.1 The FarLink app and FarLink Helper use:
- the network, for discovery, direct connections and FarLink Cloud;
- Windows Credential Manager, for credentials;
- the registry, to register the
farlink://link type and, if you choose, to start at login; - display settings, for temporary resolution changes while hosting; and
- the MachineGuid, for trial protection.
43. LinuxLink to this section
43.1 The FarLink app and FarLink Helper use:
- the network, for discovery, direct connections and FarLink Cloud;
- the Secret Service keyring, for credentials;
- an XDG desktop file, to register the
farlink://link type and, if you choose, to start at login; - the X11 RandR extension, for temporary resolution changes while hosting; and
- the machine-id, for trial protection.
Automatic resolution is not available under Wayland.
Part X — Cookies, identifiers, tracking and analyticsLink to this section
44. The appsLink to this section
44.1 The FarLink apps use:
- no cookies;
- no advertising identifiers;
- no fingerprinting for tracking;
- no third-party software development kits for analytics, advertising, attribution or crash reporting; and
- no session replay.
On iPhone and iPad, FarLink does not track you as Apple's App Tracking Transparency framework defines it, so it does not show a tracking prompt.
45. Identifiers stored on your deviceLink to this section
45.1 The install identifier and the eligibility cache are stored on your device and read by FarLink only to provide trial protection, which is part of the subscription you choose and protects the service's security. Where PECR or Article 5(3) of the ePrivacy Directive applies, we rely on the exemption for storage and access that is strictly necessary to provide the service you have explicitly requested. The same applies to the tokens and keys the app stores to keep you signed in and your data secure.
46. Signing in from a browserLink to this section
46.1 On Windows and Linux, signing in opens Apple's sign-in page in your web browser. Apple may set its own cookies there, under Apple's policies. FarLink's sign-in endpoints set no cookies. Sign-in finishes with a single-use code that expires after 60 seconds, returned to the FarLink app on your own computer.
47. Our websiteLink to this section
47.1 The Granwel website's use of cookies is covered by the Granwel Cookie Notice.
Part XI — Who we share information withLink to this section
48. Our processorsLink to this section
48.1 These companies process personal information for us, on our written instructions, under contracts that meet Article 28. They may not use it for their own purposes.
- Microsoft (Microsoft Azure): hosting (Azure Container Apps), database (Azure Cosmos DB), container registry, secret and key storage (Azure Key Vault), logs (Azure Monitor / Log Analytics) and email for service and privacy-request messages (Azure Communication Services Email, sent from privacy@farlink.granwel.com). The data is stored in the UK.
- Cloudflare, Inc.: domain name services for our domains, and network security and performance services where we enable them.
- Our email provider: for correspondence, as the Granwel Privacy Policy describes.
49. Independent controllersLink to this section
49.1 Apple Inc. and its affiliates provide Sign in with Apple, the App Store and its payments, subscription management and refunds, App Store Server Notifications, DeviceCheck and iCloud Keychain, as controllers of their own processing under Apple's privacy policy. When you sign in with Apple or subscribe, Apple knows that you use FarLink.
50. Others, only where necessaryLink to this section
- Professional advisers such as solicitors, accountants, auditors and insurers, under confidentiality obligations, where we need advice or to meet our obligations.
- Courts, regulators, law enforcement and other public authorities, where the law requires it or Part XII allows.
- Anyone you ask us to share with, at your request.
- A buyer, investor or successor business, as Part XX describes.
51. No sale, no sharing for advertisingLink to this section
51.1 We have not sold or shared personal information for cross-context behavioural advertising in the last 12 months, and we will not do so.
Part XII — Requests from governments, law enforcement and othersLink to this section
52. How we respondLink to this section
52.1 We disclose personal information to a public authority only where:
- we are legally required to;
- disclosure is necessary to protect someone's life or physical safety; or
- the law otherwise allows it, for example to prevent or detect crime where a valid exemption applies.
52.2 For every request we check:
- that it is valid;
- that it comes from an authority with power to make it;
- that it is specific and proportionate; and
- that it follows the right legal process.
We challenge requests that are not, and we disclose only the minimum required.
52.3 Because of how FarLink is built, we cannot provide what we do not have:
- the content of remote sessions;
- the contents of synced computers, which are end-to-end encrypted; and
- the passwords to your computers.
52.4 Unless the law or a court order prevents it, we will tell you about a request for your information before disclosing it, so that you can object.
Part XIII — International transfersLink to this section
53. Where your information is storedLink to this section
53.1 FarLink Cloud stores and processes information in the United Kingdom, in Microsoft Azure's UK South region.
54. Transfers outside the UKLink to this section
- Microsoft may access information from outside the UK for support, security and service operations. These transfers are covered by the Microsoft Products and Services Data Protection Addendum, which includes the EU Standard Contractual Clauses with the UK International Data Transfer Addendum, and, where applicable, the UK Extension to the EU–US Data Privacy Framework (the UK–US data bridge).
- Cloudflare runs a global network. Its transfers are covered by its data processing addendum and standard contractual clauses with the UK Addendum.
- Apple processes information in the United States and elsewhere under its own safeguards, including the EU–US Data Privacy Framework, its UK Extension and Swiss–US framework, and standard contractual clauses.
55. Transfers from the EEALink to this section
55.1 The European Commission has decided that the UK provides adequate protection for personal data, so information can flow from the EEA to us without additional safeguards.
56. Copies of safeguardsLink to this section
56.1 You can ask us for a copy of, or more information about, the safeguards for any transfer using section 4.1.
Part XIV — How long we keep informationLink to this section
57. Our approachLink to this section
57.1 We keep personal information only as long as we need it for the purposes in Part V, then delete it or irreversibly anonymise it. Information we are required to keep for longer by law, or that we need for an actual or likely legal claim, is kept for that period and then deleted.
58. Retention periodsLink to this section
<!-- generated:retention (src/privacy/info/register.ts; run npm run privacy:policy) -->
| Information | How long |
|---|---|
| Account record (identifier hash, email, dates) | Until you delete your account. We may delete accounts that have had no sign-in and no linked computer online for three years. |
| Restriction, objection and review settings on your account | Until you lift them or delete your account |
| Sign-in sessions | Until you sign out or revoke them, or 60 days after last use |
| Linked computer records | Until you remove the computer or delete your account |
| Encrypted sync records | Until you delete them, turn off sync and remove them, or delete your account |
| Subscription records | While your account exists. On deletion the link to your account is removed. Apple keeps its own records. |
| Relay session tickets | 30 seconds |
| Relay connection metadata | The length of the session, then only as part of server logs |
| Relay session content | Not stored |
| Server logs | 30 days |
| Sign-in and linking codes (device codes, desktop sign-in codes) | 10 minutes or less, single use |
| Trial claims for installs and hardware | 400 days after the trial started |
| Trial claims for networks | While the permanent network ban is in force. We review network bans at least every 24 months and delete those we no longer need. |
| Ban and suspension records (hashes and reason) | While the restriction is in force, and for up to 24 months after it ends |
| DeviceCheck bits | Held by Apple until we reset them |
| Privacy request records (request, outcome, audit trail and encrypted contact details) | Up to 2 years after the request is closed, or 6 years where it concerns a legal claim |
| Prepared data exports waiting to be downloaded (encrypted) | 7 days, or until downloaded once, whichever is sooner |
| Privacy verification links and privacy portal sign-ins | Email links 24 hours and single use; portal sign-ins 15 minutes |
| Correspondence | Up to 2 years after your matter is closed, or 6 years where it concerns a legal claim |
| Database backups | Rolling backups, overwritten within about one day |
<!-- /generated:retention -->
59. When you delete your accountLink to this section
59.1 When you choose "Delete account" in the app, we immediately and permanently delete:
- your account record;
- every sign-in session, which signs you out everywhere;
- your linked computers and their credentials, which ends any relay connections; and
- your encrypted sync records.
We also remove the link between your account and your subscription.
59.2 What remains:
- trial claims and ban records, as Part VI explains;
- server logs, until they expire after 30 days; and
- the data in rolling backups, until they are overwritten; and
- the record of your deletion request, as section 60.2 explains.
Information on your devices stays there until you delete the app.
59.3 Deleting your account does not cancel your App Store subscription. Cancel it in your Apple Account settings (Settings › your name › Subscriptions on iPhone or iPad). Otherwise Apple will keep renewing it.
Part XV — Your rights, and how to use themLink to this section
60. GeneralLink to this section
60.1 You have the rights below under the UK GDPR.
60.2 Exercising them:
- Cost. It is free. We may charge a reasonable fee, or refuse, only where a request is manifestly unfounded or excessive. If we do, we will explain why.
- Timing. We respond without undue delay and within one month of receiving your request, or of confirming your identity if we need to. Most requests are carried out automatically, straight away. For complex or numerous requests we may extend this by up to two further months; we will tell you within the first month and explain why. The only extension we apply automatically is for numerous requests: when you have more than three requests open with us at the same time.
- Identity. We need to know a request comes from you. Making it from the signed-in app is enough. In the privacy portal you either sign in with Apple, or confirm a single-use link we email you, which works once and expires after 24 hours. A request confirmed by email reaches only the data linked to that address (an account whose Apple address or verified contact address matches) and records matching identifiers you give us. We search server logs only for the IP address you made or confirmed the request from, or addresses your own account used. We will not ask for more than we need, and we never ask for identity documents by default.
- Someone acting for you. Another person can make a request for you, such as a solicitor or a parent of a young child, if they show us they are authorised. Email contact@granwel.com.
- Records. We keep a record of each request, every step taken and our response, for 2 years after it is closed (6 years where it concerns a legal claim). Contact details in it are encrypted.
60.3 How to make a request.
- In the app: Settings › Privacy & data. Requests made there are carried out straight away, and a copy of your data is given to you in the app.
- In the privacy portal, for example if you no longer have the app or no longer have an account: https://farlink.granwel.com/privacy-requests. Sign in with Apple, or give your email address and confirm the link we send you. If you appear only in our logs, you can give us your IP address or device identifiers so that we can find the records.
- By email to contact@granwel.com with "FarLink privacy" in the subject line, if neither works for you. You do not need to use any particular words.
60.4 What happens next. We acknowledge your request by email and send the result there too, from privacy@farlink.granwel.com. If you asked in the portal for a copy of your data, the email contains a download link that works once and expires after 7 days. To use it you sign in with Apple again, or show the confirmation link from our first email, so that only you can open it. The prepared copy is encrypted while it waits and deleted once downloaded or after 7 days. Each response says what we did, anything we kept and why, and how to complain.
61. Right to be informed (Articles 13 and 14)Link to this section
61.1 This policy explains how we use your information. Ask us if anything is unclear.
62. Right of access (Article 15)Link to this section
62.1 You can ask whether we hold information about you and receive a copy, along with:
- the purposes;
- the categories of information;
- the recipients;
- the retention periods;
- the source;
- whether there is automated decision-making; and
- your other rights.
62.2 The quickest way is Download my data in Settings › Privacy & data, or the privacy portal (section 60.3). You receive one JSON file containing:
- everything held about your account;
- the trial-protection records and bans that match your account or identifiers you give us, with their kind and date (records that belong to other accounts are shown only by kind and date);
- our server log entries from the last 30 days for your IP addresses (section 60.2 explains which addresses we search); and
- the information in section 62.1, generated from the same source as Appendices A to C.
Developers can also use GET /v1/me/export for the account part.
63. Right to data portability (Article 20)Link to this section
63.1 You can receive the information you gave us, which we process by contract, in a structured, commonly used, machine-readable format, and ask us to send it to another organisation where that is technically feasible. The data export is a JSON file for this purpose. Your synced computers are included in their encrypted form; your FarLink apps can decrypt them with your vault key.
64. Right to rectification (Article 16)Link to this section
64.1 You can ask us to correct inaccurate information or complete incomplete information:
- Linked computers: rename them in the app or in Settings › Privacy & data.
- Contact address: set a different address for our service and privacy emails in Settings › Privacy & data. We send a single-use link to the new address, and use it once you click it. You can go back to Apple's address at any time.
- Email address from Apple: Apple controls which address it shares. Change it in your Apple Account settings, then sign in again: we update it automatically at each sign-in.
- Anything else: contact us.
65. Right to erasure (Article 17)Link to this section
65.1 You can delete your account in the app at any time (Settings › FarLink Cloud › Account › Delete account), with the effects in section 59. You can also ask us to erase specific information. We will do so unless an exception applies, for example where we need it to prevent fraud (Part VI), to comply with a legal obligation, or to establish, exercise or defend legal claims. If we keep anything, we will tell you what and why.
65.2 In particular: trial claims and ban records are kept under the fraud-prevention exemption, and you can object to them (section 67). Server logs are not erased selectively; every entry is deleted automatically after 30 days. If you have no account and give us device identifiers, we delete matching trial-protection records unless a free trial was actually taken on them.
66. Right to restriction (Article 18)Link to this section
66.1 You can ask us to stop using your information, other than storing it, while we check its accuracy, while we consider an objection, if our use is unlawful but you would rather we restricted it than deleted it, or if you need it for a legal claim after we no longer need it.
66.2 Restrict processing in Settings › Privacy & data or the privacy portal. While a restriction is in place:
- no new trial-protection records are made for your account;
- changes to your synced computers are refused until you lift it;
- your linked computers report only that they are online, which security needs, and their details stop updating; and
- you can still download your data and delete your account.
Lift the restriction the same way, at any time.
67. Right to object (Article 21)Link to this section
67.1 You can object at any time to processing based on legitimate interests (P6 to P11), including trial protection, on grounds relating to your particular situation. We will stop, unless we can show compelling legitimate grounds that override your interests, rights and freedoms, or we need the processing to establish, exercise or defend legal claims. We will explain our decision. You have an absolute right to object to direct marketing, although we do not send any.
67.2 We decide objections by these rules, and send you the reasons:
- Trial protection, no trial ever taken on your account: we stop. Section 34.2 explains the effect, including that your account can then have no free trial.
- Trial protection, a trial was taken: we continue, because preventing repeated free trials is a compelling legitimate ground, and we send you a statement of those grounds and of your right to complain.
- Security logs: we continue, because detecting and stopping attacks and abuse is a compelling legitimate ground. Logs are deleted after 30 days.
68. Rights about automated decision-making (Article 22)Link to this section
68.1 See section 32. A review is automated first; anything not resolved automatically is decided by a person.
69. Right to withdraw consentLink to this section
69.1 We do not rely on consent for FarLink processing. If you tell us you withdraw consent, we record it and confirm that nothing relies on it. If we ever do rely on consent, you can withdraw it at any time, as easily as you gave it, without affecting processing that happened before.
70. Right to complainLink to this section
70.1 You can complain to the Information Commissioner's Office:
- Website: ico.org.uk/make-a-complaint
- Phone: 0303 123 1113
- Post: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
We would appreciate the chance to resolve your concern first (Part XXII).
71. Limits on rightsLink to this section
71.1 Some rights do not apply in every situation, and the Data Protection Act 2018 sets out exemptions, for example where disclosure would reveal information about another person, or would prejudice preventing or detecting crime, which includes fraud prevention. If an exemption applies, we will tell you, unless that itself would prejudice the purpose of the exemption.
Part XVI — Children and young peopleLink to this section
72.1 FarLink is a general-audience tool for accessing computers and is not designed for or directed at children.
72.2 Account age. You must be at least 13 years old to create a FarLink account, which matches the age of digital consent in the UK. If you are under the age of digital consent where you live (up to 16 in some countries), you need your parent's or guardian's consent.
72.3 Purchases. If you are under 18, you need a parent's or guardian's permission to buy a subscription. Apple's Family Sharing purchase controls (Ask to Buy) apply.
72.4 What we do. We do not knowingly collect personal information from children under 13. If we learn that a child under 13 has created an account, we will delete it.
72.5 Contact us using section 4.1 if you believe a child's information has been provided to us.
72.6 We have considered the ICO's Age Appropriate Design Code. FarLink collects the minimum information needed, has no profiling, no advertising, no nudge techniques, no location tracking and no public sharing features, and its settings are private by default.
Part XVII — How we protect informationLink to this section
73. Our security measuresLink to this section
73.1 We use technical and organisational measures appropriate to the risk, taking into account the state of the art, the cost, and the nature, scope, context and purposes of processing (Article 32). They include:
- Encryption in transit: TLS 1.2 or higher for all connections to FarLink Cloud.
- End-to-end encryption: synced computers are encrypted with AES-GCM using keys that never leave your devices.
- Encryption at rest: Azure encrypts databases, logs and backups at rest.
- Secrets management: signing keys, the hashing key and Apple keys are kept in Azure Key Vault and accessed only by our service's managed identity.
- Minimised, hashed identifiers:
- tokens, device credentials and Apple identifiers are stored as hashes;
- trial signals are stored as keyed hashes; and
- IP addresses are reduced to network ranges before hashing.
- Short-lived credentials: 15-minute access tokens, rotating refresh tokens with reuse detection, and 30-second relay tickets.
- Least privilege: services run with only the permissions they need, and administrative access is limited, protected by multi-factor authentication and logged.
- Abuse protection: rate limits, input validation, frame-size limits and idle timeouts.
- Logging hygiene: credentials, tokens and request bodies are removed before logs are written.
- Software security: dependency updates, code review and automated tests.
- Signed apps: apps are code-signed and distributed through the App Store or our official download pages.
74. Your partLink to this section
74.1 You are responsible for:
- keeping your devices, Apple Account and recovery phrase secure;
- using strong passwords for your computers' screen sharing;
- keeping your computers' operating systems and screen-sharing software up to date; and
- turning off hosting when you do not need it.
74.2 Never share your recovery phrase. Granwel will never ask you for it.
74.3 No system is completely secure. If you think your account or a computer has been compromised, revoke your sessions and linked computers in the app and contact us.
Part XVIII — Personal data breachesLink to this section
75.1 We have a written procedure for detecting, investigating, containing and recording personal data breaches.
75.2 If a breach is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office without undue delay and, where feasible, within 72 hours of becoming aware of it (Article 33).
75.3 If a breach is likely to result in a high risk to you, we will tell you without undue delay, in clear language (Article 34). We will explain:
- what happened;
- the likely consequences;
- what we have done; and
- what you can do to protect yourself.
75.4 We record every breach, including those we do not need to report.
Part XIX — Information for people outside the UKLink to this section
76. European Economic Area and SwitzerlandLink to this section
76.1 FarLink is not offered in the EEA (section 7). If you use FarLink while in the EEA, we still apply this policy and the UK GDPR to your information, and you can contact us or the ICO.
76.2 In Switzerland, we apply this policy in line with the Swiss Federal Act on Data Protection, and you can complain to the Federal Data Protection and Information Commissioner (FDPIC).
77. United StatesLink to this section
77.1 Where US state privacy laws apply to us, including the California Consumer Privacy Act as amended by the CPRA, and the laws of Virginia, Colorado, Connecticut, Utah, Texas, Oregon and others, residents have the rights below.
77.2 Categories collected in the last 12 months, by CCPA category:
- Identifiers: account identifier hash, email address, IP address, device and install identifiers (hashed for storage).
- Commercial information: subscription status and transactions.
- Internet or network activity: server logs and relay metadata.
We collected none of the other CCPA categories. The sources, purposes, recipients and retention periods are set out above.
77.3 Your rights. You can ask to:
- know and access the information we collected about you;
- delete it;
- correct it; and
- limit the use of sensitive information. We do not use sensitive personal information, as the CCPA defines it, for any purpose that triggers this right.
77.4 Selling and sharing. We do not sell personal information or share it for cross-context behavioural advertising, so there is nothing to opt out of. We honour Global Privacy Control signals where the law requires.
77.5 Non-discrimination. We will not treat you differently for exercising your rights.
77.6 How to make a request. Use section 60.3. An authorised agent can act for you with your written permission. If we refuse a request, you can appeal by replying to our decision. Residents of some states can then contact their state attorney general.
78. BrazilLink to this section
78.1 Under the LGPD you have rights of confirmation, access, correction, anonymisation, blocking or deletion, portability, information about sharing, and review of automated decisions. You can complain to the ANPD.
79. CanadaLink to this section
79.1 Under PIPEDA and provincial laws, you can access and correct your information, and complain to the Office of the Privacy Commissioner of Canada.
80. Australia and New ZealandLink to this section
80.1 Under the Privacy Act 1988 (Cth) and the Privacy Act 2020 (NZ), you can access and correct your information, and complain to the OAIC or the Office of the Privacy Commissioner.
81. ElsewhereLink to this section
81.1 Wherever you are, you can use the rights in Part XV. We will honour any additional rights your local law gives you.
Part XX — If FarLink changes ownership, or is shut downLink to this section
82.1 Business transfers. If all or part of Granwel's business, or FarLink, is sold, merged, transferred or reorganised, personal information may be transferred to the new owner as part of that transaction, under confidentiality obligations during negotiations. The new owner would have to use it in line with this policy. We will tell you before your information becomes subject to a different privacy policy.
82.2 Shutdown. If we discontinue FarLink Cloud or FarLink as a whole, as the Terms of Service allow, we will:
- give you notice in the app or by email where reasonably practicable;
- let you download your data before the service closes; and
- then delete or anonymise the personal information we hold, keeping only what the law requires, what is needed for actual or likely legal claims, and minimised records needed to wind up the service, such as handling subscription refunds.
Information on your devices is not affected. FarLink apps may keep working on your local network without FarLink Cloud, but we do not promise they will.
82.3 Insolvency. If Granwel becomes insolvent, any office-holder is bound by data protection law in the same way.
Part XXI — Changes to this policyLink to this section
83.1 We review this policy at least once a year and whenever FarLink, our providers or the law change. The version and dates at the top show the current text, and Appendix I lists past versions.
83.2 If we make a material change, for example a new purpose, a new kind of recipient or a longer retention period, we will tell you in the app or by email before it takes effect. Where the law requires, we will ask for your consent. Minor changes, such as clarifications, corrections or new contact details, take effect when published.
Part XXII — Complaints, governing law and contactLink to this section
84.1 Contact us first. Email contact@granwel.com (subject "FarLink privacy"), use the contact form at granwel.com, or write to Granwel Technologies LTD, Suite RA01, 195-197 Wood Street, London, E17 3NU, United Kingdom.
84.2 Complaints. We will acknowledge a data protection complaint within 30 days and tell you the outcome without undue delay.
84.3 Regulators. You can complain to the ICO (section 70) or your local supervisory authority at any time, whether or not you have contacted us first.
84.4 Governing law. This policy is governed by the law of England and Wales. Nothing in it limits your rights under data protection law, or your right to complain to a supervisory authority or go to court.
84.5 Language and format. If a translation of this policy differs from the English version, the English version prevails. If you need this policy in another format, such as large print, ask us.
Appendix A — Processing register summaryLink to this section
This summary reflects our record of processing activities under Article 30.
<!-- generated:register (src/privacy/info/register.ts; run npm run privacy:policy) -->
| Activity | Data subjects | Categories | Purpose / basis | Retention | Recipients |
|---|---|---|---|---|---|
| Accounts and sign-in | Account holders | Apple identifier hash, email, dates; session records (device name, dates, token hash) | P1 Contract | Account lifetime; sessions 60 days after last use | Microsoft (processor); Apple (controller) |
| Linked computers | Account holders | Computer name, platform, port, version, dates, hashed credential and hardware ID | P2 Contract | Until removed | Microsoft |
| Encrypted sync | Account holders | Encrypted records, record IDs, versions, dates | P4 Contract | Until deleted | Microsoft |
| Relay | Account holders; people visible on relayed screens | Session metadata; screen, input and clipboard content in transit only | P3 Contract | Content not stored; metadata in logs 30 days | Microsoft |
| Subscriptions | Subscribers | Product, transaction IDs, dates, trial, renewal, refund and revocation status | P5 Contract | Account lifetime | Apple (controller); Microsoft |
| Trial protection and bans | Account holders; devices; networks | Hashed install, hardware and network signals; hashed account and transaction IDs; DeviceCheck bits; ban reasons | P6 Legitimate interests | 400 days; network bans reviewed every 24 months; bans while in force + 24 months | Microsoft; Apple (DeviceCheck) |
| Security logs | Users of FarLink Cloud | IP address, request metadata | P7 Legitimate interests | 30 days | Microsoft |
| Service messages | Account holders | Email address, or the contact address you verified | P8 Contract / legitimate interests | Account lifetime | Microsoft (Azure Communication Services Email) |
| Privacy requests | People who make a rights request | Request type, dates, outcome and audit trail; hashed account ID; contact address, hashed identifiers and IP addresses you supply (encrypted); prepared data exports (encrypted) | P9 Legal obligation | 2 years after closure (6 years for legal claims); exports 7 days | Microsoft (hosting; Azure Communication Services Email) |
| Correspondence | People who contact us | Contact details, messages | P9 Legitimate interests / legal obligation | 2 years after closure (6 years for legal claims) | Email provider |
| Legal compliance and claims | Anyone concerned | Relevant records | P10 Legal obligation / legitimate interests | As required | Advisers; authorities where required |
<!-- /generated:register -->
Appendix B — Processors and other recipientsLink to this section
<!-- generated:recipients (src/privacy/info/register.ts; run npm run privacy:policy) -->
| Recipient | Role | What they do | Location | Safeguards |
|---|---|---|---|---|
| Microsoft Ireland Operations Ltd / Microsoft Corporation | Processor | Azure hosting, Cosmos DB, Key Vault, Container Registry, Log Analytics, Azure Communication Services Email (service and privacy-request emails) | UK South (storage); email data held in the UK; remote support access may be global | Microsoft DPA; SCCs with UK Addendum; UK–US data bridge |
| Cloudflare, Inc. | Processor | DNS; network security and performance where enabled | Global network | Cloudflare DPA; SCCs with UK Addendum |
| Email provider (see Granwel Privacy Policy) | Processor | Correspondence | As stated in the Granwel Privacy Policy | DPA |
| Apple Inc. and affiliates | Independent controller | Sign in with Apple, App Store, App Store Server Notifications, DeviceCheck, iCloud Keychain | USA and others | Apple's safeguards (DPF, SCCs) |
<!-- /generated:recipients -->
Appendix C — Retention quick referenceLink to this section
<!-- generated:retention-summary (src/privacy/info/register.ts; run npm run privacy:policy) -->
| Data | Retention |
|---|---|
| Account | Until deleted; accounts inactive for 3 years may be deleted |
| Account privacy settings | Until lifted or the account is deleted |
| Sessions | 60 days after last use |
| Linked computers | Until removed |
| Sync records | Until deleted |
| Subscription link | Account lifetime |
| Relay tickets | 30 seconds |
| Relay content | Not stored |
| Logs | 30 days |
| Sign-in and linking codes | 10 minutes or less |
| Trial claims (installs, hardware) | 400 days |
| Trial claims (networks) | While the ban is in force; reviewed every 24 months |
| Ban records | While in force + up to 24 months |
| Privacy requests | 2 years after closure (6 for legal claims) |
| Data export downloads | 7 days or one download |
| Privacy links and portal sign-ins | 24 hours / 15 minutes |
| Correspondence | 2 years after closure (6 for legal claims) |
| Backups | About 1 day |
<!-- /generated:retention-summary -->
Appendix D — Legitimate interests assessments in summaryLink to this section
D1. Trial protection and bans (P6)
- Purpose: prevent repeated free trials and evasion of bans.
- Necessity: Apple's one-trial-per-Apple-Account limit is easily bypassed with new Apple Accounts. Per-device, per-computer and per-network signals are the least intrusive effective control. We considered and rejected:
- collecting payment fingerprints (not available to us, and more intrusive);
- requiring phone numbers (more intrusive); and
- no control (unsustainable).
- Balancing:
- signals are stored only as keyed hashes;
- IP addresses are reduced to ranges before hashing;
- no profiling, advertising or other use;
- users are told before a trial is refused;
- human review is available; and
- fixed retention.
- Risk: a shared network may be refused trials because of other people. This is mitigated by human review, and the person can still subscribe and use the free plan.
- Conclusion: our interests are not overridden.
D2. Security logs and relay metadata (P7)
- Purpose: detect and stop attacks, abuse and faults.
- Necessity: request metadata and IP addresses are the minimum needed to investigate incidents.
- Balancing: 30-day retention; credentials and bodies removed; no profiling.
- Conclusion: our interests are not overridden.
D3. Service messages, correspondence, legal compliance and business transfers (P8 to P11)
- These involve limited information, used as a person would expect, with safeguards and fixed retention.
- Conclusion: our interests are not overridden.
Appendix E — What each app sends, platform by platformLink to this section
| App | Without an account | With an account |
|---|---|---|
| FarLink for iPhone and iPad | Nothing to Granwel | Account and sessions; synced records if sync is on; relay metadata and content in transit; subscription transactions; DeviceCheck token and install identifier for trial checks |
| FarLink for Mac (viewing) | Nothing to Granwel | As iPhone, plus the Mac hardware identifier for trial checks |
| FarLink for Mac (hosting) | Nothing to Granwel; local-network announcements only | Linked computer record; heartbeats about every minute; hardware identifier hash; relay sessions you start |
| FarLink for Windows and Linux | Nothing to Granwel | Account and sessions (browser sign-in); synced records if sync is on; relay metadata and content in transit; install and hardware identifiers for trial checks. These apps cannot buy subscriptions. |
| FarLink Helper (Windows and Linux) | Nothing to Granwel; local-network announcements only | Linked computer record; heartbeats; hardware identifier hash; relay sessions you start |
Appendix F — App Store privacy detailsLink to this section
On the App Store, FarLink declares:
- Data linked to you:
- Contact Info: email address;
- Identifiers: user ID and device ID;
- Purchases: purchase history;
- Used for: App Functionality, which in Apple's definitions includes preventing fraud and implementing security measures;
- Data used to track you: none; and
- Data not linked to you: none collected.
Appendix G — Frequently asked questionsLink to this section
Can Granwel see my screen? No. Relayed screen images pass through our servers in memory only and are never stored or viewed. On your local network they do not reach us at all.
Can Granwel see my computers' passwords? No. They stay on your devices, or inside end-to-end encrypted sync records we cannot read.
What happens if I lose my phone? Sign in on another device and enter your recovery phrase to restore your synced computers. Revoke the lost device's session in the app.
What happens if I lose my recovery phrase and all my devices? We cannot recover your synced computers. Your account, linked computers and subscription are not affected.
Why was my free trial refused? One of the signals in Part VI matched a trial on another account, or your network has been used for four trials. Ask for a review in Settings › Privacy & data: it is re-checked automatically first, and a person decides anything that is not resolved.
Does deleting my account cancel my subscription? No. Cancel it in your Apple Account settings.
Does FarLink work if I never create an account? Yes, on your local network.
Do you use AI on my data? No.
Appendix H — GlossaryLink to this section
- AES-GCM: a standard, authenticated encryption method.
- Bonjour / multicast DNS: a way for devices on the same network to find each other without a central server.
- Controller: the organisation that decides why and how personal information is used.
- DeviceCheck: an Apple service that lets an app developer store two bits per device with Apple, without identifying the user.
- HMAC: a keyed hash. Without the secret key, nobody can compute or match the hashes.
- Processor: a company that handles personal information on a controller's behalf and instructions.
- Relay: a server that passes a connection between two devices that cannot reach each other directly.
- TLS: the encryption used by secure web connections.
- VNC / RFB: the open protocol FarLink uses to view and control computers.
Appendix I — Version historyLink to this section
| Version | Date | Changes |
|---|---|---|
| 1.0 | 24 October 2026 | First FarLink Privacy Policy |
| 1.1 | 24 October 2026 | Automated privacy requests: Settings › Privacy & data and the privacy portal; server-log searches in access requests; restriction, objection and review rules; privacy request records and download links; Azure Communication Services Email |
| 1.2 | 24 October 2026 | Not offered in the EEA (section 7); section numbering made unique |