Terms of Service

For all users of PVG Pal
Last updated: April 2026  |  Version 1.0 (Draft)

The short version

PVG Pal is a compliance tracking tool. It helps volunteers and coordinators keep track of PVG scheme membership, deadlines, and safeguarding requirements.

PVG Pal is not a disclosure processing service. It does not replace Disclosure Scotland, the Church of Scotland Safeguarding Service, VSDS, or your organisation's safeguarding policies.

Volunteers use the app for free. Coordinators pay a monthly or annual subscription via the web dashboard. You can cancel at any time and your data is never deleted because of a payment failure.

1. About PVG Pal

1.1 PVG Pal is operated by Hugh Mackenzie, trading as PVG Pal, based in Aberdeenshire, Scotland.

1.2 PVG Pal provides a mobile app (iOS and Android) and a web dashboard for tracking PVG (Protecting Vulnerable Groups) scheme compliance in Scotland.

1.3 By creating an account or using PVG Pal, you agree to these Terms of Service and our Privacy Policy.

2. Who these terms apply to

2.1 Volunteers — individuals who use the PVG Pal app to manage their personal PVG wallet, track application status, and receive deadline reminders. Volunteer accounts are free.

2.2 Coordinators — safeguarding coordinators who use PVG Pal to manage PVG compliance for their organisation. Coordinators pay a subscription and are also bound by the Data Processing Agreement accepted during onboarding.

2.3 Auditors — individuals who access PVG Pal through a time-limited link to review an organisation's compliance status. Auditors do not create accounts and are bound by these Terms for the duration of their access.

2.4 You must be at least 16 years old to create a PVG Pal account.

3. What PVG Pal does — and what it does not do

This is the most important section of these Terms.

What PVG Pal does

3.1 PVG Pal tracks PVG scheme membership status, application progress, certificate sharing deadlines, training compliance, and generates compliance reports (such as the Church of Scotland SG07 register).

3.2 PVG Pal automates deadline reminders and status tracking through a passthrough email system (see section 7).

3.3 PVG Pal provides an AI assistant that answers general questions about the PVG process (see section 8).

What PVG Pal does NOT do

3.4 PVG Pal is not a disclosure processing service. It does not submit PVG applications to Disclosure Scotland, does not process disclosure checks, and does not issue or verify PVG certificates.

3.5 PVG Pal does not replace Disclosure Scotland, the Church of Scotland Safeguarding Service, Volunteer Scotland Disclosure Services (VSDS), or any other body involved in the PVG scheme.

3.6 PVG Pal does not provide legal advice. The AI assistant offers general guidance about the PVG process, not legal or professional advice. For specific legal questions, consult your organisation's safeguarding advisor or a qualified solicitor.

3.7 PVG Pal does not guarantee compliance. The platform is a tool to help coordinators manage their safeguarding administration. Coordinators remain responsible for their organisation's compliance with the PVG (Scotland) Act 2007 and their own safeguarding policies.

3.8 Disclosure Scotland does not notify organisations during the initial consideration stage of a PVG check. PVG Pal cannot detect or report on this stage. Coordinators remain responsible for periodic re-verification and for following their safeguarding policy regarding consideration notifications.

4. Your account

4.1 You are responsible for keeping your login credentials secure. If you use biometric or passkey authentication, only your own device should be enrolled.

4.2 You must provide accurate information when creating your account. If any of your details change, you should update them in the app or dashboard settings.

4.3 You must not share your account with anyone else or allow another person to use your account to access volunteer data.

4.4 If you suspect your account has been compromised, contact us immediately at support@pvgpal.app.

5. Subscriptions and billing (coordinators)

5.1 Volunteer accounts are free. Coordinator accounts require a paid subscription.

5.2 Subscriptions are available on a monthly or annual basis. Annual billing is the default and includes a discount. Current pricing is displayed during onboarding and on the PVG Pal website.

5.3 All payments are processed by Stripe through the web dashboard at pvgpal.app. PVG Pal never sees or stores your payment card details.

5.4 Billing is web-only. No in-app purchases are available. This is a deliberate choice to keep costs lower for your organisation.

Cancellation

5.5 You can cancel your subscription at any time from the web dashboard settings (C14). Cancellation takes effect at the end of your current billing period — you keep full access until then.

5.6 We do not offer refunds for partial billing periods, except at our discretion in exceptional circumstances.

Payment failure

5.7 If a payment fails, we will attempt to collect it again and notify you by email. You have a 14-day grace period during which your dashboard continues to work normally.

5.8 After 14 days of non-payment, your dashboard enters read-only mode. You can still view your data but cannot add volunteers, send nudges, or generate new exports.

5.9 Your data is never deleted because of a payment failure. If you reactivate your subscription at any time, full access is restored instantly with all data intact.

Price changes

5.10 We may change subscription prices with at least 30 days' notice by email. Price changes apply from your next renewal date. If you do not accept the new price, you may cancel before the renewal date.

6. Acceptable use

6.1 You agree to use PVG Pal only for its intended purpose: managing PVG compliance and safeguarding administration.

6.2 You must not:

(a) use PVG Pal to store or process data that is not related to PVG compliance;
(b) use volunteer data accessed through PVG Pal for marketing, fundraising, or any purpose unrelated to safeguarding;
(c) attempt to access data belonging to other organisations or volunteers not linked to your account;
(d) share auditor access links publicly or with individuals who are not conducting a legitimate compliance review;
(e) attempt to reverse-engineer, decompile, or extract the source code of PVG Pal;
(f) use automated tools (bots, scrapers) to access PVG Pal;
(g) use PVG Pal in any way that is unlawful, fraudulent, or harmful.

7. The passthrough email system

7.1 When a volunteer registers, PVG Pal creates a unique passthrough email address (e.g. yourname-abc123@pvgpal.app). This address is used on PVG application forms in place of the volunteer's real email address.

7.2 Emails sent to the passthrough address are processed by PVG Pal to detect status changes (e.g. "Disclosure Scotland has sent your application link"). Only the sender address, timestamp, and subject line are logged. The email body is never read, stored, or analysed.

7.3 The complete email is forwarded to the volunteer's real email address immediately. PVG Pal does not alter the email content.

7.4 PVG Pal is not responsible for emails that are delayed or lost by the originating sender (Disclosure Scotland, the Safeguarding Service, or any other body). The passthrough system forwards emails as soon as they are received.

7.5 If the passthrough email system experiences a technical failure, PVG Pal will make reasonable efforts to resolve the issue promptly. Volunteers should also monitor their real email inbox directly for critical correspondence during any known outage.

8. The AI assistant

8.1 PVG Pal includes an AI assistant powered by Anthropic's Claude Haiku model. The AI assistant answers general questions about the PVG process — for example, "Do I need a PVG check for this role?" or "How long does a PVG application take?"

8.2 The AI assistant provides general guidance only. It is not a legal advisor and its responses should not be treated as legal or professional advice. For specific questions about your situation, contact your safeguarding body or a qualified solicitor.

8.3 No personal data is sent to the AI service. The AI assistant receives only the question text — not your name, PVG number, or any other personal information. Conversations are stateless and not retained.

8.4 PVG Pal is not liable for any action taken or not taken based on information provided by the AI assistant.

9. Intellectual property

9.1 PVG Pal, including its design, code, branding, and content, is owned by Hugh Mackenzie. You may not copy, modify, distribute, or create derivative works from PVG Pal without written permission.

9.2 Your data remains yours. PVG Pal does not claim ownership of any data you enter into the platform. You grant PVG Pal a licence to process your data solely for the purpose of providing the service.

9.3 The compliance reports, SG07 exports, and audit reports generated by PVG Pal belong to the Organisation that created them. PVG Pal does not use your report data for any purpose other than providing the service to you.

10. Limitation of liability

Please read this section carefully.

10.1 PVG Pal is provided "as is" and "as available". While we work hard to make PVG Pal reliable, accurate, and useful, we cannot guarantee that the service will be error-free, uninterrupted, or completely secure at all times.

10.2 PVG Pal does not warrant that:

(a) the passthrough email system will detect every status change from Disclosure Scotland or any other body;
(b) deadline calculations will be accurate in every case — deadlines are calculated from detected events and may not account for postal delays, bank holidays, or processing backlogs;
(c) the AI assistant's responses will be accurate, complete, or appropriate for your specific circumstances;
(d) the platform will be compatible with all devices or operating systems.

10.3 PVG Pal is not liable for:

(a) any safeguarding failure, compliance breach, or regulatory action arising from the Organisation's or volunteer's failure to follow their own safeguarding policies, regardless of whether PVG Pal was being used;
(b) any loss arising from the Organisation's reliance on PVG Pal as its sole compliance tool, without independent verification;
(c) any loss arising from data entered incorrectly by users;
(d) any actions or decisions by Disclosure Scotland, the Church of Scotland Safeguarding Service, VSDS, or any other third party;
(e) indirect, consequential, or incidental losses (including loss of reputation, loss of data beyond what is stored in PVG Pal, or lost opportunities).

10.4 To the maximum extent permitted by law, PVG Pal's total liability to any user for any claim arising from or related to the use of PVG Pal is limited to the greater of (a) £100 or (b) the total fees paid by the user in the 12 months preceding the claim.

10.5 Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence, fraud, or any other liability that cannot be excluded by law.

11. Availability and service interruptions

11.1 We aim for PVG Pal to be available at all times, but we cannot guarantee 100% uptime. Planned maintenance will be communicated in advance where possible.

11.2 PVG Pal relies on Cloudflare's infrastructure, which has a 99.99% availability SLA. In the event of an infrastructure outage, we will work to restore service as quickly as possible.

11.3 The PVG Pal mobile app supports offline access to previously synced data (PVG wallet, timeline, organisation details). Features requiring a network connection (nudges, AI assistant, new registrations) will be unavailable offline.

12. Closing your account

Volunteers

12.1 You can delete your account at any time from the Settings screen (V10) in the app. This permanently removes all your personal data from PVG Pal. See our Privacy Policy for full details of what is deleted and what is retained (audit log entries only).

12.2 If you cannot access the app, email privacy@pvgpal.app and we will delete your account within 30 days.

Coordinators

12.3 To close a coordinator account and organisation, contact privacy@pvgpal.app. Because closing an organisation affects all linked volunteers, we will discuss timing with you before proceeding. Volunteers will be notified and given the opportunity to export their data or link to a new organisation.

12.4 Before closing, you should export your SG07 register and any reports you need to retain for your own records.

13. When we can suspend or terminate access

13.1 We may suspend or terminate your access to PVG Pal if:

(a) you breach these Terms of Service, the Data Processing Agreement, or our Acceptable Use policy;
(b) we are required to do so by law or by a court order;
(c) your use of PVG Pal poses a security risk to other users or to the platform;
(d) your subscription remains unpaid for more than 60 days after the grace period.

13.2 Where possible, we will give you reasonable notice before suspending or terminating your account, and will explain the reason. In urgent security situations, we may act immediately and notify you afterwards.

13.3 If your account is terminated, you may request an export of your data (SAR export) within 30 days. After 30 days, your data will be deleted in accordance with our retention policy.

14. Changes to these terms

14.1 We may update these Terms from time to time. If we make significant changes, we will notify you by email and/or push notification at least 30 days before the changes take effect.

14.2 Minor wording changes (typo corrections, formatting, updated contact details) may be made without advance notice. The current version is always available in the app settings and on our website.

14.3 If you do not agree with the updated Terms, you may close your account before the changes take effect. Continued use of PVG Pal after the effective date constitutes acceptance of the updated Terms.

15. Governing law and disputes

15.1 These Terms are governed by the laws of Scotland.

15.2 If a dispute arises, we encourage you to contact us first at support@pvgpal.app so we can try to resolve it informally.

15.3 If informal resolution is not possible, disputes will be subject to the exclusive jurisdiction of the Scottish courts.

15.4 Nothing in these Terms affects your statutory rights as a consumer under UK law.

16. How to contact us

General enquiries: support@pvgpal.app
Data protection: privacy@pvgpal.app
Website: www.pvgpal.app
Postal address: Hugh Mackenzie, trading as PVG Pal, Aberdeenshire, Scotland

PVG Pal — Terms of Service

Version 1.0 (Draft) — April 2026

Accessible from: Registration (V1b), Settings (V10 / C14), and pvgpal.app