Privacy Policy (ChatGPT App)

Effective date: March 27, 2026
Provider: Spheric Admin Ltd ("we," "us," "our")
Contact: privacy.widgets@olutely.com
Product: "Tube Map" (the "App"), a ChatGPT app

1) Scope

This policy explains how we process data through the Tube Map App when it is used inside ChatGPT. The current App displays a zoomable London Underground map and a live summary of London Underground service disruptions. The current implementation includes a hosted MCP server, a widget delivered into ChatGPT, and a direct widget request to Transport for London's API for live service status. This policy covers Spheric Admin Ltd's processing through those components and related hosting, logging, and analytics systems. It does not replace OpenAI's policies for ChatGPT platform processing.

Current implementation summary:

  • Current tool name: london-underground.
  • Current tool input schema: {}. The tool does not require location, station name, journey details, free-text search, name, email address, phone number, or other user-supplied tool arguments.
  • Current tool result: a short assistant-only confirmation text plus empty structuredContent {} and empty response metadata {}.
  • Current widget behavior: the widget loads static assets from our widget host, reads runtime presentation values such as locale, theme, display mode, and limited device-platform information, and fetches live line-status data directly from https://api.tfl.gov.uk/Line/Mode/tube/Status?detail=true.
  • Current live status data displayed: line names, status severity values, status descriptions, optional disruption reasons, and an in-session refresh timestamp.

2) Data categories, purposes, recipients, retention, and controls

2.1 Tool invocation, MCP delivery data, logs, and analytics telemetry

What: The current tool itself has no user input fields, so you do not need to submit any tool arguments to use it. However, when ChatGPT invokes the tool or loads MCP resources, our hosted MCP path may process technical request data such as request path, timestamp, response status, duration, request IP address as seen by our host, user-agent/header data, MCP session IDs, JSON-RPC IDs, tool name, request bodies or params (currently including an empty tool argument object and MCP metadata), and an OpenAI subject identifier if the platform provides one in request metadata. The current server code also logs MCP request bodies to console and sends HTTP/MCP telemetry to Mixpanel's EU endpoint.
Why: To deliver the App, return the widget, operate and secure the service, diagnose errors, monitor reliability/performance, prevent abuse, and support analytics for the hosted MCP path.
Recipients: Our hosting, CDN, infrastructure, and logging providers acting on our behalf; OpenAI/ChatGPT as part of the tool invocation flow; personnel who need access for operational or security reasons; and Mixpanel using the EU Mixpanel endpoint when that hosted Express path is in use.
Retention by us: We do not use a separate application database to store user profiles or tool histories for this App. We aim to minimize operational logs and generally retain them for no longer than 30 days unless a longer period is reasonably necessary for security, abuse prevention, incident response, or legal obligation. Mixpanel telemetry is retained in our analytics workspace until deleted by us or removed by the applicable workspace retention setting.
Your controls: You can choose not to use the App. Because the current tool input is empty, you do not need to provide additional personal fields to invoke it. You can also manage ChatGPT account and conversation data through OpenAI controls and contact us with privacy requests.

2.2 Direct widget requests to our asset host and to Transport for London's API

What: When the widget loads, your browser or ChatGPT webview requests our widget assets such as HTML, JavaScript, CSS, and image files. The current widget also sends a direct GET request to Transport for London's API at https://api.tfl.gov.uk/Line/Mode/tube/Status?detail=true to obtain live line-status data. Those requests can expose technical web request data such as IP address, user agent, timestamp, requested URL, and other standard HTTP metadata to the recipient systems. The current TfL request does not include a user-supplied location, station, or free-text parameter. TfL's response currently includes line names, status severity values, status descriptions, and optional disruption reasons.
Why: To deliver the widget assets and retrieve live London Underground service status for display in the App.
Recipients: Our widget hosting/CDN providers, Transport for London and its hosting/infrastructure providers, OpenAI/ChatGPT's widget runtime, and network operators needed to route the requests.
Retention by us: We do not proxy the live TfL status request through our MCP server and do not maintain a separate database of TfL status responses for this App. Our hosting providers may retain standard access logs for asset delivery as described in section 2.1. We do not control how TfL or other third parties retain request data once it is sent to them.
Your controls: You can choose whether to open the App and whether to refresh the live status panel. If you do not want the widget runtime to contact TfL for live status, do not use or refresh the App.

2.3 In-session widget runtime and display state

What: Temporary in-session state used to render and operate the widget, such as map zoom level, pan offset, current display mode, loaded service-status results, refresh time, locale/language, theme, and limited device-platform information used for presentation adjustments. The current frontend may also fall back to browser language settings if host locale data is unavailable.
Why: To render the App in the right language and theme, support inline/picture-in-picture/fullscreen display modes, adapt the presentation for device context, and keep the current map/service-status view working during the session.
Recipients: Primarily OpenAI/ChatGPT and the widget runtime in your active session, plus your browser or webview environment. Under the current code, this session state is not intentionally written to a separate application database by us.
Retention by us: We do not intentionally store this in-session widget state in a separate app database. It is intended to exist mainly in active session/browser memory unless some portion later appears in operational logs described above or in a support request you send us.
Your controls: You can stop using the widget at any time, choose whether to refresh live data, and manage language/theme settings through your device, browser, or ChatGPT environment where available.

2.4 Contact data if you email us

What: Your email address and the contents of your message.
Why: To respond to privacy, support, or legal requests and maintain a record of the request.
Recipients: Spheric Admin Ltd and our email/service providers acting on our behalf.
Retention: Up to 24 months after final resolution unless a longer period is required by law or reasonably needed to establish, exercise, or defend legal claims.
Your controls: You choose what information to include in your message and may ask us to delete data we still hold, subject to legal limits.

3) What we do not do

  • No current tool input fields for names, email addresses, phone numbers, home/work addresses, station selections, free-form search text, or precise location.
  • No current structured tool output fields or returned response-metadata fields containing user profile, contact, or location data; current structuredContent and returned _meta are empty objects.
  • No account creation or sign-in through the current App.
  • No browser GPS request and no use of ChatGPT-provided openai/userLocation metadata in the current App.
  • No microphone, camera, contacts, or payment collection through the current App.
  • No intentional use of localStorage, sessionStorage, advertising SDKs, or cross-site tracking scripts in the current widget.
  • No sale of personal information.

4) Cookies and similar technologies

We do not intentionally set advertising or profiling cookies through Tube Map. ChatGPT/OpenAI, your browser, our hosting providers, and third-party services you contact through the widget may use their own operational cookies or similar technologies for platform operation, delivery, or security under their own policies.

5) Sharing and disclosure

We do not sell personal information. We may disclose data only as necessary to:

  • Operate, host, deliver, monitor, analyze, and secure the App through service providers such as hosting, CDN, infrastructure, logging, and analytics providers.
  • Retrieve live service-status data from Transport for London needed for the widget display.
  • Comply with law, regulation, legal process, or enforceable government request.
  • Protect the rights, safety, and security of users, us, and the service.

6) User rights and controls

Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, or object to processing of personal data we hold.

To exercise rights or ask questions, contact privacy.widgets@olutely.com. We may need to verify your identity before fulfilling a request.

Because Tube Map runs inside ChatGPT, you can also manage conversation and account data through OpenAI controls. OpenAI's privacy policy: https://openai.com/policies/privacy-policy.

7) International processing

The App may be accessed globally, and data may be processed in countries where we or our service providers operate. Where required, we use appropriate safeguards for international data transfers.

8) Security

We implement reasonable technical and organizational safeguards designed to protect data processed through the App. No system can guarantee absolute security.

9) Children's privacy

The App is not directed to children under 13 (or the minimum age required in your jurisdiction). We do not knowingly collect personal information from children.

10) ChatGPT / OpenAI platform notice

OpenAI independently processes chat content, account data, platform telemetry, in-session widget data, and related runtime information under its own terms and privacy practices. This policy describes Spheric Admin Ltd's processing through Tube Map only.

11) Changes to this policy

We may update this policy from time to time. If we make material changes, we will update the effective date above and ensure the policy continues to reflect the App's current tool inputs, outputs, metadata, and other disclosed data flows.

12) Contact

Questions about this policy or App privacy practices: privacy.widgets@olutely.com (Spheric Admin Ltd).