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The app has no concept of direction or walls, only estimated distance from Bluetooth signal strength, so someone living downstairs could certainly trigger it.
One of the things it also relies on is how long you've been in contact with the same device/person, so if there's no one else that could apply to it's a reasonable bet it's them.
grams
Ive recevied an NHS notification to self isolate. Only outdoors activity has been shops (brief visits). Figure likely trigger is downstairs neighbours who have come down with Covid (was planning on acting as their personal shopper) but have avoided contact with them (we are on good terms) given potential for infection. Does anyone know if same building different floor is likely to trigger false NHS alert?