Privacy Policy

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I. INTRODUCTION

Thien Ly (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you use our iOS mobile application (the “App”, “our App”) and explains how we and some of the companies we cooperate with process that information.

When we refer to personal data (or personal information) we mean any information of any kind relating to an identified or identifiable natural person.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

Our Privacy policy applies to all users, and others who access the App (“Users”).

For the purposes of the GDPR, we are the data controller.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS. BY ACCESSING OR USING THE APP, YOU AGREE TO PROCESSING OF YOUR PERSONAL DATA WHICH IS PROVIDED TO US IN LINE WITH THE TERMS OF THIS PRIVACY POLICY.

II. INFORMATION WE PROCESS

There are two general categories of information we can process.

1.1 Information that you submit

We ask for and collect the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.

  • Authorization and/or Account Information. When you sign up for an account, we require certain information such as your email address or Apple ID / Sign in with Apple credentials - depending on the App settings.
  • Precise and Background Location Data. Because the core feature of our App is location sharing, we request access to your device's precise geolocation data. If you grant "Always Allow" permissions, we will collect your location in the background even when the App is closed or not in use. This is strictly necessary to enable core features like updating your chosen contacts on your whereabouts, sending geofence alerts (e.g., arriving at a "Place"), and detecting driving motion.
  • Device Sensor Data (Apple CoreMotion & Battery Status). To enhance the location-sharing experience, the App utilizes iOS sensor frameworks to collect battery level status and motion activity data (e.g., fitness and motion frameworks detecting if you are walking or driving) to accurately update your authorized contacts and trigger driving notifications.
  • Content Information. Photos, pictures, or other custom assets that you select and upload inside the App to customize your user profile or group places.

1.2 Information That Is Processed Automatically

When you use the App, some information about your device and your user behaviour may be processed automatically. This information is generally non-personal, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. Otherwise we may not be able to provide you with all the requested services and features of the App.

We use third-party automatic data processing technologies (such as Google services and Mixpanel) to analyze certain information sent by your iOS device or our App. Automatic data processing technologies (advertising or analytics tools) provide us with the data described below. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

  • Device identifiers. When you use an Apple iOS device (an iPad or an iPhone) to access our App, we may access, collect or monitor one or more “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. Device identifiers provide reports or personalized content and ads.

    What data can be processed:

    1. Type of your Apple device and iOS operational system version which is installed on your mobile device;
    2. Region information of your mobile device;
    3. Internet Protocol (“IP”) address;
    4. Advertising identifiers (such as the Apple IDFA) which are strings of numbers and letters that identify your individual smartphone or tablet.
  • Cookies and similar technologies. When you use the App, we may use local storage, temporary identifiers, and similar technologies like pixels, web beacons, and scripts to collect information about how you use our App and provide features to you. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you.
  • Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.

    Processing information through automatic data processing technologies starts automatically when you start using the App, subject to your applicable consent choices via Apple's App Tracking Transparency (ATT) framework and Google User Messaging Platform.

    The App may use automated processing of your personal data, including profiling which means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a) To make our service available. We use information that you submit and information that is processed automatically to provide you with all requested location-tracking and safety services.

(b) To improve, test and monitor the effectiveness of our App. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

(c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.

(d) To communicate with you. We use the information we have to communicate with you, to send you operational notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

(e) To prevent fraud and spam, to enforce of law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy.

4.1 Sharing with Other Users

The primary purpose of the App is to share your live location and device status (like battery level) with people you trust. Your precise location data, places visited, and driving status are only shared with the specific contacts you explicitly invite and authorize within the App. We do not make your location publicly accessible, and we never sell your precise location history to third-party data brokers.

4.2 Third-Party Providers and Systems

We will not rent or sell your personal data to third parties, but we may share your information from tools like local identifiers, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may also share certain information such as device advertising data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

We may use one or more of the following third-party services and tools: Apple SearchAds; Google Mobile Ads (AdMob); Firebase; CoreLocation Framework; Apple Maps; Crashlytics; Qonversion; RevenueCat; Mixpanel; Appfigures. In case you want to learn more about the services and privacy options please consult their websites and privacy policies.

Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices or the content of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it needed for objective reasons, due to public interest or in other unforeseen circumstances:

  • as required by law;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to an Apple ecosystem or government request;
  • if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We work in the international space and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

For the purposes of data storage, we recourse to the services of secure cloud hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

Location History: We minimize the storage of your highly sensitive location data. Routine location coordinate history is routinely overwritten or deleted from our active servers after a limited period, retaining only what is necessary to display your recent history to your authorized contacts.

Some basic account data may still be stored for a certain time period if information is necessary to comply with legal obligations (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

VII. EXERCISING YOUR RIGHTS & CONSENT

For the data we store and access you are entitled to address us regarding the following issues:

  • Data Access and Portability. You can request copies of your personal information held by us.
  • Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask us to correct change, update or rectify your data.
  • Data Retention and Deletion. We generally retain data for as long as your account is in existence or as needed to provide the App. However, specific retention times can vary based on context of the processing we perform and on our legal obligations. You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also delete your account at any time. We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, or where we have a legitimate interest in doing so (e.g. to prevent fraud and abuse and maintain and enhance security).
  • Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which we use your personal information.

Please bear in mind that we ensure the above mentioned rights only with respect to the information that you submit.

7.1 Managing Advertising & Tracking Preferences

iOS Device Tracking Permissions: We utilize Apple's native App Tracking Transparency (ATT) framework to request your explicit permission before tracking your activity across other companies’ apps and websites for targeted advertising purposes. You can modify your tracking preferences at any time within your iPhone or iPad system settings by navigating to Settings -> Privacy & Security -> Tracking.

European Privacy Rights (GDPR & UK GDPR): If you are located in the European Economic Area (EEA) or the United Kingdom, we are committed to complying with applicable data protection requirements regarding the collection of personal data and the serving of personalized advertisements. You have the right to withdraw your consent, limit data collection, or object to processing at any time. You can easily manage these preferences directly within the App by navigating to Settings and tapping "Privacy Choices", adjusting your iOS tracking settings, or by contacting us directly.

7.2 US Regional Privacy Rights

Residents of certain US States (including California, Virginia, Colorado, Connecticut, and Utah) are granted specific rights regarding their personal information.

Do Not Sell or Share My Personal Information: We do not sell your personal data for money. However, we may share certain device identifiers and usage data with third-party advertising partners to provide you with personalized ads. Under laws like the California Privacy Rights Act (CPRA), this may be considered a "sale" or "sharing" of data. You have the right to opt-out of this sharing. You can exercise this right at any time by navigating to the App's Settings menu and tapping the "Privacy Choices" button, by adjusting your system privacy settings, or by contacting us directly.

To submit a formal request regarding your state-specific rights, please contact us through the email displayed below. When submitting such a request, please include the wording "Your rights to maintain confidentiality in [Your State]", as well as your name, address, city, state, and zip code. You must provide sufficient information so that we can verify your residency and process your request.

VIII. SECURITY

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about security of our App, you can contact us at through the email displayed below.

IX. CHILDREN’S PRIVACY

We are committed to protecting the privacy of children and complying with laws such as the Children's Online Privacy Protection Act (COPPA) in the United States and the General Data Protection Regulation (GDPR-K) in the European Union.

When accessing our App, we utilize age-screening mechanisms. For users who identify as being under the age of digital consent in their region (e.g., under 13 in the US, or under 16 in certain EU countries), we apply strict data limitations. We do not prompt these users for tracking consent, we do not access or collect Apple device advertising identifiers (IDFA), and we configure our third-party advertising partners to serve only non-personalized, general-audience advertisements. We also restrict certain data collection practices for teenagers (e.g., users aged 13 to 17) where required by applicable local laws.

If we learn that we have inadvertently collected personal data from a child under the applicable age of consent without verifiable parental consent—outside of the strict, limited use-cases permitted by law—we will erase that information as quickly as possible. If you believe that we might have any unauthorized information from or about a child, please contact us immediately.

X. CHANGES TO THE PRIVACY POLICY

This Privacy policy may change from time to time.

Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

XI. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us at privacy@sharelocation.app.