PRIVACY POLICY

INFORMATION WE COLLECT AND HOW WE USE IT

To identify you in the App system, you are required to enter your phone number. This processing of your phone number is necessary to form a contract with you (Terms of Use).

When you start using the App, we automatically collect the following data:

• Device Information: Information about your device, such as your IP address, brand and model of the device, time zone, general location, network settings, and other device-related data.
• Security Information: Battery status of your device and information about the App’s performance, including crash reports.
• Usage Data: Information on how you interact with the App, such as which features you use most frequently.

We use this information to provide you with the App’s functionalities and to improve its performance. This data processing is based on the necessity to fulfill our contract with you (Terms of Use).

When you create an account in the App, we process your account details, such as your email, phone number, name, and optional profile picture. If you log in using Google, Facebook, or similar accounts, we do not store the data from those accounts; instead, you voluntarily provide your email, name, and phone number, which are securely linked to your account in our database. This information is used to create your account in our system and is processed based on the necessity to fulfill our contract with you (Terms of Use).

Third-Party Account Integration
When you choose to log into our App using a third-party account such as Facebook or Google, we may receive certain information from that service to facilitate the login process. This information typically includes your name, email address, and profile picture. Please note that we do not store your login credentials from these third-party services. The use of your data from these third-party accounts is subject to their respective privacy policies. We encourage you to review these policies to understand how your information is handled.

When you add someone to your group or join a group, we process information about the groups you belong to, based on the performance of our contract with you (Terms of Use).

To provide the core functionality of the App, we need access to your precise location and movement history. Without this, providing the App’s main features will be impossible. We process your location data based on your consent. You can withdraw your consent at any time, but please note that doing so will prevent the App from functioning as intended.

When you use the “invite a user” feature, we may process the contact details of the person you invite, such as their phone number. Please ensure that you have a legal basis to provide us with such information.

When you use the chat feature within the App, we may process the data exchanged in the chat. This data is processed solely to provide the in-app chat functionality, based on the necessity to fulfill our contract with you (Terms of Use).

If a child is using the App, we process additional data necessary to verify the parent or other legal guardian who has provided the legally required consent under data protection laws. This data may include an identity document, a selfie, and any other data required by applicable law. We process this information based on legal requirements specifically for child data protection laws.

If you contact us with a support request, we process the data you provide in your request, such as your name (optional), email address, the nature of your request, and any attached files (if applicable). This data is processed based on our legitimate interest in providing you with support, balanced against your interest in receiving assistance.

When you make a payment for a subscription, your payment data, such as card information, is processed directly by the payment provider. This could be the app store if you pay through it or a third-party payment processor, as outlined below. We do not store your full payment details. However, for payments made through our website, we retain certain payment-related information (such as last 4 digits of your card and card brand) along with payment receipts (including the package name and the date and time of the purchase) to confirm your subscription status. This data is processed based on the necessity to fulfill our contract with you (Terms of Use).

We may use your email address to send you relevant information about our App based on your consent. You can opt out of receiving such emails at any time by following the unsubscribe link in the email.

We may use your data for advertising purposes and to analyze our marketing campaigns. We may share, or permit third-party ad networks, social media companies, and other third-party services to collect information about your use of the App over time, so that they may play or display ads relevant to your interests on the App and other websites, apps, or services. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google, and others.

These third-party ad partners may collect the following data:

• Device advertising identifier
• Data about your interactions with ads
• Usage Data

Your data is processed based on our legitimate interest, which seeks to balance our goal of enhancing the profitability of the App with your interest in keeping the App’s price stable. For advertising identifiers that enable data personalization, we obtain your consent.

DATA COLLECTION METHODS

To provide and improve our services, we collect data through several methods:

• Data You Provide: When you create an account or provide other information, such as when using in-app features like chat, we collect data directly from you. This includes your phone number, name, email address, and other details relevant to your account and profile.
• Data We Collect Automatically: Certain information is collected automatically when you use the App, including device information (e.g., IP address, device model, and network settings), usage data (e.g., app features you interact with), and security information (e.g., crash reports). We also collect device battery status to enhance functionality for your group members.
• Data Collected with Your Permission: We request access to certain data, such as precise location and movement history, essential for the App’s core features. You have control over these permissions and may withdraw consent anytime via your device settings. Note that certain functionalities may not work if permissions are withdrawn.
• Data from Third Parties: If you log in using third-party accounts, like Facebook or Google, we may receive basic profile information from these services, such as your name and email address, to facilitate account creation and login.

USE OF COOKIES

What Are Cookies?
Cookies are small text files that are stored on your device when you visit our App or website. These files are used to enhance your user experience, remember your preferences, and analyze your activity within the App or on our website. Cookies can be either session-based (temporary) or persistent (stored for a longer period).

Types of Cookies We Use
We use the following types of cookies:

• Essential Cookies: These cookies are necessary for the App or website to function properly. They enable core features such as security, login functionality, and preferences management.
• Functional Cookies: These cookies allow our App to remember certain user preferences, such as language or location, to provide a more personalized experience.
• Performance Cookies: These cookies help us analyze how users interact with our App or website. The data collected by these cookies is anonymous and used to improve the functionality and user experience of our service.
• Advertising Cookies: These cookies are used to deliver advertisements relevant to your interests. They may track your browsing behavior and allow third-party ad networks to display targeted ads. We may use this data to improve our marketing campaigns and display personalized ads both within the App and across other platforms.

Your Consent to Use Cookies
By using our App, you consent to the use of cookies as described in this Privacy Policy. For cookies that are not strictly necessary for the functioning of the App (such as advertising cookies), we will ask for your consent prior to their activation.

Managing Your Cookie Preferences
You can manage your cookie preferences at any time. Most devices and web browsers allow you to set preferences for cookies, including:

• Blocking cookies entirely.
• Allowing cookies only from specific sites.
• Deleting cookies after a session ends.

If you choose to block or delete cookies, some parts of the App or website may not function as intended, and you may experience limited access to certain features.

WITH WHOM WE CAN SHARE DATA

We may share your data with certain third parties to enhance our services and functionalities. Below are the purposes for sharing data and the corresponding third parties involved, along with information on how they protect your data:

Advertising and Analytics

• Facebook: We share data with Facebook to serve targeted advertisements and analyze advertising effectiveness. Facebook employs robust security measures, including encryption and access controls, to protect user data and privacy, as outlined in their Data Policy.
• AdMob: This service helps us serve ads within the App and track ad performance. Google, which owns AdMob, utilizes various security protocols, including encryption and compliance with GDPR and CCPA, to ensure data protection. More details can be found in the AdMob Privacy Policy.
• Appsflyer: We use Appsflyer for attribution purposes, allowing us to understand the effectiveness of our marketing campaigns. Appsflyer adheres to strict security standards, including GDPR compliance and data encryption, as detailed in their Privacy Policy.
• Amplitude: Data is shared with Amplitude to analyze user behavior and improve our App based on usage patterns. Amplitude ensures data security through encryption, regular security audits, and compliance with privacy regulations, as stated in their Privacy Policy.

Location Services

• Google: To enhance location-based functionalities within our App, we use Google Places to provide real-time information and location-related searches relevant to users. The App shares location data with Google, which applies strict security measures, such as encryption and robust access controls, to protect user information in alignment with Google's Privacy Policy.
• Trax: We integrate Trax to gather anonymized location data, which is used solely for analyzing aggregated, non-personally identifiable location usage patterns. This data helps us enhance our application’s features. For more information on how Trax handles data, please refer to their Privacy Policy.

Data Storage

• Firebase (Google LLC): Data is stored in Firebase for real-time database services and analytics. Firebase uses security measures such as data encryption, access controls, and compliance with GDPR to protect user data, as outlined in their Privacy Policy.

Log-in Features

• We may provide you with the option to log into our App using third-party accounts such as Facebook and Google. If you choose to utilize this feature, please be aware that you are granting us access to your data from the respective third-party account.

Groups and Members

• When you add someone to a group or join one, please be aware that certain information—such as your account details, device battery status, location, and movement history—will be shared with other group members. You can view the members of your groups and manage your participation directly within the App.

Payment Processing (for Web Users)

• Braintree: We share payment information with Braintree to process transactions. Braintree follows PCI DSS compliance and utilizes encryption and tokenization to protect payment data, as detailed in their Privacy Policy.
• Stripe: We share payment information with Stripe for processing payments. Stripe is committed to data security and adheres to PCI DSS standards, implementing encryption and secure data handling practices, as outlined in their Privacy Policy.

Emergency Services

• Telesign (SOS Calls): Data may be shared with Telesign to provide emergency calling features. Telesign implements industry-standard security practices, including data encryption and compliance with relevant data protection regulations, as outlined in their Privacy Policy.

Legal Obligations

• We may share your data with third parties if required to do so by applicable law, regulation, or legal request. This includes circumstances where we need to comply with a subpoena, court order, or other legal process, or to protect our rights, privacy, safety, or property, or that of our users or others.

INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to and stored on servers located outside your country of residence, including the United States, where we and our third-party service providers operate. These countries may not have the same data protection laws as your country of residence.

When we transfer data internationally, we take steps to protect your information in compliance with this Privacy Policy and applicable laws. These measures may include implementing Standard Contractual Clauses approved by relevant authorities or using other legally approved transfer mechanisms. If you have questions or need further information about international transfers, please contact us at designated support email.

DATA RETENTION POLICY

• Account-Related Data: We retain your personal data, including account details and app usage information, as long as your account is active. Upon account deletion, all data will be irreversibly erased from our systems, except in cases where extended retention is legally required or to comply with specific requests.
• General Data: Personal data that is no longer relevant or needed for our services will be deleted or anonymized within three years of your last activity, unless legal, security, or operational reasons require a longer retention period.
• Location Data: We retain a history of your movements for a period of two weeks.
• Third-Party Integrations: Data processed by third-party services (such as payment processors or analytics providers) is governed by their respective retention policies. We ensure that each service complies with our privacy standards.
• Exceptions for Legal Requirements: In cases where we are required by law to retain certain information beyond typical retention periods (e.g., regulatory compliance, legal claims, audits), we will securely store the relevant data as needed.

CHILDREN’S DATA POLICY

Our App is designed primarily for users aged 13 and older in the US and 16 and older in the EU, in line with data protection regulations. If a child under the age of 13 (in the US) or 16 (in the EU) wishes to use the App, they may do so only with the consent of a parent or legal guardian. If you become aware that someone under these age limits is using the App without the required parental consent, please inform us using the contact information provided in our Privacy Policy.

Parental Consent

If you are a parent or legal guardian, you can grant consent for your child’s use of the App by creating an account on their behalf. To do this, please follow the consent procedures outlined within the App during the account setup process. We may collect certain data based on the method you choose, such as a document, a selfie, and any other information required by applicable law. This data is used solely for the purpose of verifying your identity in compliance with legal requirements.

Data Usage

We use children’s data strictly for App functionalities and do not use it for advertising purposes. This includes tracking the child’s location, facilitating communication within designated group chats, and other functionalities essential for the App's operation. By consenting to your child’s use of the App, you agree to the data processing methods outlined here, which may be subject to change as we update our services to improve user experience.

Rights and Responsibilities of Parents and Guardians

As a parent or legal guardian, you are responsible for monitoring and managing your child’s activities within the App. The App provides tools for parents and guardians to view and adjust their child’s location-sharing and other privacy settings to help protect your child’s privacy and control their interactions within the App. Additionally, you may request deletion or updates to your child’s data by contacting our support team.

USER RIGHTS REGARDING YOUR DATA

You have specific rights concerning your personal data. We are committed to ensuring that you are informed about these rights and how you can exercise them:

• Right to Access: You have the right to request information about the personal data we hold about you. This includes the ability to see what data has been collected and how it is being used.
• Right to Rectification: You can amend certain personal data associated with your account if it is inaccurate or incomplete. This ensures that your information is up to date.
• Right to Erasure: You can request the deletion of your account and all associated personal data. Upon doing so, we will permanently remove your information from our systems.
• Right to Restrict Processing: In certain circumstances, you can request that we limit the processing of your personal data. This may apply if you contest the accuracy of the data or if the processing is unlawful.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format. You may also transmit this data to another service provider, where feasible.
• Right to Object: You can object to the processing of your personal data at any time, especially if it is based on legitimate interests or used for direct marketing purposes.

Exercising Your Rights

To exercise any of these rights, please log into your account and navigate to the account settings to make the necessary changes or to delete your account. If you need further assistance, feel free to contact our support team at help@family-locator.com. Please note that removing the App from your mobile device will not delete your personal information.

We aim to respond to all legitimate requests within one month. If your request is particularly complex or if you have made numerous requests, this period may be extended by two additional months.

California Consumer Privacy Act (CCPA) Notice

As a California resident, you have the following rights:

• Right to Know: You may request information about the categories and specific pieces of personal data we collect about you, as well as the purposes for which we collect and use this data.
• Right to Delete: You can request that we delete any personal data we have collected from you, subject to certain exceptions as permitted by law.
• Right to Opt-Out: You have the right to opt-out of the sale of your personal data to third parties. Please note that we do not sell any personal data.
• Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of your rights under the CCPA.

Exercising Your Rights

To exercise your rights under the CCPA, please submit a request by contacting us at help@family-locator.com. We will respond to your request within 45 days in accordance with the CCPA.

DATA SECURITY MEASURES

We implement robust security measures to protect your personal data, adhering to industry standards. This includes encrypting location-based data and using secure transmission protocols to ensure data integrity during transfer.

While we take significant steps to safeguard your information, it is essential to recognize that no system is completely impervious to breaches. In the event that any information under our control is compromised due to a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised, and take other steps in accordance with applicable laws and regulations.

Users are equally responsible for maintaining the security of their accounts. This includes safeguarding their login credentials, choosing strong passwords, and ensuring the security of their devices. We strongly recommend that users regularly update their passwords and refrain from sharing their account details with others to mitigate potential security risks.

CHANGES

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When changes are made, we will revise the “Last Updated” date at the top of this policy and notify you through the App or other means, as appropriate.

Your continued use of the App after changes are posted signifies your acceptance of these changes. We encourage you to periodically review this policy to stay informed about our information practices and your rights.

For substantial changes that affect your rights, we will provide you with more prominent notice, such as an email or a notification within the App, to ensure you are aware of the updates.