GPS Tracker & Location Tracker Privacy Policy (Revised Version)

Effective Date: December 10, 2025

Thank you for choosing "GPS Tracker & Location Tracker" (hereinafter referred to as "this app").

We highly value your personal data privacy and security, especially sensitive data related to real-time location information. This Privacy Policy details how this application collects, uses, shares, stores, and protects your personal information, as well as the legal rights you have over this data.

The core function of this application is to achieve mutual location tracking and safety assurance through the friends you actively select and bind . We promise that without your and/or the tracked user's explicit consent, we will never proactively share your real-time location with any unbound or unauthorized third parties.

Before registering or using this application, please carefully read and understand this policy. By accessing, registering for, or using this application, you indicate that you have read, understood, and accepted all the terms and practices described herein.

We are committed to complying with data protection standards globally, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act/California Privacy Rights Act (CCPA/CPRA), etc., to ensure that your personal information is processed legally, properly, and securely.

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1. Information and Contact Details of the Data Controller

This application is operated and controlled by the following entities:

Category	Detailed Information
Company Name	NAICOO PTE. LTD.
Registered Address	60 PAYA LEBAR ROAD #05-39 PAYA LEBAR SQUARE - 409051
Data Protection Contact Email	[email protected]

If you have any questions, exercise rights, or file a complaint regarding personal information processing, please contact us via the above email address.

Tip: It is a professional practice to use a dedicated rather than a personal email address as the data protection contact email. Otherwise, regulatory authorities may consider that the data controller has not established a formal privacy management process.

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2. Information We Collect

To provide the core "Friend Location and Tracking" feature of this app, maintain service stability, and enhance User Experience, we only collect the information necessary to achieve these purposes and have clearly defined the legal basis for collection and processing.

1. Information required for core functions (location services)

Data Category	Specific Information	Collection Purpose	Legal Basis (GDPR)
Real-time location data	Precise geographical location information provided by GPS, Wi-Fi, or cellular networks (including latitude, longitude, timestamp, and moving speed).	Allows you to track each other with your bound friends, enabling the core safety location service. Your location is only shared with users you have explicitly consented to bind with.	Process sensitive geolocation data based on the "explicit consent" (GDPR Article 9(2)(a)) of you and your friends to fulfill the contract regarding the use of location services between you and your friends (GDPR Article 6(1)(b)).
Device Identifier	Device ID (e.g., Android ID, IDFA), device model, operating system version.	is used to technically identify your and your friends' devices, ensuring that your location data can be accurately matched and only transmitted to the friends you have authorized to bind, and enabling relevant status notifications and reminders.	It is necessary for the performance of the service contract with you (Article 6(1)(b) of the GDPR). Without this information, we cannot create a secure account for you or accurately transmit location data to the friends you have specified.
Mobile Number/Contact Information	Contact information you voluntarily choose to fill in (used for registration, account recovery, and inviting friends).	It facilitates your selection and invitation of friends for binding, establishing a positioning relationship.

2. Application Usage Information

Data Category	Specific Information	Collection Purpose	Legal Basis (GDPR)
App Usage Data	Function usage frequency (e.g., viewing maps, setting safety zones), in-app setting change records.	Understand the usage patterns of features, and continuously improve the User Interface and User Experience.	The legal basis for processing such information is our legitimate interests (Article 6(1)(f)), namely maintaining and improving the security, stability, and user experience of the service. We have ensured that it does not affect your rights and freedoms.
Diagnostic and Crash Data	Anonymous crash logs (not containing personal information), performance data.	Timely detect and fix software errors to improve application performance and stability.

3. Optional Information

We will collect this information voluntarily provided by you only after obtaining your explicit consent :

• Feedback or problem descriptions submitted through the "Feedback" feature;
• Responses to optional surveys (e.g., satisfaction ratings, feature suggestions).

4. Juvenile Protection and Age Threshold

This application is not intended for juveniles under 16 years old.

• We will not intentionally collect any personal information from individuals under 16 years of age.
• When registering, you need to undergo age verification. If you are under 16 years old, you will not be able to use any features of this service. If we inadvertently collect data from individuals under 16 years old, we will immediately terminate the service and delete all relevant information within seven (7) working days.
• If you are a parent or guardian and learn that your child has provided us with information without your consent, please contact us immediately through the contact information provided in this policy. We will promptly fulfill the above deletion obligation after verifying your identity.

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3. How We Use Your Information

We strictly adhere to the principles of purpose limitation and data minimization, and process your information based on legitimate legal grounds.

1. Provide core positioning services

This is the core purpose of fulfilling the service agreement with you:

• Real-time location sharing: Transmit your real-time geographical location information to friends or family members who have explicitly consented to binding and authorization, in order to achieve secure tracking and location services.
• Safe Zone Alert: Allows you to set up geo fencing (such as "Safe Zone") and trigger automatic notifications or alerts based on your settings when you or a tracked friend enters or exits the area.
• Notification Service: Sends important notifications such as location updates, battery status, or help requests.

2. Strictly restricted use of sensitive data (precise geographical location)

We are well aware that real-time precise geographical locationfalls undersensitive data. We promise that its use will be strictly limited to the following methods and scope:

• Strictly limited to core services: Only used to implement the core positioning and security functions described in Article 1 above between you and specific friends.
• Never Used for Non-Essential Purposes: We will never use real-time precise geolocation for targeted advertising, marketing, or any analytical purposes unrelated to core security services without your explicit secondary consent.

3. Improve and optimize services

To continuously improve service quality and security, on the premise that your personal data has been anonymized or aggregated (i.e., cannot identify a specific individual), we may use it for:

• Performance Improvement: Utilize device parameters, location data statistics (after anonymization) and error logs to fix compatibility issues and improve the accuracy and stability of location updates.
• Function Development: Analyze usage data, develop and optimize new features (e.g., route history query, travel time estimation).

4. Customer Support

When you contact us via email for assistance, we will use the device and usage information you provide to efficiently diagnose and resolve issues.

5. Fulfilling legal obligations and protecting legitimate rights and interests

We may use your information within the necessary limits to:

• Comply with legal obligations: Respond to valid legal processes, such as court orders or government requests.
• Protecting significant interests: Taking necessary actions to protect the personal safety of you, other users, or the public (such as responding to emergency requests for assistance).
• Exercise legal rights: To identify, prevent, or address fraud, abuse, security breaches, and other behaviors in order to protect our and users' legitimate rights and interests.

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4. Data Sharing and Transmission Rules

We strictly adhere to the principles of data minimization, purpose limitation, and confidentiality obligations. We will never sell or rent your personal information for marketing purposes.

Your data will only be shared or transferred under the following circumstances:

1. Location Data Sharing (Core Service)

• Shared only with bound users: Your real-time location data will only be shared with those users whom you have actively initiated a binding with and received their acceptance (or those whose invitations you have accepted). This is a core feature of this application.

2. With third-party service providers

We may share information with third-party partners providing technical support. We have signed data processing and Non Disclosure Agreements, which require:

• Data is processed only in accordance with our instructions and shall not be used for its own purposes;
• The strictness of data protection measures is not lower than ours;
• Data transmission shall not be carried out without consent or legal requirement.

Common scenarios include:

• Managed Service Provider: Access anonymous devices and use data to maintain server stability (e.g., load balance).
• Analytics Service Provider: Access non-identifiable usage Statistical Data to generate performance reports and support optimization.

3. International Data Transmission

Our service providers operate globally. This means that your personal information may be transferred outside your country/region for processing, including to countries outside the European Economic Area (EEA), the United Kingdom, or California.

We ensure that all such transfers are protected by appropriate legal safeguards to meet the legal requirements of the data source. These safeguards include:

• For transfers originating from the EEA and the United Kingdom, we primarily rely on the Standard Contractual Clauses (SCCs) approved by the European Commission and the Information Commissioner's Office.
• For other cross-border transfers involving personal data, we rely on legal mechanisms such as binding contractual obligations and adequacy determinations of the data receiving jurisdiction.
• You can obtain more information about these safeguards by contacting us.

4. Regarding "Sale"/"Sharing" under CCPA

• We will not "sell" your personal information for monetary consideration. However, under the broad definitions of CCPA/CPRA, our data arrangements with certain analytics service providers may be considered "sharing" for "cross-context behavioral advertising".
• California consumers have the right to opt out of such "sharing." You may exercise this right through the "Do Not Sell or Share My Personal Information" link provided on our website's homepage and in the app settings.

Legal Statement and Mandatory Disclosure

We may disclose information to the competent authorities under the following legal conditions:

• Comply with applicable laws, regulations, or government orders;
• Respond to requests from legitimate investigations or government agencies (such as law enforcement agencies, regulatory authorities);
• Protect applications, users, or public interests (e.g., handling suspected fraud or cybersecurity threats).

5. Business Transfer

In the event of a merger, acquisition, or asset sale, your personal data may be transferred as part of the transaction. We will require the successor entity to continue to comply with this Privacy Policy. If there are significant policy changes, we will notify you and obtain your consent.

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5. Your legal rights

We are committed to safeguarding your control over personal information. The following rights apply based on your place of residence:

1. Basic rights (applicable to all users)

Regardless of where you are, you can directly exercise the following control rights through the product:

• Manage location sharing: within the app, you can individually pause sharing or completely unbind for any friend at any time, and this operation takes effect immediately.
• Delete historical data: You can clear all historical location records with a single click in "Settings".
• Account Cancellation: Deletes your account and all associated personal data. This action will also synchronously unbind your relationships with all friends.
• Contact us: Feel free to communicate with us regarding privacy issues [email protected].

2. Rights Based on the California Consumer Privacy Act (CPRA) Additional Rights for California Residents (CCPA/CPRA)

If you are a resident of California, you have the following statutory rights:

• Right to be informed: Know the categories and details of personal information we collect, use, disclose, and "sell"/"share".
• Right of access: Obtain a copy of specific personal information we have collected about you.
• Right to erasure: Request the deletion of personal information we have collected from you (subject to legal exceptions).
• Right of rectification: Request the correction of inaccurate personal information.
• Opt-out Right: To optimize your experience, we share some information with our partners, which may constitute a 'sharing' activity under CCPA/CPRA. You have the right to opt out of such data sharing through the 'Do Not Sell or Share My Personal Information' link on our website and app.
• Restricted right of use for sensitive information: Restricts our use of your sensitive personal information, such as precise geographical location, to only the necessary purposes for providing services.
• Right to non-discrimination: Your exercise of rights will not result in differential treatment or charges for services.

3. Rights Based on the EU General Data Protection Regulation (GDPR) Additional Rights for EU Residents (GDPR)

If you are a resident of the European Economic Area (EEA) or the United Kingdom, you have the following legal rights:

• Right of access: Obtain a copy of your personal data held by us.
• Right of rectification: Request the correction of inaccurate or incomplete personal data.
• Right to erasure (right to be forgotten): Request the deletion of your personal data (in cases where the data is no longer necessary, you withdraw your consent, etc.).
• Right to restrict processing: In specific circumstances (such as disputes over data accuracy), request the temporary suspension of processing your data.
• Right to data portability: Obtain the data you have actively provided in a structured, common format and transfer it to other service providers.
• Right of objection: Based on your special circumstances, object to our processing of your data on the basis of "legitimate interests".
• Right to withdraw consent: You may withdraw at any time any consent you have given to us. Withdrawing consent will affect the relevant functions that rely on such consent:

    ⚪︎ Core Function Consent: If you need to revoke consent for sharing your location with a specific friend, please unbind from that friend within the app.

    ⚪︎ System Permission Consent: If you need to revoke system permissions such as device location and photo album, please manage them in the system settings of your device, but this may cause the relevant functions to become unavailable.

    ⚪︎ Other Marketing Consent: If you need to manage your consent for marketing notifications, please manage your preferences in the app settings.

• Right to lodge a complaint with a supervisory authority: lodge a complaint with the data protection authority in your place of residence.

4. How to exercise your rights

• Exercise Requirements: Requests to exercise these rights must be verifiable. We may ask you to provide information to confirm your identity to protect the security of your data.
• Contact Information: You may exercise your rights by sending an email to our Data Protection Officer:

    ⚪︎ Email Address: [email protected]

    ⚪︎ Toll-free number:

Tip: CCPA mandates that enterprises must provide at least two rights request channels, one of which is a toll-free phone number, with only a very small number of "purely online" enterprises being exceptions. For high-risk applications that process real-time location, it is more prudent to add a toll-free phone number as a rights exercise channel. Please decide based on your business situation.

• Email Subject: Please use "Rights Request + [Specific Request]".
• Response Time Limit: We will respond to your request within the statutory time limit ( usually 30-45 days after receiving a verifiable request ), in accordance with applicable law in your area.
• Non-discrimination: We will not discriminate against you or provide differential services because you exercise your legitimate rights.

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6. Data Retention

We retain your personal information only for the shortest necessary period required to achieve the purpose, strictly adhering to the principle of data minimization:

Data Category	Retention Period Standard	Description
Real-time location data (sensitive)	Real-time location: Temporary cache, retained for no more than 7 days. Historical records: By default, they are retained for 30 days and will be automatically deleted upon expiration.
Device and Usage Data	Retained during your use of the service. After the account is cancelled, the data will be deleted after 30 days.
Feedback and survey data	Delete after the problem is resolved or the analysis is completed6 months.	For subsequent reference and improvement.
Data required by law	Retain until the expiration of the legal time limit.	For example, compliance, tax, or litigation hold requirements.

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7. Legal Basis for Processing

Under applicable laws, we process your personal data on the following legal bases (see Part II for details):

1. Agree: For optional data and sensitive data (e.g., precise location, feedback, analytical recommendations).
2. Contract Performance: To perform the service agreement with you (e.g., providing core positioning functions).
3. Legitimate Interests: To ensure safety and service integrity without compromising your privacy (e.g., fraud prevention, error correction).
4. Legal Obligations: To comply with applicable laws (e.g., in response to government requests).

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8. Information Security Measures

We implement technical, administrative, and physical safeguards to protect your personal data from unauthorized access, use, or disclosure:

1. Technical Measures:

• Encrypted data transmission (TLS/SSL);
• Encrypted storage of sensitive data (such as location data, device ID);
• Regular vulnerability scanning (at least once a quarter).

2. Management Measures:

• Access Control: Only authorized employees with legitimate work purposes are permitted to access data;
• Employee Training: Conduct regular Security Training and sign confidentiality commitment letters.

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9. Third-Party Services

This application may integrate limited third-party modules to implement auxiliary functions. These service providers process data in accordance with their own privacy policies. Although we will carefully select such partners and require them to comply with data protection standards, we cannot directly control or be responsible for their actions. We recommend that you review:

• Analytics Services: For example, Google Analytics (collects anonymous usage data). Privacy Policy:https://policies.google.com/privacy
• Advertising Services: For example, AdMob. Privacy Policy:https://policies.google.com/privacy

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10. Update of this Policy

We may update this Privacy Policy in the following circumstances:

1. Changes in laws and regulations (e.g., the entry into force of a new privacy law);
2. Major modifications to application functions or data processing methods;
3. Improvement of privacy protection standards or user expectations.

• Non-substantive Changes: For non-substantive changes that do not affect user rights and data processing methods, we will update the Privacy Policy page and modify the "Effective Date".
• Material Changes: For material changes involving user rights, data collection scope, or the introduction of new third parties, we will notify you in a prominent manner (e.g., in-app pop-up or email) and, if necessary, obtain your explicit consent again.

Continuing to use this application after the update indicates that you accept the revised policy.

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11. Contact Information

If you have any questions, feedback, or complaints regarding this Privacy Policy, please contact us via the following methods:

• Email: [email protected]

We will respond within the statutory time limit in accordance with applicable laws after receiving your inquiry.