Privacy at FamiloApp

• FamiloApp is one of the world's best apps in terms of privacy of your data
• We comply with the German Bundesdatenschutzgesetz (BDSG) as well as the EU General Data Protection Regulation (GDPR)
• You can use pseudonym in FamiloApp
• You can delete your FamiloApp account at any time or contact us to get your personal data deleted
• All data and permissions processed by FamiloApp follow the clear purpose to enable a specific feature of the app
• Your data is not processed for third-party advertising purposes
• If you limit your location mode ( "Places only" or "Invisible"), your location will only be transmitted according to the selected mode
• User-generated content (such as text, images, audio, or video) within FamiloApp is never shared outside your group
• We take all available measures to ensure the security of the app and data transmission and our servers
• Your data will be transferred with TLS/SSL encryption

This privacy policy applies specifically to the FamiloApp smartphone app. If some content applies to our website www.familo.net we will specifically point that out.

When collecting, processing and storing your personal data, we comply with the legal requirements in Germany and the European Union. These can be found in the Bundesdatenschutzgesetz (BDSG) and the Telemediengesetz (TMG) as well as in the EU General Data Protection Regulation (GDPR).

When you use our app, we may collect and process the following data:

1. Registration Data:

• Mobile phone number (MSISDN)
• Username (a pseudonym may be used)
• Email address (optional)
• Gender (optional)
• Date of birth (optional)

Purpose: To create and manage your account and provide access to our app's core functionalities.
Data Retention: Stored until account deletion.

2. Data Collected During App Usage:
Device and Network Information

• IP address
• Device information (includes brand, model, time zone, general location, battery status)
• Device settings and network carrier

Purpose: To ensure the app functions properly across various devices, enhance security, and troubleshoot technical issues. Please note that your IP address stored in server logs for security purposes only.
Data Retention: Stored until account deletion. Device settings and network carrier information are cached temporarily, retaining only the most recent state, no permanent storage is involved.

Location Data:

• Location data: Your real-time precise location.

Purpose: To provide real-time location-based services, a core feature of FamiloApp.
Data Retention: Stored for up to 2 weeks.

Usage Content:

• Usage data: Includes messages, alerts, pictures.

Purpose: To support in-app features and facilitate user interactions.
Data Retention: Only the most recent 300 activities per user group are stored.

Contacts:

• Phone contacts: Processed but not saved; hashed to ensure privacy, so we can only identify contacts who are also registered on FamiloApp.

Purpose: To identify other users on FamiloApp who are in your phone book.

Purchase Information:

• Purchase receipts: For in-app purchases; stored until account deletion.

Purpose: To manage subscriptions.
Data Retention: Stored until account deletion.

3. Support Request Data:

• When you contact us for support, we process information you provide, such as your name(optional), email address, the nature of your request.

Purpose: To assist you and address your concerns effectively.
Data Retention: Stored within three years.

4. Data Collected Through Third-Party Services:

• When you log into FamiloApp using a third-party account, we may receive specific information from that service to facilitate login, such as your name, email address, and profile picture.

Purpose: To facilitate login and personalize your FamiloApp account.
Data Retention: Stored until account deletion.

Please also see section Improvement of our service by collecting statistical data values for the information about how we use statistical data for the improvement of our service.

Data Retention and Deletion Policy

• The retention periods for specific data categories are outlined above However, if you do not delete your account, we will automatically delete or anonymize your data three years after your last account login, in compliance with our data retention policies.
• In certain cases, we may retain your data for a longer period if required by law, regulatory requirements, or legitimate business interests (e.g., for accounting, tax obligations, or to resolve disputes, enforce agreements, or ensure security).

All permissions requested by the app serve the purpose to provide you a specific feature within the app.

Permissions on Android devices:

In-app purchases: To make in-app purchases of premium features available
Identity: Management of the FamiloApp user accounts
Contacts: To add other people to your group
Location: To share your location with your group members
SMS: To send invitation SMS to your group members
Photos: To send pictures and create your profile image
WiFi: Information about whether you have an active Internet connection
Device ID: To verify your phone number when registering

Permissions on iOS devices:

Camera / Photos: To send pictures and create your profile image
Microphone: To send voice messages to your group members
Contacts: To add other people to your group
Location: To share your location with your group members
Notifications: To send automatic alerts when someone arrives at a location or sends a message
Background Updates: Update your location even when the app is not running in the foreground
Mobile data: To transmit messages, images and location

We process your personal data primarily based on the contract (General Terms and Conditions) between us and you (Art. 6(1)(b) of GDPR).

We ask for your explicit consent to collect and process your location data. This consent is voluntary, and you can withdraw it at any time by adjusting your location settings in your phone. However, please note that if you withdraw consent for location data processing, certain core functionalities of the app, such as real-time location sharing, may be limited.

We do not use profiling or automated decision-making that would significantly affect users' rights. The app allows users to create profiles, add family members, and track their locations, but it does not involve automatic analysis or decision-making based on this data.

We also want to share a few important details about how we use your data:

• Before registration, you can review our General Terms and Conditions and this Privacy Policy. You can access and read them directly from the registration screen. After registration, you can return to the General Terms and Conditions and Privacy Policy anytime within the app, on our website or our app store page.
• The manually entered data (mobile number, username) are required to enable the use of the app and its features. The optional input of additional data (e-mail address, gender and birthdate) improves the user experience of the app for you.
• You can use FamiloApp by entering a pseudonym. There is no need to enter your real name in the app.
• For the app and all of its features to work properly, automatic collection and use of Device and Network Information is required during sessions (see section "What kind of data do we collect?").
• Your user account is created using a randomized user ID (technically as 12-byte ObjectId value). We use this account to authenticate users and ensure system security for example.
• After you granted us access to your address book, we will propose contacts to connect with, which are also registered on FamiloApp. You can connect with others and share content with them within FamiloApp. The contacts in your address book will be processed but not stored. Through so-called hashing, we can not see any specific contacts on the server side, unless they are also registered on FamiloApp.
• All data is collected and processed by us in the minimum necessity to guarantee the functionality of the app.
• Our users expect high accuracy for location-based features, and we provide this to deliver the best possible experience. However, if you choose a less accurate location mode, such as "Places only" or "Invisible," we do not continuously track your location. Instead, your location is only detected when necessary for these specific features and is not stored permanently.
• By offering personalized and prominent adjustable location modes for users we follow the "privacy by design" principle.
• User-generated content (such as text, images, audio, or video) within FamiloApp is never shared outside your group.
• Your data is not processed for third-party advertising purposes.
• The collection and processing of your payment data for billing purposes will not be handled by us directly. It will be processed by third-party payment providers who manage payment transactions securely on our behalf.

To continually improve FamiloApp's features and user experience, we rely on a variety of third-party services, analytics, location, mapping, cloud storage, and more. These services help enhance app performance and user engagement. We ensure all third-party providers adhere to strict data protection agreements regarding the access, storage, and processing of your data. Additionally, we implement technical safeguards, including TLS/SSL encryption, to protect your data during transfers and ensure its confidentiality and integrity.

We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our services:

Entity name	Services performed	Entity location	Link to Privacy Policy
Facebook	Analytics / ad management service provider	USA	Privacy Policy
Appsflyer	Deeplinking, analytics services, events tracking provider	USA	Privacy Policy
Amplitude	Product analytics, events tracking	USA	Privacy Policy
Google (Google Analytics, Google Maps)	Analytics service provider, Maps integration	USA	Privacy Policy
Firebase Crashlytics (Google LLC)	User authentication, analytics, marketing service provider	USA	Privacy Policy, Firebase Policy
Braintree (for Web Users)	Payment processing	USA	Privacy Policy
Stripe (for Web Users)	Payment processing and financial infrastructure services	USA	Privacy Policy

Please note that some of the third-party services we work with may process your data outside of the EU. In such cases, we ensure that appropriate safeguards are in place to protect your data in compliance with applicable privacy laws.

Your data will also be shares with members of your group within the FamiloApp.

Additionally, we may disclose your data if required by law or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In order to improve our service, we use data generated while using the FamiloApp. This includes the following data points: app starts, session lengths, feature usage, IP address, mobile ad IDs, installation UUID, Android IDs, screen views, user properties (such as first launch or user gender), app crashes, and custom event parameters.

For tracking these data points, creating statistics and derive improvement analysis, we handover this data to the following third party services:

• Firebase
• Google Analytics

According to Art. 6(1)(f) of GDPR, we have a legitimate interest in collecting such statistical data, as it helps us improve the app and user experience, without overriding your rights and freedoms.

You can delete your personal user data by the deletion of your user account in the FamiloApp or by contacting us to arrange the deletion of all personal information from our servers (see section Who is responsible and how do I contact FamiloApp?).

You can access and export all personal data that we store about you to you or a third party by contacting us (see section Who is responsible and how do I contact FamiloApp?).

In addition to access and deletion rights, under the GDPR you also have the right to:

• Correction: Request correction of any inaccurate or incomplete personal data we hold about you. You can correct any inaccurate or incomplete personal data we hold about you by updating your information directly through your FamiloApp account settings.
• Restriction of Processing: Request that we limit the processing of your data under certain circumstances.
• Objection: Object to the processing of your data for direct marketing or other purposes based on our legitimate interests.
• Data Portability: Receive a copy of your data in a structured, commonly used, machine-readable format and transfer it to another service if desired.
• Withdraw Consent: Withdraw consent at any time if our processing is based on your consent.

You may submit a request to exercise any of these rights by contacting us (see section Who is responsible and how do I contact FamiloApp?). We will respond to your request within 30 days, as required under the GDPR, unless an extension is necessary due to the complexity of the request or a high volume of requests.

If you are not satisfied with how we have addressed your issue, you have the right to file a complaint about how your personal data is being handled with the Federal Commissioner for Data Protection and Freedom of Information (BfDI).

We take all reasonable technical and organizational measures to ensure the security of the app and data transmission. To prevent unauthorized access or disclosure, and to ensure data accuracy and legitimate use, we have implemented appropriate procedures to safeguard the data handled within the FamiloApp.

• Your registration and authentication in the app are done through a unique code sent via SMS, which you must enter into the app. This provides a level of security comparable to mobile TAN processing in online banking.
• Data transfer to our server backend is secured via TLS/SSL encryption using the HTTPS protocol, with additional transport encryption.
• Local storage on your device is limited to what's necessary for the functionality of FamiloApp. When you uninstall the app, all data is erased from the device. However, on Android devices, data stored on external memory may remain even after uninstallation.
• App usage is logged within FamiloApp, but by default, we do not access this data. You can choose to send this data to us via email for troubleshooting and improving your app experience.
• Certain screens within FamiloApp load as web pages, but these are exclusively owned by FamiloApp and not third-party websites.
• Our server backend is protected by various safety and security mechanisms. You authenticate and gain access using a unique token based on your personal data, ensuring secure authentication. We also implement firewalls and conduct regular security updates to safeguard your information.

In the event of a data breach or security incident, we will take immediate steps to mitigate the impact and notify affected users. This includes informing you without undue delay if your personal data is compromised. We will also report the incident to the relevant supervisory authority within 72 hours of becoming aware of it.

Your Internet browser automatically transmits data to our web server when accessing our www.familo.net. This includes the date and time of access, URL of the referring website, retrieved file, amount of data sent, browser type and version, operating system and your IP address. This data is stored as log files.

We do not use any web analytics service for the data collected on our website. Also we do not store any cookies in your web browser while visiting our website.

To get in touch with us:
FamiloApp GmbH
Carl-Petersen-Straße 101
20535 Hamburg, Germany
Registered Office: Hamburg, Hamburg District Court HRB 157046
Managing Directors: Lars Christiansen

If you have questions or suggestions regarding data protection, you can easily contact us support@familo.net.

An easily searchable imprint with all relevant information and ways to contact FamiloApp is available within the app, on the website, and on our app store page.

Our privacy statement is easily accessible at any time, it is also available during the use of the app, from our website and our app stores pages. We may update this Privacy Policy from time to time. This latest version is dated November 20, 2024.