1. What is Personal Information?
2. What Personal Information Does Locga Collect?
2.1 Information you provide for the use of technology
Registration and Profile Information. When you create an account, we may collect your personal information such as your username, first and last name, birth date, email address, mobile phone number and a photo, if you choose to have a photo associated with your account. If you want to add a child or family member’s name to your account, we collect the child or family member’s name, email address, and mobile phone number. We may collect billing information when you sign up for the Premium service. We may collect additional information from a parent in order to obtain verifiable parental consent to allow a child to use the Locga Service. When you register in our app with social media, such as Facebook, we receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network.
Location Services. We collect your location through GPS, WiFi, or wireless network triangulation in order to obtain your location for the purposes of providing the Locga Service. Locga is also using location services in the background to provide a key safety feature: so the parent users can get real-time geofence alerts from their children. While you are logged in to your account and have location services enabled, we will continue to collect your location information in order to provide the Locga Service (for example, to provide the Locga Services or to share your location with the members you allow to see your location). We maintain location information only so long as is reasonable to provide the Service and then delete the location data.
Messages and User Content. We collect information when you message other members of your Family through the use of the service. We may also retain any messages you send to us.
Locga only collects "sensitive" personal information when you voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person's race, ethnicity, political, philosophical religious or similar beliefs, trade union membership, physical or mental health, sexual life, sexual orientation, or criminal record. Please use your discretion when providing sensitive information to the Company, and under any circumstances, do not provide sensitive information to us, unless you thereby consent to our use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in our databases. If you have any questions about whether the provision of sensitive information to Locga is, or may be, necessary or appropriate for particular purposes, please contact us at firstname.lastname@example.org.
2.2 Automatically collected information through the use of technology:
When you use the Locga Service, we and our business partners may collect certain information about your computer or device through technology such as cookies, web beacons, log files, or other tracking/recording tools. The information we collect through the use of tracking technologies includes, but is not limited to, IP address, browser information, referring/exit pages and URLs, click stream data and how you interact with links on the website, mobile app, the Locga Service, domain names, landing pages, page views, cookie data that allows us to uniquely identify your browser, browsing behavior on our site, mobile device type, mobile device IDs or other persistent identifiers, and location data collected from your mobile device. Some or all of this data may be combined with other personally identifying information described above.
Remember information so that you will not have to re-enter it during your visit or the next time you use the Locga
Provide custom, personalized content and information
Monitor the effectiveness of our Service and our marketing campaigns
Monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns
Diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs
Automatically update our mobile application on your system and related devices
2.3 Driving Event Data:
We collect, and may use a third-party partner to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. We may also share this information with third party partners for marketing and research purposes. If you want to opt-out, please adjust your settings in your mobile device to limit the app’s access to your sensory and motion data.
2.4 Children’s Privacy:
Please contact us at email@example.com if you have questions about your child’s account. If you believe that we might have inadvertently collected information from a child under 13 without parental consent, please contact us.
3. How Does Locga Use Personal Information?
Generally, Locga collects, stores, uses and discloses information to enable us to:
* provide the Locga service;
* create your account;
*identify you as a user;
*respond to your inquiries and emails;
* improve the application;
*send you administrative and service related communications;
*send you newsletters, surveys, offers, and other promotional materials;
*monitor the effectiveness of our Service and our marketing campaigns.
*If you are an individual from the European Economic Area (EEA), we use your Personal Information, we may process your personal data on one or more of the following legal grounds: (i) because processing is necessary to perform a contract with you, such as to deliver the Locga Service; (ii) to comply with our legal obligations; (iii) because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms. We may also process your Personal Information based on your consent where you have expressly given that to us
3.1 Third Party Analytics
We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Locga Service. Tools like Appsflyer, Flurry and Firebase collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analyzing and improving the Service. Anonymous aggregate statistics that do not personally identify the Users will be kept and used by us for various purposes including analysis and reporting of usage patterns.
When you access the Locga Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or other identifier), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude), WiFi location or similar information regarding the location of your mobile device.
3.2 Third Party Ad Networks
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 Locga Service over time, so that they may play or display ads that may be relevant to your interests on the Locga Service as well as on other websites, apps or services, or on other devices you may use. 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 information such as clickstream information, timestamp, hashed email address, device ID or AdID, and information about your use of third-party applications. They may also collect and analyze information about your use of the Locga Service in order to recognize you across various devices you use.
3.3 Integrated IoT Partners
For our IoT users: please be aware that Locga may receive the following data from our partner devices: anonymized authorization token, anonymous account ID, SOS signal, tracker ID, anonymous location data. These data do not contain any user details and are used solely to trigger SOS alerts to circle members inside Locga mobile app.
4. How Does Locga Share Your Personal Information?
We share your personal information, including name, email, location and driving event data, with others within your Locga circles.
We may share your personal information, including your location data, driving sensor data, unique identifiers or AD IDs and other data with third parties for their marketing and business purposes, including without limitation, to inform and improve third-party advertising. These third-party partners may use this information according to their own privacy policies.
Any information or content that you voluntarily post to our App Store and Google Play Store, or our social media pages will automatically be available to the public. We may publicly post your reviews and comments online.
We may, and you hereby authorize us to, disclose your Personal Information (including messages) to a third party without your consent: if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities, in connection with any legal investigation, when we believe in good faith that such disclosure is required by and in accordance with the law or to respond to subpoenas or warrants served on Locga, to any third party with your prior consent to do so.
5. How Does Locga Protect Your Personal Information?
The security of your Personal Information is important to us. We use all commercially reasonable efforts to store and maintain your Personal Information and location information in a secure environment and have implemented reasonable procedures designed to limit unauthorized access, use or disclosure of your Personal Information. We encrypt the transmission of your location-based data using secure technologies to preserve the integrity and security of all information we collect. Despite these measures, you should know that Locga cannot fully eliminate security risks associated with Personal Information. In the event that any information under our control is compromised as a result of a breach of security, 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 any applicable laws and regulations. Please also remember, that to protect the communications that have taken place in the app, never give out your password.
6. How Long We Retain Your Personal Information:
7. How Can I Update User Access or Deactivate my Account?
If your personal information changes, or if you no longer desire the Locga Service, you may email us at firstname.lastname@example.org to deactivate your account. You may also correct, update, or amend your personal information in your profile settings within the Locga app or by emailing us. Removing Locga from your mobile device will not delete the personal information that has been retained about you. If you leave your circles, we will retain your user content in the event that you would like to access it in the future. Your user content can be deleted permanently by emailing a request to email@example.com.
8. How Can I Manage Communication with Locga?
You may "opt out" of receiving marketing or promotional emails from us by following the instructions in those emails or by emailing us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. To opt out of push notifications, please edit settings within the app or change your settings at the device level.
9. What Laws are Locga Governed by?
10. Additional Rights For EEA And Certain Other Territories:
If you are from certain territories (such as the EEA), you may have the right to exercise additional rights available to you under applicable laws, as follows:
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please contact us at email@example.com. We will respond to your request within thirty days of receipt of the request. We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by firstname.lastname@example.org. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request
Objections to processing of personal data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defense of a legal claims. To invoke this right, please contact us at email@example.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
(a) The processing is based on consent or on a contract, and
(b) The processing is carried out by automated means.
To invoke this right, please contact us at firstname.lastname@example.org. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you for, contact us at email@example.com. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations. You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint
11. California Privacy Rights
We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance
If you have any questions or suggestions about our