PRIVACY NOTICE

Target Service: Phone Location Tracker (“Service”)

Data Controller: WEBPEAK OÜ (Registry Address: Harju maakond, Tallinn, Lasnamäe linnaosa, Valukoja tn 8/2, 11415, Estonia)

Primary Legal Contact: support@webpeakou.net

Effective Date: September 10, 2026

1. CORE GOVERNANCE & ELIGIBILITY PROTOCOL

1.1 Binding Acceptance: Accessing or using the Location Tracker Service requires full agreement to this Privacy Notice. If you do not accept these terms, you must immediately (a) delete your account and request data removal, (b) cancel active subscriptions, and (c) uninstall the Service.
1.2 Strict Age Requirement: The Service is strictly intended for individuals who are 18 years of age or older. We do not knowingly collect or process data from minors under 18. If you suspect a minor has submitted personal data, notify support@webpeakou.net immediately for prompt deletion.
1.3 Data Minimization Commitment: We process only the minimum amount and categories of data necessary to fulfill designated operational purposes, maintaining standards of accuracy, completeness, and currency.

2. COMPREHENSIVE DATA PROCESSING MATRIX

The table below outlines all categories of personal data collected, their source mechanisms, processing rationale, and applicable legal bases under data protection laws:

Category & Source	Specific Data Points Collected	Operational Purpose	Lawful Basis
Identifiers (Directly Provided)	Name, Email Address, Phone Number	Account setup, identity verification, newsletter distribution, and direct user support.	Contract Performance User Consent
Service & Geolocation (Directly Provided)	User Profile Photos, Real-time GPS Geolocation	Delivering core personalized tracking features and Circle location sharing.	Contract Performance User Consent
Telemetry & Device Data (Automated Collection)	IP Address, Hardware ID, GAID, Device Model/Type, OS Version, Time Zone, Language, Mobile Carrier	Technical operation, traffic analysis, performance optimization, and ad tailoring.	Contract Performance Legitimate Interest
Log & Usage Activity (Automated Collection)	Pages viewed, features used, session duration, interaction frequency	Analytical assessment and ongoing enhancement of Service architecture.	Contract Performance Legitimate Interest
Subscription Records (Received via Payment System)	Transaction history, Subscription ID, renewal terms, validity periods	Managing subscription status, verifying active tiers, and handling tier billing.	Contract Performance User Consent

Excluded Data Categories: We do not collect or process special categories of data, including racial/ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic/biometric data, health/sex life details, or criminal records.

3. LEGITIMATE INTERESTS BALANCING

When processing data under the lawful basis of Legitimate Interest, we balance our business goals against your privacy rights across five core areas:

Measured Service Promotion: Communicating product updates and marketing in an appropriate, non-intrusive manner.
User Experience Analytics: Studying aggregated interaction patterns to refine app features.
Ad Personalization: Delivering tailored, relevant ad experiences.
Legal Defense: Protecting our business, assets, and reputation against legal claims or liability.
Terms Enforcement: Monitoring and preventing actions that breach our Terms of Use.

4. COOKIES, SDKs & AUTOMATED TELEMETRY

Tracking Technologies: We utilize embedded SDKs, cookies, and tracking scripts when you interact with our mobile application or website.
Functional Impact: These tools handle ad optimization, analytics, and live support/chat functionality. While you may disable or block tracking mechanisms through device settings, doing so may degrade specific features within the Service.

5. DATA SHARING & THIRD-PARTY INTEGRATIONS

Personal data is disclosed only to authorized personnel, contractors, affiliates, and vetted service providers under strict confidentiality duties and processing instructions:

Infrastructure & Analytics Partners:

Google LLC
Meta Platforms Inc.
Apple Inc.
Amplitude Inc.
Firebase Inc.
Namecheap Inc.
Velia.net Internetdienste GmbH
Hetzner Online GmbH
Appfigures Inc.
Cloudflare Inc.
Amazon Web Services Inc.

Public Authorities & Law Enforcement: We disclose data when required by law, court order, or regulatory mandate, or to defend safety, property, and legal rights.
Corporate Transactions: User information may be transferred as a business asset during corporate mergers, acquisitions, asset sales, restructuring, or bankruptcy proceedings.

6. INTERNATIONAL DATA TRANSFERS & SECURITY

Cross-Border Transfers: Data collected within the European Economic Area (EEA) may be transferred to countries outside the EEA. Where target jurisdictions lack an equivalent data protection standard, transfers are safeguarded using European Commission Standard Contractual Clauses (SCCs) or applicable Adequacy Decisions.
Technical & Organizational Security: We apply SSL encryption, perimeter access controls, role-based data restrictions, and regular risk assessments. Formal protocols are established to investigate and address suspected security breaches, including notifying affected users and authorities when required by law.
Data Retention Limits: Data is stored only for as long as necessary to fulfill operational, contract, tax, or legal requirements. Retention periods are calculated based on data sensitivity, potential risk of harm, legal limitations, and active account status.

7. REGULATORY RIGHTS MATRIX (EEA, UK, US & CANADA)

To exercise any applicable privacy right, email support@webpeakou.net. Requests are verified against account details (e.g., email address, transaction history, subscription start date) following data minimization rules.

A. European Economic Area (EEA) & United Kingdom (UK)

EEA and UK users hold the following statutory data rights:

Right to Access / Rectification: Request details on processing activities or correct inaccurate/incomplete information.
Right to Erasure ("To Be Forgotten"): Request full deletion of personal data where legal exceptions do not apply.
Right to Restriction / Objection: Limit processing activities or object entirely based on custom circumstances.
Right to Data Portability: Receive an exported copy of your data for transfer to another controller.
Consent Withdrawal: Revoke previously granted consent at any time without affecting prior lawful processing.
Regulatory Complaints: File grievances directly with an EU Data Protection Authority or the UK Information Commissioner's Office (www.ico.org.uk / 0303 123 1113).

B. United States Regional Rights Framework

Response timelines for US state requests range from 30 to 60 days based on local state rules, with optional 30-day extensions where necessary. Unresolved complaints can be escalated to the Federal Trade Commission (FTC).

Applicable State Jurisdiction	Available Privacy Rights
California, Colorado, Connecticut, Indiana, Iowa, Montana, Tennessee, Texas, Utah, Virginia	• Right to Access / Confirm Processing • Right to Request Deletion • Right to Personal Data Portability • Right to Opt Out of Data Sales
California, Colorado, Connecticut, Indiana, Montana, Tennessee, Texas, Virginia	• Right to Correct Inaccuracies • Prohibition against automated decision-making without human review
Colorado, Connecticut, Indiana, Montana, Tennessee, Texas, Utah, Virginia	• Right to Opt Out of Targeted Advertising / Profiling
California Specific Rights	• Opt Out of Sensitive Data Processing • Private Right of Action for security breaches • CCPA Opt-Out Notice: We do not sell personal data for monetary or other value. Users may register a formal preference against future sales. • Shine the Light: Request annual disclosures regarding third-party direct marketing sharing by emailing subject "Request for California Shine the Light Privacy Information". • Do-Not-Track (DNT): Automated web browser DNT signals are not currently supported due to technological limitations.
Colorado, Connecticut, Indiana, Montana, Tennessee, Texas, Virginia	• Right to Opt In before Sensitive Data Processing

C. Canadian Residents

Canadian users hold rights under federal and provincial privacy frameworks (including PIPEDA). Inquiries or complaints can be submitted via support or escalated to the Office of the Privacy Commissioner of Canada.

8. AMENDMENTS & DIRECT CONTACT

Updates: Material updates will be communicated through the app, email, or a mandatory acceptance screen. Non-material updates are indicated by modifying the "Last Updated" date. Continued app usage implies acceptance.
Data Protection Inquiries: Email support@webpeakou.net.