PRIVACY POLICY

Effective Date: May 20, 2024

Last Updated: May 20, 2024

1. Introduction

Welcome to TrackMe (the "App"). This Privacy Policy explains how Sheriff Security AG("we," "us," or "our") collects, uses, shares, and protects your personal data when you use our family location tracking application and related services.

Trust and security are our core values. We are committed to protecting your privacy and ensuring strict compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Swiss Federal Act on Data Protection (FADP), and other applicable data protection laws.

2. Data Controller Information

For the purposes of data protection laws, the Data Controller responsible for your personal data is:

Company Name: Sheriff Security AG
Business Identifier: D-U-N-S® Number: 487350682
Address: c/o Maryna Stryzhova, Brunngasse 66, 4153 Reinach, Switzerland
Contact Email: trackme@sheriff.com.ua

3. Information We Collect

To provide the TrackMe service, we collect the following categories of personal data:

A. Data You Provide Directly:

Account Information: Name, email address, phone number, profile picture, and password.
Family Circle Data: Information about the family groups ("Circles") you create or join, and the roles assigned (e.g., Parent, Child).

B. Data Collected Automatically:

Precise Geolocation Data: We collect your real-time precise location data using GPS, Wi-Fi, and cellular towers. TrackMe collects background location data (even when the App is closed or not in use) to continuously share your location with your authorized Family Circle. This is the core functionality of the App.
Device Information: Device model, operating system, unique device identifiers (IMEI, MAC address), battery level, and network status (to inform your family if your phone is unreachable).
Usage Data: Information on how you interact with the App, timestamps, and crash reports.

4. Purposes and Legal Basis for Processing

Under the GDPR and FADP, we process your data based on the following legal grounds:

Purpose	Data Category	Legal Basis
Account Creation & Service Provision: To manage your TrackMe account, Circles, and provide customer support.	Account Information, Family Circle Data	Performance of a Contract (GDPR Art. 6(1)(b))
Location Tracking & Sharing: To share your real-time location and movement history with authorized members of your Circle.	Precise Geolocation Data	Explicit Consent (GDPR Art. 6(1)(a)). You can withdraw this at any time via device settings.
Device Status Alerts: To notify your family if your battery is low or you lose connection.	Device Information	Legitimate Interest (GDPR Art. 6(1)(f)) to ensure family safety.
App Improvement & Analytics: To fix bugs and improve the TrackMe user experience.	Usage Data, Device Information	Legitimate Interest (GDPR Art. 6(1)(f)) or Consent (if using tracking cookies/SDKs).
Legal Compliance: To comply with law enforcement requests.	All applicable data	Legal Obligation (GDPR Art. 6(1)(c)).

5. Children's Privacy

As a family tracking app, the safety and privacy of children are our highest priority.

Parental Control: TrackMe accounts for children under the age of 16 (or the applicable age of digital consent in your jurisdiction) may only be created and linked by a parent or legal guardian acting as the Family Administrator.
Data Control: The parent controls the child's data, location sharing permissions, and can delete the child's account at any time.
If we discover we have collected personal data from a child without verifiable parental consent, we will delete that information immediately.

6. Who We Share Your Data With

Sheriff Security AG does not sell, rent, or trade your personal data, including your location data, to third parties, marketers, or data brokers. We only share data with:

Your Family Circle: Members you explicitly invite and authorize within the TrackMe App.
Trusted Service Providers (Data Processors): Third-party cloud hosting providers (e.g., Hetzner Online GmbH) strictly required for operating our service. They are bound by strict Data Processing Agreements (DPAs).
Law Enforcement: Only when legally required by a valid court order or subpoena.

7. Data Retention

We adhere to data minimization principles:

Account Data: Retained for as long as your TrackMe account is active. Upon requesting account deletion, data is removed within 30 days.
Location History: Real-time location is overwritten dynamically. Location history (if supported by your plan) is retained for a maximum of 7 days and then permanently deleted from our servers.

8. International Data Transfers

Sheriff Security AG is headquartered in Switzerland. Switzerland is recognized by the European Commission as providing an adequate level of data protection. If we transfer your data to servers or service providers outside Switzerland or the European Economic Area (EEA), we ensure your data is protected by utilizing safeguards such as Standard Contractual Clauses (SCCs).

9. Your Privacy Rights

If you are a resident of the EU/EEA or Switzerland, you possess the following rights:

Right of Access: Request a copy of the data Sheriff Security AG holds about you.
Right to Rectification: Correct inaccurate data.
Right to Erasure ("Right to be Forgotten"): Request the permanent deletion of your TrackMe account and associated location data directly through the App settings or by contacting us.
Right to Withdraw Consent: Stop background location sharing at any time by disabling GPS permissions in your phone's OS settings.
Right to Restriction & Portability: Request suspension of processing or receive your data in a machine-readable format.

To exercise these rights, email us at trackme@sheriff.com.ua. You also have the right to lodge a complaint with your local Data Protection Supervisory Authority (e.g., the FDPIC in Switzerland).

10. Data Security

Sheriff Security AG implements state-of-the-art technical and organizational measures to protect your data. This includes TLS/SSL encryption for data in transit and encryption at rest for data stored on our servers. You are responsible for keeping your TrackMe account password and Family Circle invitation codes confidential.

11. Changes to this Policy

We may update this policy periodically. If material changes are made (especially regarding geolocation data), we will notify you via an in-app alert or email prior to the changes taking effect.

12. Contact Us

For any questions regarding this Privacy Policy or requests to delete your data, please contact us at:

Email: trackme@sheriff.com.ua
Mailing Address: Sheriff Security AG, c/o Maryna Stryzhova, Brunngasse 66, 4153 Reinach, Switzerland.