Findmy Device Privacy Policy

This Privacy Policy describes how FlashSoft OU, a company registered in Estonia ("Company," "we," "us," or "our"), collects, uses, and discloses information in connection with your use of the FindMy Device — Bluetooth Tracker & Radar mobile application, published on Google Play as Sweep: Bluetooth Device Finder (together, the "App"), available on the Apple App Store and Google Play. Where the iPhone and Android versions work differently, this policy says so.

By downloading, installing, or using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use the App.

1. Information We Collect

1.1 Information You Provide Directly

• Custom names or labels you assign to tracked devices within the App (stored locally on your device only).
• Feedback and support messages: If you send us a message from the App, we receive your email address, your name (optional), your message, and technical details that help us answer: app version, device model, operating system version, language, time zone and whether you have a premium plan. We use this only to reply to you.

1.2 Information Collected Automatically

• Bluetooth Data (Local Only): The App scans for Bluetooth Low Energy (BLE) signals to detect nearby devices and estimate proximity. Scanned device identifiers (MAC addresses) and signal strength data (RSSI) are processed exclusively on your local device and are never transmitted to our servers or any third party.
• Location Data (On Your Device): On iOS, Bluetooth scanning requires the "Location When In Use" or "Location Always" permission. On Android, the location permission is required by the system to scan for Bluetooth devices and Wi-Fi networks. If you turn on "remember where I left it" and allow location access all the time, the App saves the place where a device disconnected or went out of range, and background tracker alerts may compare your recent locations to check whether an unknown tracker moved with you. These locations are stored only on your device. To show a street address for a saved place, the App passes its coordinates to the address lookup service built into your phone's operating system (on Android, the Google Geocoder). We do not receive, store on our servers, or share your GPS coordinates or location history.
• Find a Friend (Local Only): When you use Find a Friend, your phone broadcasts a Bluetooth signal with a random 4-digit code so the other phone can find you. On phones with Ultra Wideband, the two phones exchange session parameters directly over Bluetooth. Nothing is sent to our servers.
• Wi-Fi Network Data (Local Only): The network scanner and Wi-Fi analyzer read the names, addresses, makers and open services of devices on your local network and the nearby Wi-Fi networks. This data stays on your device.
• Speed Test: The speed test downloads and uploads test data to Cloudflare (speed.cloudflare.com). As with any internet connection, Cloudflare sees your IP address.
• QR Codes: On Android, QR codes are scanned with the Google code scanner from Google Play services. The App does not get access to your camera, and the image is processed on your device.
• Diagnostic & Crash Data: We collect crash reports and performance diagnostics through Firebase Crashlytics (Google) and Apple's crash reporting: the error details, device model, operating system and app version, and a random installation identifier. This data does not include your name or contact details and is used solely to improve App stability.
• App Usage Analytics: We use Firebase Analytics (Google) to see how features are used (for example, how many scans are started or which screens are opened). Events are linked to a random app instance identifier, not to your name or email.
• Advertising (Android, free version): The free Android version shows ads from Google AdMob (banner, native, full-screen and optional rewarded video ads). Pro users see no ads. To show and measure ads, the Google Mobile Ads SDK collects your device's Advertising ID, approximate location derived from your IP address, information about ad interactions, and diagnostic data. In the European Economic Area, the United Kingdom and Switzerland we ask for your consent through Google's consent form (Google User Messaging Platform) before personalized ads are shown; you can change your choice at any time in the App under Settings → Ad privacy choices. You can also reset or delete your Advertising ID in your phone's settings (Settings → Privacy → Ads). Google's use of this data is described at policies.google.com/technologies/partner-sites.
• Purchase & Subscription Data: If you buy a premium plan, the Apple App Store or Google Play processes the transaction. We receive a purchase receipt or token with the product, price, currency and country, and we use Apphud to check your subscription status. We never have access to your name, card number, or payment details.

1.3 Information We Do NOT Collect

• Your name, email address, phone number, or any other contact information (unless you contact us via email or the in-app feedback form).
• Your precise GPS location or location history on our servers (places you save stay on your device).
• Photos, camera roll, microphone recordings, or any other media.
• Bluetooth device identifiers (MAC addresses) of devices you scan.
• Any data from your contacts, messages, or other apps.

2. How We Use the Information

We use the information we collect only for the following limited purposes:

• To provide and maintain the core functionality of the App (Bluetooth scanning and device proximity estimation).
• To diagnose and fix software bugs and crashes.
• To validate and manage your in-app subscription status.
• To show and measure ads in the free Android version (Google AdMob), according to your consent choices.
• To improve, personalize, and develop the App's features over time.
• To comply with applicable laws and legal obligations.

We do not sell your personal data. In the free Android version, Google AdMob may show personalized ads only where you have allowed it; Pro removes ads.

3. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), we process your personal data on the following legal bases:

• Contractual Necessity (Art. 6(1)(b) GDPR): Processing necessary to provide you with the services you requested (e.g., crash reporting to maintain App quality).
• Legitimate Interests (Art. 6(1)(f) GDPR): We have a legitimate interest in improving App stability and performance using diagnostics and usage analytics, and this interest does not override your fundamental rights.
• Consent (Art. 6(1)(a) GDPR): Where required (e.g., for device tracking, location permissions, and personalized advertising in the free Android version), we rely on your explicit consent given via the iOS or Android system permission prompt.

4. Sharing of Information

We do not sell, rent, or trade your personal information. We may share limited non-personal information only in the following circumstances:

• Service Providers: Trusted third-party vendors that process data on our behalf under data processing agreements (DPAs): Google (Firebase Analytics, Firebase Crashlytics, Google Play Billing), Apple (App Store purchases), Apphud (subscription status), Cloudflare (speed test) and, in the free Android version, Google AdMob and its ad partners (advertising). They are not allowed to use your data for their own purposes beyond what their terms permit for providing the service.
• Legal Requirements: We may disclose information if required by law, court order, or governmental authority, or if necessary to protect our rights, property, or the safety of users and the public.
• Business Transfers: In the event of a merger, acquisition, or asset sale, your information may be transferred. We will notify you before your data is transferred and becomes subject to a different privacy policy.

5. Data Retention

Data stored locally on your device (device names, scan history) is retained until you delete the App or clear its data. Crash and analytics data is retained for up to 12 months, after which it is automatically deleted. We retain subscription validation tokens only as long as necessary to confirm your active subscription status. Feedback messages are kept as long as needed to answer you and then deleted on request.

6. Security

We implement appropriate technical and organizational security measures to protect against unauthorized access, alteration, disclosure, or destruction of data. However, no method of electronic transmission or storage is 100% secure. We encourage you to use strong device passcodes and keep your phone's operating system up to date.

7. Your Rights (GDPR & CCPA)

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data.
• Right to Restrict Processing: Request that we limit how we use your data.
• Right to Data Portability: Receive your data in a portable format.
• Right to Object: Object to processing based on legitimate interests.
• Right to Withdraw Consent: Withdraw any consent given at any time in your phone's settings (iOS: Settings → FindMy Device; Android: Settings → Apps → Sweep → Permissions). To delete the data stored on your device, use "Delete all data" in the App's settings or uninstall the App.

To exercise any of these rights, contact us at contact@flashsoftapps.com. We will respond within 30 days.

8. Children's Privacy

The App is not directed to children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children under these ages. If you believe a child has provided us with personal data without parental consent, please contact us immediately at contact@flashsoftapps.com and we will promptly delete such information.

9. International Data Transfers

FlashSoft OU is established in Estonia (EU). If your third-party service providers process data outside the EEA, we ensure that appropriate safeguards are in place (such as Standard Contractual Clauses approved by the European Commission) to protect your data.

10. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes by updating the "Last Updated" date at the top of this page and, when appropriate, through an in-app notice. Your continued use of the App after any changes constitutes your acceptance of the revised policy.

11. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact our Data Protection Officer: