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 (the "App"), available on the Apple App Store.

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).

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 (Local Only): On iOS, Bluetooth scanning requires the "Location When In Use" or "Location Always" permission. The App uses this permission solely to enable Bluetooth scanning functionality as required by the operating system. We do not collect, store, or transmit your precise GPS coordinates or location history.
• Diagnostic & Crash Data: We may collect anonymous, non-personally identifiable crash logs and performance diagnostics (e.g., via Apple's native crash reporting or a third-party tool such as Firebase Crashlytics). This data contains no personal information and is used solely to improve App stability.
• App Usage Analytics: Aggregated, anonymized data on feature usage (e.g., number of scan sessions) may be collected to improve the user experience. No individual user can be identified from this data.
• Purchase & Subscription Data: If you subscribe to a premium plan, Apple's App Store processes the transaction. We receive only an anonymized receipt token to verify and unlock your subscription. We never have access to your name, credit 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 support).
• Precise GPS location or location history.
• 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 improve, personalize, and develop the App's features over time.
• To comply with applicable laws and legal obligations.

We do not use your data for targeted advertising, profiling, or sale to third parties.

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 anonymous diagnostics, and this interest does not override your fundamental rights.
• Consent (Art. 6(1)(a) GDPR): Where required (e.g., for device tracking, location permissions), we rely on your explicit consent given via the iOS 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 (e.g., crash reporting tools, subscription management platforms) that process data on our behalf under strict data processing agreements (DPAs). They are prohibited from using your data for their own purposes.
• 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. Anonymous 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.

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 iOS version 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 via iOS Settings → FindMy Device → Permissions.

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: