Privacy Policy

1. Information We Collect

We collect various types of information to provide and improve our Services. The information we collect includes:

1.1 Information You Provide Directly

1.2 Information Collected Automatically

• Device Information: Device type, operating system, unique device identifiers, mobile network information
• Usage Data: App features used, pages visited, time spent, interaction patterns
• Log Data: IP address, browser type, access times, referring URLs
• Cookies and Tracking: Session cookies, preference cookies, analytics cookies

1.3 Location Information

1.4 Information from Third Parties

• Authentication Services: Data from Google, Facebook, or Apple Sign-In
• Payment Processors: Transaction information (we don't store full payment details)
• Analytics Providers: Aggregated usage statistics
• SMS Providers (Twilio): Message delivery status and metadata

2. How We Use Your Information

We use the collected information for the following purposes:

2.1 Service Provision

• Create and manage your account
• Provide emergency alert and location sharing features
• Process and deliver notifications
• Enable communication with emergency contacts
• Authenticate users and prevent unauthorized access

2.2 Service Improvement

• Analyze usage patterns to improve functionality
• Develop new features and services
• Conduct research and testing
• Personalize user experience
• Troubleshoot technical issues

2.3 Communication

• Send service-related notifications
• Respond to support requests
• Provide updates about our services
• Send marketing communications (with your consent)
• Request feedback and reviews

2.4 Safety and Security

• Detect and prevent fraud and abuse
• Protect against security threats
• Enforce our Terms of Service
• Comply with legal obligations
• Respond to emergency situations

3. How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

3.1 With Your Consent

• Emergency Contacts: When you activate SOS alerts, we share your location and message with designated contacts
• Third-Party Integrations: When you authorize connections to external services

3.2 Service Providers

We share information with trusted third-party service providers who assist us in operating our services:

• Cloud Hosting: AWS, Google Cloud, or similar providers
• SMS Services: Twilio for message delivery
• Analytics: Google Analytics, Firebase
• Payment Processing: Stripe, PayPal (encrypted payment data only)
• Customer Support: Help desk and ticketing systems

All service providers are contractually obligated to protect your data and use it only for specified purposes.

3.3 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes (subpoenas, court orders)
• Respond to government requests
• Protect our rights, property, or safety
• Prevent fraud or illegal activities
• Respond to emergencies involving danger of death or serious injury

3.4 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity. You will be notified of any such change.

3.5 Aggregated Data

We may share anonymized, aggregated, or de-identified data that cannot be used to identify you for research, analytics, or marketing purposes.

4. Data Security

We implement industry-standard security measures to protect your information:

4.1 Technical Safeguards

• Encryption: Data is encrypted in transit (TLS/SSL) and at rest (AES-256)
• Secure Servers: Protected by firewalls and intrusion detection systems
• Access Controls: Role-based access with multi-factor authentication
• Regular Audits: Security assessments and vulnerability testing
• Data Backups: Regular encrypted backups with disaster recovery plans

4.2 Organizational Safeguards

• Limited employee access to personal data
• Confidentiality agreements with all personnel
• Regular security training
• Incident response procedures

5. Your Privacy Rights

You have the following rights regarding your personal information:

5.1 How to Exercise Your Rights

To exercise any of these rights:

• In-App Settings: Access and manage your data directly in the application
• Email Request: Contact us at privacy@appssosoft.com
• Written Request: Send to our business address (see Contact section)

We will respond to your request within 30 days. Identity verification may be required.

5.2 California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information
• Right to opt-out of the sale of personal information (we do not sell data)
• Right to non-discrimination for exercising privacy rights

5.3 GDPR Rights (European Users)

If you are in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR), including all rights listed above plus the right to lodge a complaint with a supervisory authority.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

6.1 Retention Periods

6.2 Account Deletion

When you delete your account:

• Personal information is deleted within 90 days
• Some data may be retained for legal compliance
• Anonymized data may be retained for analytics
• Backup copies are deleted within our backup retention cycle

7. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

7.1 Types of Cookies

• Essential Cookies: Required for basic functionality (cannot be disabled)
• Preference Cookies: Remember your settings and choices
• Analytics Cookies: Help us understand how you use our services
• Marketing Cookies: Track visits across websites for advertising (with consent)

7.2 Managing Cookies

You can control cookies through:

• Browser settings (most browsers allow you to block or delete cookies)
• Our cookie consent banner
• Opt-out tools from advertising networks

Note: Disabling cookies may affect functionality of our services.

7.3 Do Not Track

Some browsers have "Do Not Track" features. Currently, there is no industry standard for DNT signals, but we respect your privacy choices.

8. Children's Privacy

Our Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

8.1 Age Verification

By using our Services, you represent that you are at least 13 years old. Users between 13-18 must have parental consent.

8.2 Parental Controls

For users under 18, we recommend parents:

• Review and approve emergency contacts
• Monitor location sharing settings
• Set up parental controls on devices
• Discuss emergency procedures with minors

9. International Data Transfers

Your information may be transferred to, stored, and processed in countries other than your own. We ensure adequate protection through:

9.1 Transfer Mechanisms

• Standard Contractual Clauses: EU-approved data transfer agreements
• Adequacy Decisions: Transfers to countries with adequate protection
• Privacy Shield (where applicable): Compliance frameworks
• Explicit Consent: When required for specific transfers

9.2 Data Localization

Where possible, we store data in your region. However, some services require cross-border data flows for functionality (e.g., emergency alerts sent internationally).

10. Third-Party Services

Our Services may integrate with third-party platforms. We are not responsible for the privacy practices of these third parties.

10.1 Third-Party Privacy Policies

Please review the privacy policies of:

• Twilio: twilio.com/legal/privacy
• Google Maps: policies.google.com/privacy
• WhatsApp: whatsapp.com/legal/privacy-policy
• Telegram: telegram.org/privacy

10.2 Social Media Integration

If you connect social media accounts, we may receive information according to your social media privacy settings.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements.

11.1 Notification of Changes

We will notify you of material changes by:

• Posting updated policy on our website
• Updating the "Effective Date" at the top
• Sending email notification (for significant changes)
• In-app notifications

11.2 Your Acceptance

Continued use of our Services after changes constitutes acceptance of the updated Privacy Policy. If you disagree with changes, you may discontinue use and request account deletion.

12. Your California Privacy Rights

California residents have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

12.1 Information We Collect (CCPA Categories)

12.2 Sale of Personal Information

12.3 How to Submit a Request

California residents can submit requests to:

• Email: privacy@appssosoft.com with subject "California Privacy Request"
• Toll-Free: 1-800-XXX-XXXX (if applicable)
• Online Form: Visit appssosoft.com/privacy-request

We will respond within 45 days and verify your identity before processing requests.

13. Data Breach Notification

In the unlikely event of a data breach that affects your personal information, we will:

13.1 Our Response

• Immediate Action: Contain and investigate the breach
• Notification: Inform affected users within 72 hours (where required by law)
• Transparency: Explain what data was affected and steps taken
• Remediation: Provide guidance on protecting yourself
• Regulatory Compliance: Report to relevant authorities as required

13.2 What We'll Tell You

• Date and time of the breach
• Types of data affected
• Number of affected users
• Steps we've taken to address the breach
• Recommendations for protecting yourself
• Contact information for questions

14. Automated Decision-Making

We may use automated systems to improve our services, but we do not make significant decisions solely based on automated processing without human oversight.

14.1 What We Use Automation For

• Fraud Detection: Identify suspicious activities
• Service Optimization: Improve app performance
• Personalization: Customize user experience
• Analytics: Understand usage patterns

14.2 Your Rights

You have the right to:

• Request human review of automated decisions
• Object to automated processing
• Understand the logic behind automated decisions

15. Sensitive Personal Information

We recognize that certain information is particularly sensitive and deserves extra protection.

15.1 What We Consider Sensitive

15.2 Extra Protections

• Enhanced encryption (AES-256)
• Restricted employee access
• Automatic deletion after use (location data)
• Explicit consent required
• No sharing except for intended emergency purposes

16. Marketing and Communications

16.1 Types of Communications

• Transactional: Service updates, security alerts (cannot opt-out)
• Promotional: New features, offers, tips (can opt-out)
• Survey/Feedback: User experience research (can opt-out)
• Emergency Alerts: SOS notifications (cannot opt-out)

16.2 Opting Out

You can opt-out of marketing communications by:

• Clicking "Unsubscribe" in emails
• Adjusting notification settings in the app
• Contacting us at privacy@appssosoft.com
• Replying "STOP" to SMS messages

Note: You will still receive essential service communications.

17. Accessibility

We are committed to making our Privacy Policy accessible to everyone.

17.1 Alternative Formats

This Privacy Policy is available in:

• Web format (with screen reader support)
• PDF download
• Large print (upon request)
• Plain language summary (upon request)

17.2 Language Options

Available in multiple languages. Request translation at privacy@appssosoft.com

18. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

18.1 Mailing Address

Appssosoft
[Your Street Address]
[City, State/Province, Postal Code]
[Country]

18.2 Data Protection Officer (DPO)

For GDPR-related inquiries:

Email: dpo@appssosoft.com

18.3 Supervisory Authority

EU/EEA residents have the right to lodge a complaint with your local data protection authority if you believe we have not complied with applicable data protection laws.

19. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), we process your data based on the following legal grounds:

20. Special Provisions for Emergency Services

20.1 Emergency Activation

When you activate an SOS alert:

• Immediate Location Sharing: Your precise GPS coordinates are captured and shared
• No Prior Consent Required: In emergency situations, we may share your location without additional consent
• Third-Party Transmission: Data is sent through SMS providers (Twilio) and messaging apps (WhatsApp, Telegram)
• No Guarantee: We cannot guarantee delivery due to network conditions

20.2 Emergency Contact Access

Your designated emergency contacts will receive:

• Your current GPS coordinates
• Timestamp of alert
• Custom emergency message
• Google Maps link to your location

20.3 False Alarm Policy

If you accidentally activate an SOS alert:

• Cancel within the countdown period (10 seconds)
• Immediately contact your emergency contacts to confirm safety
• Location data from cancelled alerts is deleted within 24 hours

20.4 Emergency Services Cooperation

We may cooperate with law enforcement and emergency services by providing:

• User location data
• Account information
• Emergency contact details
• Alert history and timestamps

This cooperation is limited to genuine emergency situations and legal requests.

21. Updates and Version History

We maintain a history of significant changes to this Privacy Policy:

22. Acknowledgment and Consent

By using Appssosoft's services, you acknowledge that:

• ✓ You have read and understood this Privacy Policy
• ✓ You consent to the collection, use, and sharing of your information as described
• ✓ You understand the emergency nature of location sharing in ELSA
• ✓ You are responsible for the accuracy of information you provide
• ✓ You have the authority to provide emergency contact information
• ✓ You will notify us of any changes to your information