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Table of Contents

1. Introduction
2. Information We Collect
3. How We Use Your Information
4. Information Sharing
5. Data Security
6. Cloud Backup and Data Retention
7. Your Rights
8. International Transfers
9. Children's Privacy
10. Contact Information

1. Introduction

Fein ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, and protect your information when you use our application.

This Policy complies with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data Protection (UAE PDP Law), the European Union's General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the UK Data Protection Act 2018.

By using Fein, you consent to the collection and use of information in accordance with this Policy. If you do not agree with our policies and practices, please do not use our application.

2. Information We Collect

2.1 Personal Information

We collect the following personal information:

• Name, email address, and phone number
• Profile information (avatar, emergency contacts)
• Medical information (blood type, allergies, medications)
• Location data and location history
• Device information and usage statistics

2.2 Location Data

Our application requires access to your device's location services to provide group tracking functionality. We collect:

• Real-time GPS coordinates
• Location history and movement patterns
• Geofencing data for place-based alerts
• Driving behavior and safety metrics

Background collection. When you enable location sharing, Fein collects location data in the background — including while the app is closed or not in use — so that live sharing, place arrival and departure alerts, trip history, and SOS continue to work. Your location is shared only with members of the groups you join; it is never sold and never used for advertising. You can pause sharing at any time in the app, or revoke the location permission in your device settings.

Motion & activity recognition. With your permission, Fein reads your device's low-power motion activity classification (for example: walking, driving, still) to reduce GPS use and save battery. This classification is processed on your device and is not part of your shared location history.

Battery optimization exemption (Android). Fein may ask you to exempt it from Android battery optimization so the operating system does not suspend background location sharing and SOS alerts. This setting only changes how Android schedules the app in the background; it does not give Fein access to any additional data.

2.3 Technical Information

We automatically collect technical information including:

• Device type, operating system, and app version
• IP address and network information
• Usage analytics and crash reports
• Battery level and device performance data

3. How We Use Your Information

We use your information for the following purposes:

• Provide group location tracking services
• Send location-based alerts and notifications
• Generate driving reports and safety analytics
• Manage emergency contacts and SOS features
• Provide optional cloud backup and data synchronization services
• Improve app functionality and user experience
• Provide customer support and technical assistance
• Comply with legal obligations and regulations

We process your personal data based on the following legal grounds:

• Consent: You have given clear consent for processing
• Contract: Processing is necessary for service provision
• Legitimate Interest: For app improvement and security
• Legal Obligation: To comply with applicable laws

4. Information Sharing

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

• With group members you have authorized
• Emergency services during SOS activations
• Service providers who assist in app operation
• Legal authorities when required by law
• Business transfers (with appropriate safeguards)

All third-party service providers are bound by strict confidentiality agreements and data protection obligations.

5. Data Security

We implement comprehensive security measures to protect your personal information:

• End-to-end encryption for all data transmission
• Secure cloud storage with AES-256 encryption
• Client-side encryption for cloud backup data
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Employee training on data protection
• Incident response and breach notification procedures

6. Cloud Backup and Data Retention

6.1 Cloud Backup Service

Fein offers an optional cloud backup feature that allows you to securely store your app data, settings, and preferences to iCloud (iOS) or Google Drive (Android). This service enables seamless data transfer when you switch to a new device or reinstall the app.

6.2 What Data is Backed Up

With your explicit consent, we may back up the following data:

• App settings and preferences (location intervals, notifications, units)
• User profile information (name, basic preferences - no emergency contacts)
• Interface customizations (theme, layout preferences)
• Onboarding progress and feature preferences
• Machine learning models and anonymized pattern data (if opted in)

6.3 Cloud Backup Security

Your cloud backup data is protected with multiple layers of security:

• Client-side encryption: Sensitive data is encrypted on your device before upload
• Platform security: Data stored using Apple iCloud or Google Drive infrastructure
• Granular controls: Choose exactly what data categories to include in backups
• Data integrity verification: Checksums ensure backup completeness
• Automatic deletion: Failed or corrupted backups are automatically removed

6.4 Your Control Over Cloud Backups

You have complete control over your cloud backup data:

• Opt-in only: Cloud backup requires explicit consent during onboarding
• Granular selection: Choose specific data categories to backup
• Manual or automatic: Control when backups are created
• Wi-Fi controls: Option to backup only when connected to Wi-Fi
• Easy deletion: Delete backups anytime from app settings
• Complete disable: Turn off cloud backup entirely at any time

6.5 Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

• Active accounts: Data retained while your account is active
• Cloud backups: Retained according to your backup frequency settings (typically 30-90 days)
• Deleted accounts: Personal data deleted within 30 days of account deletion
• Legal obligations: Some data may be retained longer to comply with legal requirements
• Analytics data: Anonymized usage data may be retained for up to 2 years for service improvement

Cloud backup data is stored exclusively on your chosen platform (iCloud for iOS users, Google Drive for Android users) and is subject to their respective privacy policies and retention practices. We do not store backup data on our own servers.

7. Your Rights

Under applicable data protection laws, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate information
• Right to Erasure: Request deletion of your data
• Right to Portability: Receive your data in a portable format
• Right to Restriction: Limit how we process your data
• Right to Object: Object to certain processing activities
• Right to Withdraw Consent: Revoke consent at any time

To exercise these rights, please contact us using the information provided in Section 10.

8. International Transfers

Your personal data may be transferred to and processed in countries other than your country of residence. We ensure that such transfers comply with applicable data protection laws through:

• Adequacy decisions by relevant authorities
• Standard contractual clauses (SCCs)
• Binding corporate rules (BCRs)
• Other appropriate safeguards

9. Children's Privacy

Our application is designed for group use and may collect information about children under 18. We comply with all applicable laws regarding children's privacy:

• Parental consent required for children under 13 (COPPA)
• Age verification and parental controls
• Limited data collection for children
• Right for parents to review and delete children's data

10. Contact Information

If you have any questions about this Privacy Policy, please contact us:

Address: Fein LLC
Privacy Department
United Arab Emirates
Data Protection Officer: [email protected]

For EU residents, you also have the right to lodge a complaint with your local data protection authority.

This Privacy Policy is effective as of the date listed above and will remain in effect except with respect to any changes in its provisions in the future.