SMARTGOCARE APP — COMPREHENSIVE PRIVACY POLICY
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1. WHO WE ARE AND HOW THIS POLICY APPLIES
Smartgocare ("Shenzhen i365-Tech Co.,Limited ") develops and operates the Smartgocare iOS application (“the App”), which is used solely to configure, manage, and monitor a 4G LTE SOS GPS locator watch (“the Device”) worn by older adults or other vulnerable individuals who may require rapid assistance. The App is designed exclusively for adult caregivers and is not intended for or marketed to children or teenagers. It does not contain any gaming, social-networking, photo-sharing, advertising, or entertainment features.
This Privacy Policy (“Policy”) governs your use of the App, our cloud servers, technical support, and any online services we provide (“Services”). By installing the App, creating an account, or using the Services, you agree to this Policy. If you do not agree, please uninstall the App and discontinue use.
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2. KEY DEFINITIONS
Personal Data / Personal Information refers to any information relating to an identified or identifiable natural person.
Processing refers to any operation performed on Personal Data, including collection, recording, storage, transmission, deletion, or analysis.
Controller means Smartgocare, the entity that determines how and why Personal Data is processed.
Processor refers to third-party service providers who process data on our behalf under contract.
Device Data means telemetry, identifiers, and sensor outputs sent from the GPS watch.
Account Holder refers to the adult caregiver who registers and manages a Smartgocare account.
Wearer refers to the person wearing the Device (usually an elderly individual).
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3. GUIDING PRIVACY PRINCIPLES
We are committed to the following privacy principles:
Lawfulness, Fairness & Transparency: We process data based on lawful grounds and explain our practices clearly.
Purpose Limitation: We collect data for specific, legitimate purposes and do not misuse it.
Data Minimisation: We only collect what is necessary.
Accuracy: We aim to keep your data accurate and current.
Storage Limitation: We retain data only as long as needed for legal or business purposes.
Integrity & Confidentiality: We apply strong safeguards to protect data.
Accountability & App Store Transparency: The types of data listed in Section 4 match exactly what is declared in our App Store Privacy Manifest. We regenerate the manifest for each public release and validate its accuracy automatically before publishing.
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4. THE INFORMATION WE COLLECT
4.1 Information You Provide Voluntarily
Registration data, such as your email or mobile number, password (hashed), and optional nickname or avatar.
Contact information, if you use the “Import Contacts” function. Only names and phone numbers that you manually select are uploaded; we do not collect postal addresses, birthdays, or notes.
Support requests you send to our email.
Optional responses to product surveys.
4.2 Information from Third Parties
We do not collect data from marketing databases or social networks. The only third-party sources are:
Analytics from Apple MapKit about map tile performance (anonymized and non-identifiable).
Aggregated install and crash data from the App Store.
4.3 Information We Do Not Collect
We do not collect:
Photos, camera, microphone, or audio/video content.
Health data such as heart rate, blood oxygen, or step count.
Device advertising identifiers or ad-tracking tools.
Internet browsing history, email content, or unrelated app usage.
5. iOS PERMISSIONS WE REQUEST AND HOW TO MANAGE THEM
We request the following permissions:
Location: To display the Device on a map, draw geofences, and calculate distances. If denied, map and geofence functions may not work, but SOS alerts will still function. You can manage this in your iPhone's settings under Smartgocare > Location.
Contacts: To let you import emergency contact numbers more easily. You can also type numbers manually. To disable, go to Settings > Privacy & Security > Contacts.
Notifications: To deliver critical alerts. You can disable this in Settings > Notifications > Smartgocare.
We do not request access to photos, Bluetooth, camera, microphone, calendar, motion sensors, or HealthKit.
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6. LEGAL BASES FOR PROCESSING
We process your data based on:
Contractual necessity: To create your account, send alerts, and provide core Services.
Legitimate interest: For safety, fraud prevention, and performance improvement.
Consent: For accessing your contacts or location. You can withdraw consent anytime.
Legal obligations: To comply with telecom, tax, or product safety laws.
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7. HOW WE USE PERSONAL DATA
7.1 Location data and activity tracking
We use this capability only to deliver alert notifications and to display your current and historical locations and routes, enabling safety collaboration with your authorized contacts.
We use your location information solely to provide a better service experience (e.g., alert notifications, historical route viewing). We do not use your location information for any other purpose without your consent, such as selling it to third parties for commercial promotion.
Before collecting location information, we clearly inform you of the purpose, scope, and methods of collection. For example, this Privacy Policy describes location-data collection in detail, and we only collect such data after obtaining your explicit consent.
Because one of the app’s primary scenarios is allowing users to query their own and friends’ historical and online locations, location services are foundational. When you enable location features and use location-based services, we obtain device location information (including IP address, GPS location, and sensor information from WLAN access points, Bluetooth, and cellular base stations) so that you can view your own and your friends’ locations.
After you grant location permission, the app tracks activity according to the location interval configured by you or your device, solely to implement core features: viewing historical locations and routes, and delivering alert notifications.
7.2 Friend visibility and authorization
Your location and routes are recorded and—subject to your authorization—can be viewed by your friends or designated guardian contacts. You can also view your own and your friends’ locations.
You may revoke a friend’s access at any time by deleting the friend or blocking that friend’s visibility.
Unless otherwise required by law, we retain location information only for the period necessary to provide the services. For more information, see the “Data Retention & Disposal” section.
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We use your data to:
1. Authenticate your account and enable password reset.
2. Pair and configure your watch.
3. Display real-time location and history.
4. Send alerts for SOS, low battery, or geofence entry/exit.
5. Monitor app performance and troubleshoot errors.
6. Meet legal obligations like audit or recall.
7. Create encrypted backups and ensure data availability.
We do not use personal data for profiling, advertising, or automated decision-making that has legal or similar consequences.
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8. COOKIES, SDKs, DEVICE STORAGE
The App does not use web cookies or embedded browsers. Instead:
We store secure session tokens in Apple’s Keychain.
We do not use advertising, A/B testing, or third-party analytics SDKs.
We do not use any tracking pixels.
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9. HOW WE SHARE OR TRANSFER DATA
We only share data with the following trusted service providers:
Apple MapKit: for displaying map content.
Apple APNs: for delivering alerts securely.
Google Firebase Crashlytics: for anonymous crash reports.
We do not share data with advertisers, data brokers, or social platforms. If our company is merged or sold, we will notify you before transferring any data.
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10. DATA RETENTION AND DISPOSAL
We retain and dispose of your data as follows:
Account credentials are stored for the life of your account, plus 30 days.
Location history is kept for 90 days and then deleted automatically.
SOS and alert logs are retained for 12 months.
Crash reports are deleted after 180 days via Firebase.
Support tickets are retained until your case is closed, plus 24 months.
Server audit logs are kept for 18 months or longer if required by law.
Backups are encrypted and wiped within 30 days of deletion. If required by law enforcement or ongoing legal matters, data retention may be extended.
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11. YOUR PRIVACY RIGHTS
11.1 Access and Portability
You can export your personal data and location history in JSON, CSV, GPX, or KML formats from within the app.
11.2 Rectification
You can edit your email, phone number, and nickname in the app. For device identifiers like IMEI, please contact support.
11.3 Restriction and Objection
You may opt out of Crashlytics or analytics tracking through settings.
11.4 Automated Decisions
We do not make any legally impactful decisions automatically. You may request a manual review if you believe a server-side action affects you unfairly.
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12. CALIFORNIA AND U.S. STATE PRIVACY RIGHTS
We do not sell or share your data under CCPA/CPRA definitions.
We process geolocation data only to deliver the intended services.
Global Privacy Control (GPC) signals are respected and disable optional analytics.
We do not share data with third parties for marketing.
13. Account cancellation
You can cancel your account from the app’s top-left “More” menu. We complete cancellation within 15 business days. After cancellation, all service records and data tied to the account are deleted or anonymized, except where laws require retention. Access is revoked immediately upon submitting the request. Encrypted backups are erased or anonymized within 30 days of deletion. If you sign in again before cancellation is completed, we treat that as a withdrawal of your request.
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14. NO USE BY CHILDREN
Our app is intended for users age 16 and older. We do not knowingly collect data from minors. If we discover such data, it will be erased. Parents may contact us to request deletion.
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15. CHANGES TO THIS POLICY
We may update this Policy for legal or operational reasons. You will be notified of any significant changes via the app and our website at least 7 days in advance. Continued use indicates your acceptance.
16. CONTACT US
Data Controller: Smartgocare
Email (Privacy/Data Protection): [support@smartgocare.com](mailto:support@smartgocare.com)
Email (General Support): [support@smartgocare.com](mailto:support@smartgocare.com)
We aim to respond to privacy inquiries within 10 business days and resolve formal complaints within 30 calendar days.