Privacy at FamiloApp

• FamiloApp is one of the world's best apps in terms of privacy of your data
• A transfer of your data for advertising purpose does not take place
• You can use FamiloApp with a synonym
• Your data will be transferred with TLS/SSL encryption
• You can log out of FamiloApp at any time or contact us to get your personal data deleted
• All data and permissions processed by FamiloApp follow the clear purpose to enable a specific feature of the app
• We take all available measures to ensure the security of the app, data transmission and our servers
• If you limit your location mode, (Location mode “Places only” or “Invisible”) your location will only be transmitted according to the selected mode
• There is no other publication of your content (for example text, images, audio or video) other than to share with your contacts
• By integrated data privacy settings in the app you can access and change your privacy settings at any time
• We comply with the German Bundesdatenschutzgesetz (BDSG) as well as the EU General Data Protection Regulation (GDPR)

This privacy statement applies specifically to the FamiloApp smartphone app. If some content applies to content on our website www.familo.net www.familo.net we will specifically point that out.

When collecting, processing and storing your personal data, we comply with the legal requirements in Germany and the European Union. These can be found in the “Bundesdatenschutzgesetz” (BDSG) and the “Telemediengesetz” (TMG) as well as in the EU General Data Protection Regulation (GDPR). The legal basis for processing personally identifiable data (PII) is Art. 6 I f) EU GDPR. In order to implement these specific laws we focus on the publication “Orientierungshilfe zu den Datenschutzanforderungen an App-Entwickler und App-Anbieter” of the “Düsseldorfer Kreis”, an association of German data protection authorities, published on 16th of June 2014. In this document the authorities point out which data protection and technical requirements for the development and deployment of mobile applications apply. Also, we fulfill the requirements of the EU General Data Protection Regulation (GDPR).

Personal data entered by you during registration (inventory data) which we store until the deletion of your account:

• Mobile phone number (MSISDN)
• Username (use of a pseudonym is possible)
• E-mail address (optional)
• Gender (optional)
• Date of Birth (optional)

The following data is collected and processed during your use of the app FamiloApp (technical data):

• IP address (stored in server logs for security purposes only)
• Device and card identifier (UDID, ANDROID_ID, IDFA; stored until account deletion)
• Location data, device settings and network carrier (only last state is cached without permanent storage)
• Usage data (for example, messages, alerts, pictures; we store only the past 300 activities per circle)
• Contacts in your phone book: These are processed, but not saved. By hashing we can not see the user’s data on the server side, unless they are also registered on FamiloApp.
• Purchase receipts (in-app purchases; stored until account deletion)

All permissions requested by the app serve the purpose to provide you a specific feature within the FamiloApp app. All processed data also serves to provide you a specific feature of FamiloApp or to improve your experience of usage.

Permissions on Android devices:

In-app purchases: To make in-app purchases of premium features available
Identity: Management of the FamiloApp user accounts
Contacts: To add other people to your group
Location: To share your location with your group members
SMS: To send invitation SMS to your group members
Photos: sending pictures and create your profile image
WiFi: information about whether you have an active Internet connection
Device ID: verifying your phone number when registering

Permissions on iOS devices:

Camera / Photos: To send pictures and create your profile image
Microphone: To send voice messages to your group members
Contacts: To invite your group members to FamiloApp
Location: To share your location with your group members
Notifications: Automatic alerts when someone arrives at a location, or sends a message
Background Updates: Update your location even when the app is not running in the foreground
Mobile data: Transmission of messages, images and location

• For the collection, processing and transmission of your usage data we request you to give electronic consent at the beginning of your FamiloApp usage.
  • Before registration, you will be notified that by registering you agree to our privacy policy and terms of use.
  • You can open our privacy policy and terms of use and read them directly from the registration screen.
  • You are informed in our privacy policy and terms of use that your consent can be revoked at any time, for example, by deleting your user account or by e-mailing us.
• The manually entered data (mobile number, pseudonym username) are required to enable the use of the FamiloApp app and its features. The optional input of additional data (e-mail address, gender and birthdate) improves the user experience of the app for you.
• You can use FamiloApp by entering a pseudonym. There is no need to enter your real name in the app. To register you don't have to use your actual mobile number and can use another one which you can access. In this case, the verification code will be sent to this other number.
• For the app and all of its features to work properly, automatic collection and use of additional data is required during sessions (see section "What kind of data do we collect?").
• Your user account is created using a randomized user ID (technically as 12-byte ObjectId value). We use this account to authenticate users and ensure system security for example.
• After you granted FamiloApp access to your address book, we will propose contacts to connect with, which are also registered on FamiloApp. You can connect with others and share content with them within FamiloApp. The contacts in your address book will be processed but not stored. Through so-called hashing, we can not see any specific contacts on the server side, unless they are also registered on FamiloApp.
• All data is collected and processed by FamiloApp in the minimum necessity to guarantee the functionality of the app. Regarding location data, for example, our users expect a very high accuracy, which is why we provide it to our users in this form.
• If the user has chosen a less accurate location mode ("Places only" or "Invisible") in the app, the location is not detected by us permanently, but only in the moments required for these respective functions.
• By offering personalized and prominent adjustable location modes for users we follow the "privacy by design" principle.
• There is no other publication of user-generated app content (for example text, images, audio or video content) outside the group of users by FamiloApp.
• A processing of your data for advertising purposes for third parties does not take place.
• A collection and processing of your data for billing purposes payment transactions will not take place.
• The FamiloApp app collects and processes data with increased protection requirements.

To improve the features of the FamiloApp app as well as your user experience continually, we perform aggregated analyses of the app usage. To achieve the best possible analysis of this data, we rely on specialized third party services. Third parties must agree to our restrictions in terms of access, storage and use of your personal data. For that we do contractual arrangements (for example, with a contract for data processing) and technical measures to restrict possible misuse of such information by the third party, but we do not take any liability for any third party to comply with these restrictions and agreements. The transfer takes place exclusively through a TLS/SSL encryption. The following services receive specific data for further processing.

We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our services:

Entity name	Services performed	Entity location	Link to Privacy Policy
Facebook	Analytics / ad management service provider	USA	Privacy Policy
Appsflyer	Deeplinking, analytics services, events tracking provider	USA	Privacy Policy
Amplitude	Product analytics, events tracking	USA	Privacy Policy
Google	Analytics service provider, Maps integration	USA	Privacy Policy
Firebase Crashlytics (Google LLC)	User authentication, analytics, marketing service provider	USA	Privacy Policy, Firebase Policy
Purchasely	Paywalls management	USA	Privacy Policy

In order to improve our service for you, we use data generated while using the FamiloApp app. This includes better understanding of app usage in order to better tailor FamiloApp's service offerings to the needs of our customers. According to Art. 6 I f) EU GDPR we have a legitimate interest to collect such statistical data values. It comprises the following data points: app starts, session lengths feature usage, IP address, Mobile ad IDs, Installation UUID, Android IDs. For tracking these data points, creating statistics and derive improvement analysis we handover this data to the following third party services:

• Localytics
• Fabric
• Firebase
• Google Analytics

You can stop this processing of your data anytime by selecting the according setting under "Data Privacy" in the main menu of the FamiloApp app.

You can delete your personal user data by the deletion of your user account in the FamiloApp app or by contacting us to arrange the deletion of all personal information from our servers (see section Who is responsible and how do I contact FamiloApp?).

You can access and export all personal data that we store about you to you or a third party by contacting us (see section Who is responsible and how do I contact FamiloApp?).

We take all reasonable technical and organizational actions to ensure the security of the app, the data transmission and our server (Technical data privacy). To prevent unauthorized access or unauthorized disclosure and to ensure the accuracy of the data and the legitimate use of the data, we have the appropriate technical and organizational procedures to secure the data, which is handled in the FamiloApp app.

• Your registration and authentication in the app is done through a unique code which is sent via SMS to you and then has to be typed into the app. Thus, we provide a level of security as high as in mobile TAN processing in online banking.
• The transfer of data to our server backend is handled via a secure TLS/SSL encryption by using a HTTPS protocol. A transport encryption is added.
• The local storage on the device takes place only to the extent as is necessary for providing the features of FamiloApp. When uninstalling the app we will erase all data from the device. On Android device data stored on the external memory of the device might be retained even when uninstalling the app.
• A logging within the app will take place during the use of FamiloApp. FamiloApp has no access to this data by default. You can send this data manually to us via mail, so we can troubleshoot and improve your user experience of the app.
• Some particular screens within the FamiloApp app will be loaded as Web pages. These are exclusively FamiloApp-owned web pages and no third party websites.
• Our server backend is subject to various safety and security mechanisms: You authenticate yourself and gain access with an individually created token based on your own data. This is a secure authentication. Firewalls and regular security updates are applied.

Your Internet browser automatically transmits data to our web server when accessing our website www.familo.net. This includes the date and time of access, URL of the referring website, retrieved file, amount of data sent, browser type and version, operating system and your IP address. This data is stored as log files.

We do not use any web analytics service for the data collected on our website. Also we do not store any Cookies in your web browser while visiting our website.

Both in the imprint of the app and on our website, in our Privacy Policy and our App Store pages you will find our contact information. To get in touch with us:

FamiloApp GmbH
Carl-Petersen-Straße 101
20535 Hamburg, Germany
Registered Office: Hamburg, Hamburg District Court HRB 157046
Managing Directors: Lars Christiansen

If you have questions or suggestions regarding data protection, you can easily contact us at support@familo.net.

Both within the app, and on our website, and on our App Store page there is an easily searchable imprint with all relevant information and ways to contact FamiloApp.

Our privacy statement is easily accessible at any time, it is also available during the use of the app, from our website and from our App Store pages. We update this Privacy Policy regularly to altered functionality in the FamiloApp app. This latest version is dated 10th June 2019.