Privacy Policy

This policy explains what our apps do with your information, in plain terms. The short version: we operate no servers of our own, we receive no personal data from the apps directly, and your coordinates are never sent to us. The limited advertising and analytics data described below is collected and held by Google, under Google's own terms, and not by us.

1. Who we are

These apps are made by Jason Attard ("we", "us", "our"), an individual based in Malta, who is the data controller for the limited processing described in this policy. "NinjApps" is simply the name the apps are published under; it is not a company, and there is no separate legal entity behind it.

You can reach us at studio@ninjapps.com. We answer privacy questions ourselves; there is no separate team to route you through. If you need a postal address for a formal request, ask and we will give you one.

We are not required to appoint a data protection officer, because we do not carry out large-scale monitoring or large-scale processing of special category data. Privacy questions go to the address above.

2. Which apps this covers

• Find Me: GPS Coordinates, and Find Me: GPS Coordinates + (the ad-free edition)
• Find My Car: Where I Parked, and Find My Car: Where I Parked + (the ad-free edition)

Where something applies only to the free editions, which show ads, we say so. This policy covers these apps only. It does not cover the app stores you download them from, or any other service you reach from them.

3. Your location, and where it goes

This matters most, so it comes first.

When you ask for a location fix, the app reads your device's position using the operating system's location services. That position is shown on your screen and, in Find My Car, saved on your device so you can return to it.

We never receive your coordinates. We have no server for them to be sent to. Your position leaves your device in only three situations:

• To turn coordinates into an address. The app asks your operating system's geocoding service (Apple on iOS, Google on Android) to look up the address for your coordinates. That lookup is handled by Apple or Google as independent controllers, under their own privacy policies, and we do not receive the result of it.
• When you choose to send it. Using Copy, Share, or Map hands the coordinates to whatever app or person you pick. That is your action, and where it goes from there is outside our control.
• Advertising, in the free editions only, and only if you consent. See section 4.

Giving us location access is not a legal or contractual requirement, and you are not obliged to do it. You can refuse or withdraw it at any time in your device settings. The only consequence is practical: the apps remain usable with location switched off, but they cannot show or save a position until you allow access and ask for a fix.

4. Advertising (free editions only)

The free editions are funded by ads served through Google AdMob. The ad-free editions contain no advertising code and this section does not apply to them.

To show ads, Google may store and read information on your device, including advertising identifiers, and may use it to select and measure ads. Depending on the consent you give, Google and its advertising partners may also use device information and location data for personalised advertising. Google determines how it uses that data for its own purposes, and acts as an independent controller when it does.

How your choice is collected. In the European Economic Area, the United Kingdom and Switzerland, the app shows Google's consent form before requesting any ad. No ad is requested until you have answered it. Outside those regions, ads are served without a consent form where local law permits.

How to change your mind. You can reopen the consent options from within the app at any time and withdraw or change your consent. Withdrawing consent does not remove ads; it limits how your data may be used to select them. Your device settings also let you reset your advertising identifier or ask apps not to use it.

Tracking. Our apps do not use Apple's App Tracking Transparency framework and do not request the advertising identifier on iOS. On iOS, ad measurement uses Apple's own privacy-preserving attribution instead.

Google's handling of this data is governed by its own policies: how Google uses data in AdMob and the Google Privacy Policy. We do not control those policies and cannot vary them on your behalf.

5. Analytics

We use Google Analytics for Firebase to understand how the apps are used in aggregate, for example how many people who open the app reach a location fix.

Analytics starts when you open the app. We rely on our legitimate interest in understanding how the apps are used well enough to improve them, balanced against what is actually collected: aggregate counts, no location, no contact details, and nothing that lets us identify you. There is currently no in-app switch for analytics. Deleting the app stops it, and your device settings let you reset or restrict the identifiers Google may use.

We deliberately log almost nothing. The events we record carry only short, fixed values from a closed list, such as whether a location permission was granted or refused, that coordinates were shown, which button was pressed, and how a purchase ended. There is no field anywhere in the app that accepts free text.

We do not log your latitude, longitude, address, place name, or a device identifier. The app has no code that sends those values to analytics.

Firebase also collects some information automatically, such as app opens, device model, operating system version, country, and a randomly generated app instance identifier. That collection is Google's, described in Google Analytics for Firebase and the Google Privacy Policy.

6. Purchases

The free editions offer a one-time purchase to remove ads, and the + editions are paid apps.

We do not process payments and never see your payment details. All purchases are handled by Apple's App Store or Google Play, as independent controllers, under their own terms and privacy policies. The app asks the store whether this account owns the purchase, and receives back only that answer. We receive no name, no email address, and no card information.

Refunds are handled by the store, not by us. See our support page for how to request one.

7. Who else is involved

These are the categories of recipient that may handle information from the apps:

• Google, for advertising in the free editions, for analytics where you have agreed to it, for address lookups on Android, and for purchases made through Google Play.
• Apple, for address lookups on iOS, ad measurement on iOS, and purchases made through the App Store.
• Anyone you choose to send a location to, when you use Copy, Share or Map.

There are no others. We do not use data brokers, advertising exchanges of our own, customer relationship tools, crash reporting services beyond the platform defaults, or any other third-party service that receives your personal data from us.

8. What we do not do

• We do not ask you to create an account, and we do not ask for your name, email address, phone number, or date of birth.
• We do not sell your personal data, and we never have.
• We operate no servers or databases of our own, so we hold no store of user data to search, leak, or hand over.
• We do not combine data across our apps to build a profile of you.

9. Legal bases for processing

Where the UK GDPR or the EU GDPR applies, we rely on the following:

• Providing the app's core function (reading your position, showing it, saving a parking location on your device): necessary to deliver the service you asked for.
• Personalised advertising and storing information on your device for advertising, in the free editions: your consent, collected through the form described in section 4, and withdrawable at any time.
• Analytics: our legitimate interest in understanding how the apps are used well enough to improve them, balanced against the fact that the data is aggregate and carries no location, no contact details and nothing that identifies you to us. You can object to processing based on legitimate interests; see section 13.
• Purchases and restoring them: necessary to perform the transaction you entered into.

10. Automated decisions and profiling

We make no automated decisions about you that produce legal effects or similarly significantly affect you. Nothing in the apps scores, ranks, screens or profiles you, and no decision about you is taken by us at all.

Where you consent to personalised advertising in the free editions, Google may use profiling to choose which ads to show. That profiling is Google's, carried out under its own policies linked in section 4, and it affects only which advertisement appears.

11. Retention

Anything the app saves for you, such as a parking location or your preferences, stays on your device and is deleted when you delete the app. We do not control that copy and cannot retrieve or remove it remotely.

We hold no personal data ourselves, so we have nothing to retain or delete on our side. Analytics data is held by Google and deleted automatically at the end of the retention period set in our Firebase configuration; we do not extend it, and you can ask us what that period currently is. Advertising data is retained by Google under its own retention periods, described in the policies linked above.

Email you send us is kept only as long as needed to deal with what you asked about, and to keep a record that we answered.

12. International transfers

Google and Apple are global companies and may process the data described above outside your country, including in the United States. Those transfers are made under the safeguards those companies put in place, which for their US entities include certification under the EU-US Data Privacy Framework and its UK extension, and standard contractual clauses approved by the European Commission where certification does not cover a particular flow. Because we send nothing ourselves, we make no international transfers of our own.

13. Your rights in the EEA and the UK

If the EU or UK GDPR applies to you, you have the right to request access to your personal data, correction, erasure, restriction of processing, portability, and to object to processing based on legitimate interests. Where we rely on consent, you can withdraw it at any time, without affecting anything done before you withdrew it.

In practice, the fastest route for most of these is your own device and the companies that hold the data: your device settings control location access and your advertising identifier, the in-app privacy options control advertising and analytics consent, and deleting the app removes everything stored locally.

For anything you want from us, write to studio@ninjapps.com. We will respond within one month, and will tell you if we need to extend that by up to two further months because the request is complex or there are several of them. Be aware that because we hold no identifiable data about you, we usually cannot locate "your" records, and will explain that rather than guess. Where we cannot identify you from the data we hold, we may ask for information that helps us do so, and we may decline a request we cannot tie to you.

Requests are free. Where a request is manifestly unfounded or excessive, in particular because it repeats, the law allows us to charge a reasonable fee or to refuse it, and we will explain our reasons if that ever happens.

If you are unhappy with how we have handled a request, you can complain to your local data protection authority. In Malta, where we are based, that is the Office of the Information and Data Protection Commissioner.

14. US state privacy rights

This section applies to residents of US states with comprehensive privacy laws, including California, and only to the extent those laws apply to us.

In the twelve months before the date of this policy, the categories of personal information involved in the free editions have been identifiers, specifically advertising and app instance identifiers, internet or network activity such as which screens and buttons were used, approximate or precise location where you allowed it and consented to its use for ads, and inferences drawn by Google for advertising. This information is collected on your device by Google's advertising and analytics components, for advertising, measurement and product improvement, as described in sections 4 and 5.

We do not sell personal information, and we have never done so. Where you allow personalised advertising, information from your device is made available to Google and its advertising partners for advertising across services, which some US state laws treat as "sharing" or as "targeted advertising" even though no money changes hands, and which you can stop at any time.

Depending on your state, you may have the right to know what personal information is collected, to access or delete it, to correct it, to opt out of targeted advertising and of any sale or sharing, to limit the use of sensitive personal information, and not to be discriminated against for exercising those rights. Precise geolocation is treated as sensitive personal information; ours is used only for the purposes described in section 3 and for advertising where you have agreed to it.

To exercise any of these, open the privacy options inside the app and turn off personalised advertising, or write to studio@ninjapps.com. We will respond within the time your state's law allows. An authorised agent may make a request on your behalf with written proof of authority. Because we hold no account or contact details, we may be unable to identify you or to locate information beyond what your own device and the in-app options control, and we will tell you plainly when that is the case.

15. Children

Our apps are general-purpose utilities. They are not directed at children, they are not listed in any children's category, and we do not knowingly collect personal data from children.

In the European Economic Area and the United Kingdom, where consent is the basis for advertising or analytics in the free editions, that consent should be given by someone who has reached the age set by their own country's law, which is between 13 and 16 depending on the country, or by a parent or guardian on their behalf.

In the United States, we do not knowingly collect personal information from children under 13, as those terms are used in the Children's Online Privacy Protection Act. If you believe a child has provided information through our apps, or has used them in a way that needs our attention, contact us and we will act on it, including switching off advertising personalisation for that install where we are able to.

16. Security

Because your location and preferences stay on your device, their security depends largely on your device: a passcode, up-to-date software, and not jailbreaking or rooting it all help. For the limited data handled by Apple and Google, we rely on the security measures those companies apply, which are theirs to design and operate rather than ours. No app or service can promise absolute security, and we do not.

17. Other services and links

The apps and this site can hand you off to services we do not run, such as your maps app, your email app, an app store, or a page you open from a link. Once you are there, that service's own privacy policy governs what it does, and we have no control over and take no responsibility for how it handles your information.

18. Changes to this policy

We will update this page when the apps change in a way that affects it, and we will move the effective date and the last updated date at the top. Significant changes to how we use your data will be flagged in the app where we can, and where the law requires it we will ask for your consent again rather than assume it. Continuing to use the apps after a change means you accept the updated policy.

This policy describes our privacy practices. Your agreement with us is set out in the Terms and Conditions.

19. Contact

Questions, requests, or corrections: studio@ninjapps.com. A real person reads it.