Privacy Policy

Last updated: June 2025

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL DATA MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD,AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.

1. INTRODUCTION

Nearsy("we,""us" or"our") takes your privacy seriously. This Privacy Policy("Privacy Policy") explains our data protection policy and describes the types of information we may process when you install and/or use"Nearsy" software application for mobile devices(the"App","our App").

When we refer to personal data(or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

This Privacy Policyapplies to all users of the App regardless of where they are located.

2.INFORMATION WE PROCESS

There are several categories of information that can be processed.

Functional Information

We ask for and process the following personal information when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.

Activity Information directly related to your use of the App,i.e. your profile with username and photo(if you choose to add them to profile), geolocation data, location and route history, added by you place names and addresses, list of selected friends and family members, location sharing state, battery status. We process your traffic and location data automatically through GPS, WiFi, or wireless network triangulation for the requested location-based services, not to identify you. If you turn off location sharing we will not share your location with your selected friends and family members.

We process this information by ourselves. Nevertheless, we may also engage third parties for storing this personal data in order to fulfill obligations and deliver the full scope of services. This personal data can be deleted either by these third parties in accordance with our instructions or by our own means.

After you grant us the relevant permission, we may also gain technical access to your contact list(to match contact details) and the camera roll on your device. However, we do not collect, store, or use the data from your contact list or camera roll. All files that might be processed stored locally on your device, they are inaccessible to us. Only you can share files to certain parties by exporting them through the App.

You can change access permissions at any time through the Settings app on your device. For more details and instructions, please visit Google Play Support.

Information associated with your account within the App(Authorization data). You may choose to register within the App using your Google Account. In this case the following categories of data will be processed: method of registration in the App,email address, name,and photo(if you choose to add them to your profile).

If you remove the App from your device but do not delete your account within the App, we will continue to store the information associated with your account for a certain period of time.

Suppose you choose to delete your account within the App, all the saved information associated with your account will be erased without recovery and you will no longer have access to such information or opportunity to restore it.In case you log out of your account within the App, your history will be deleted from your device. You will be able to access your history when you log in to the same account again.

Contact Information(name,e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, support form. We collect, store and process it by our cloud storage provider. We use such information to respond effectively to your inquiry, fulfill your requests,and send you communications that you request and perform the requested services.

Information That Is Processed Automatically

When you use the App, some information about your device and your user behavior may be processed automatically.This information is generally non-personal, i.e.it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interests in improving our App and giving our users the best experience. If we do not access such data we may not be able to provide you with all the features of the App.

We use third-party automatic data processing technologies to analyze certain information sent by your device via our App(advertising or analytics tools). Some of them launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you,in particular to analyze or predict aspects concerning your personal preferences,interests,behavior,location or movements(see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first launch the App.

Device Details. When you use a mobile device to access our App, some details about your device are reported, including"device identifiers". Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device(but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.

Cookies and similar technologies. When you use the App, cookies and similar technologies may be used(pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links or ads they dicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.

Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.

Ad-related information.The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was"dicked"or if it was shown as a"conversion" event; what the ad offer is about; what type of ad it is(e.g.,text,image, or video); which ad placement is involved(where the ad offer is displayed within the App); whether you respond to the ad.

In-app events. When you use our App, analytics tools automatically record your activity information(tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).

Subscription details: information about your subscriptions in the App(subscription ID, subscription start date, its duration, payment receipts); information about the account that you create when you get registered(email,date of registration,etc.);login history.

Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means(not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties(see Section IV).

Payment Information

Our e-commerce provider(Google) is responsible for billing, processing and charging for in-app purchases, handles your personal information and keeps it absolutely safe and secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information.

3. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a) To make our service available. We use functional information and information that is processed automatically to provide you with all requested services.

(b) To improve, test and monitor the effectiveness of our App. We use the information that is processed automatically to better understand user behavior and trends,detect potential outages and technical issues,to operate,protect,improve,and optimize our App.

(c) To provide you with interest-based(behavioral) advertising or other targeted content. We may use the information that is processed automatically for marketing purposes(to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.

(d) To communicate with you. We use the information we have to communicate with you through newsletters, i.e.to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

(e) To prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy Policy.

4. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy Policy. We adhere to the U.S. Digital Advertising Alliance's Self-Regulatory Principles for the Mobile Environment.

Please note that while integrating external services we choose third parties that can assure they apply all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like log files,and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties' tracking technologies or how they may be used.

We may also share certain information such as cookie data with third-party advertising partners.This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

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

In case you want to learn more about these services and their privacy options(including opt-out) please consult the correspondent websites and privacy policies. We are not responsible for any usage of your personal data by the abovementioned third parties in violation of our instructions.

Our App may contain links to third-party websites/ services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

5.INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S.law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received,in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data- if possible- before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

6. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period(but no longer than the storage purpose requires) if information is necessary to comply with legal obligation(taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

7. USER PRIVACY RIGHTS

Applicable data protection laws give you the following rights regarding your personal information:

The Right to Know(also referred to as the Right to Access). You have the right to obtain a confirmation as to whether or not personal data concerning you is being processed. Additionally, you can request a copy of personal data we hold about you and additional details on how such data is processed.

The Right to Data Portability. You are entitled to request your personal information in a portable,structured and machine-readible format that makes it easier to reuse such information or transfer it directly to another service, move it wherever you want.

The Right to Correct Inaccuracies(also referred to as the Right to Rectification). Where you cannot update your data by yourself through your account(if available) or the App settings, you can ask us to correct,change, complete or rectify your data.

The Right to Data Deletion(also referred to as the Right to Erasure or the Right to Be Forgotten). You have the right to request the deletion of all or some pieces of your personal data we process. In this regard you should bear in mind that applicable data protection laws may provide exceptions to the Right to Data Deletion,which means that under certain circumstances we may need to keep some pieces of your data to comply with legal obligations,detect fraud,exercising or defence of legal claims,for other legal reasons.Therefore,upon receiving your verified request, we'll delete your personal data and direct our service providers to do the same unless a legal exception applies.

The Right to Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is processed. These specific circumstances are addressed in data protection laws that may apply to you. For example, you can ask for restriction of data processing in the case of disputed accuracy: if you believe that the personal data we hold about you is inaccurate, you can request a restriction of processing while we verify its accuracy.

The Right to Object to Processing of Personal Data. When your personal information is processed automatically with the involvement of third party service providers, you may object to such processing in some circumstances. Additionally, when your personal information is processed for direct marketing purposes,you may ask to cease processing your data for these direct marketing purposes. In order right to object please submit us the corresponding request. You may also contact the third party service providers listed in the Section IV of this Privacy Policy to learn how you can object to their processing of your data. Most of them have dear instructions on their privacy pages, functional API or other options.

To exercise any of the rights described above, you can contact us through contact form. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.

You also have the right to lodge a complaint with your local data protection or a supervisory authority if you reasonably believe that your rights under applicable data protection laws have been breached. Please note that when you exercise your right to lodge a complaint with your local data protection or a supervisory authority, you may be required to provide additional information and support your complaint with sufficient objective evidence. By lodging a complaint you agree to provide sufficient explanation as to what you believe impaired your rights. Additionally, in some cases prior to lodging a complaint with your local data protection or a supervisory authority, you may be required to send your initial daim directly to us and ask for clarifications if necessary.

If you are located in the European Union, you may address our representative when you have questions on privacy issues: forextrends2017@gmail.com

8.HOW TO OPT OUT

Opt-out of marketing tracking

You can manage your activity tracking permissions via device settings. If you don't want third-party service providers to use your Advertising ID for the purpose of delivering you personalized ads on the basis of your interests please follow the instructions below:

For Android devices with Android 12 and lower: go to Settings> Privacy> Ads, then you can choose either to"Reset advertising ID" or to"Delete advertising ID".

For Android devices with Android 13 and up: go to Settings> Security& privacy> More privacy settings> Ads,then you can choose either to"Reset advertising ID" or to"Delete advertising ID".

If you choose to"Reset advertising ID", your current ID will be replaced with a new one. Apps can still show you personalized ads, but they may be less relevant or interesting for a while.

If you choose to"Delete advertising ID", your advertising ID will be permanently deleted, and a new one will not be assigned. You will no longer see ads based on this advertising ID. Apps can still display ads, but they may be less relevant or interesting to you.

Additional information can be found here: Google Policies – Advertising Identifiers (see the subsection “Advertising identifiers for mobile apps”).

Opt-out of Location Data Processing

You can manage, control when and which apps on your device have access to your device location data. For this purpose see the instructions below.

For Android devices: turn Location off for the applicable Product via the menu “Settings > Apps > [applicable Product] > Permissions > Location > Select one of the available options” or “Settings > Location > App Permissions >Tap the App > Select one of the available options”.

You can find more information here: Google Support.

9. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through the email or contact form displayed below.

10. CHILDREN’S PRIVACY

Our App is not intended for children. Therefore, we do not knowingly or intentionally collect or solicit any personal information from children. For the purposes of this Section X the terms “child” and/or “children” in the context of data processing activities may be interpreted on a case-by-case basis as prescribed by applicable data protection laws. No one who is considered a “child” under applicable data protection laws is allowed to directly provide any personal information to the App.

As a general rule we consider a person under the age of 16 to be regarded as “a child” until we have legal grounds to conclude that a person under 16 should be treated as an adult as per provisions of local data protection rules or based on the parent authorization provided to us directly.

Solely the holders of parental responsibility are liable for preventing their children from providing personal information via the App without relevant verifiable parental consent. If we learn that we have collected personal information from a child without verification of parental consent, we will erase that information as quickly as possible. If you reasonably believe that we might have any information from or about a child, or a child has directly provided us with personal information via the App without verifiable parental consent, please contact us.

11. CHANGES TO THE PRIVACY POLICY

This Privacy Policy is updated regularly.

Whenever we change this Privacy Policy, we will post those changes to this Privacy Policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

12. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us at forextrends2017@gmail.com.