Privacy Policy

LOCATER (the “Locater”, “us”, “our” or “we”) and its affilicates understand the importce of your privacy to you and will respect your privacy. The LOCATER Privacy Policy (“this Policy”) applies to the products and services that we provide and the extensions thereof, including various products and services that we provide to you through the LOCATER Mobile Applications, our official website, our client, and new forms emerging with technology (“our Platform”). If a separate privacy policy or terms of use exists for a specific product or service, the privacy policy or terms of service for that product or service will prevail. If the privacy policy or terms of service for the product or service is not covered by such product or service, this Policy shall prevail. If one of our affiliated companies uses the products or servcies provided by us in their product or services but does not set up a separate privacy policy, this Policy shall also apply to such products or services. Unless otherwise agreed, the terms used in this Policy shall have the same meaning as those defined in the LOCATER Terms of Service.

If you are a minor or a person without full capacity(“minor” or “minors”) under the laws of the jurisdiction in which you reside, please carefully read and fully understand this Policy in the company of your legal guardian and use LOCATER products and services after obtaining the consent of your legal guardian.
Please read the Policy carefully (especially the bolded content) and make sure you understand our rules for processing your personal information. We will process your personal information appropriately based on lawful and legitimate means and in good faith, in accordance with current laws and regulations. If you have any questions about this Policy, you can contact us through the contact information posted on our Platform.

1. Applicability of This Privacy Policy
1.1 Scope

This Privacy Policy applies to the LOCATER Services provided on LOCATER mobile applications and other websites owned by LOCATER, as well as other interactions (e.g., customer service requests, user conferences, etc.) you may have it with us.

LOCATER services specifically include:

  • LOCATER mobile application User Account;
  • The purchase of physical products through the LOCATER website.
1.2 Consent

If you do not agree with the terms of our Privacy Policy, do not access or use the LOCATER Services, the LOCATER mobile applications, or any other aspect of our business.

1.3 Third Party Providers

This Privacy Policy does not apply to any third party applications or software that are integrated with the LOCATER Services through the LOCATER mobile applications, or any other products, services or businesses of any other third party.

2. How We Collect and Receive Your Personal Information
2.1 Registration Data

When you sign up for a LOCATER mobile User Account, we receive the following information from you.

  • Your first and last name, phone number, email address and password. This is mandatory information.
  • If voluntarily provided by you, your personal profile photos, the tracked object or person related information that allows identification of its owner, such as the GPS location of your mobile device.

When registering via social logins like Google, Facebook and Apple, we receive your first and last name and email address.

2.2 Other Information
  • We also collect, generate and recieve other information and data.
  • LOCATER Service Metadata. When you use the LOCATER Services, metadata is generated that provides additional context about the way you use the LOCATER Services. For example, we may log features, content, links or Third Party Services that you have viewed or used.
  • Log Data. Like most mobile applications, LOCATER Services also automatically collects log information from LOACATER mobile application, such as app version, usage data and error reports, to enhance app performance and security.
  • Device Information. We also collect information about devices used to access the LOCATER Services, including information on the type of device , the operating system, device settings, application IDs, unique device identifiers, and crash data.
  • Location Information. We receive information from you and other third parties that helps us approximate your location, such as an IP address received from your device. We may also collect location information from devices in accordance with the setting of your device.
  • Text Messages. With your consent as required by applicable law, we may send marketing and service-related text messages to your mobile device. You may opt out of receiving these messages by replying “STOP” at any time.
2.3 Automatic Collection

Generally, no one is required by law or contract to provide registration data or other information. However, certain information is collected automatically and, if certain information is not provided, we may be unable to provide LOCATER Services.

2.4 Analytics and Advertising Technologies

We may collect analytics data, or use third-party analytics tools such as Google Analytics, which may use tracking technologies, to help us measure traffic and usage trends for LOCATER Service, LOCATER mobile application and products. The types of data that analytics technologies may capture are as follows:

  • Referral/exit pages;
  • How frequently you access LOCATER Services;
  • Whether you open emails or click the links contained in emails;
  • Whether you access LOCATER Services from multiple devices;
  • The features you use;
  • The links you click;
  • The ads you view and click on;
  • Your location when you access or interact with our Products and Services;
  • Technical related information about your device and operating and/or network systems, such as IP Address and device ID
  • Information about your engagement with certain features and usage statistics;
  • Other similar actions.

The advertising partners collect and use information such as:

  • Click stream information, timestamp, hashed email adress, device ID, AdID
  • Your use of third-party applications.

And may combine this information with information they collect directly through Tracking Technologies or that they receive from other third-parties. These third party partners may use the information they have gathered independently according to their own privacy policies.

2.5 Provide Basic Services and Improve Security

To improve the security of your use of services and to more accurately prevent phishing site scams and Trojan horses, we may determine the risk of your account by knowing some of your intent usage habits, your user behavior data, user’s device information, URL access records (e.g. Device terminal type, device terminal screen resolution, device network operator, etc.) and may record URLs that we consider risky.

3. How We Use the Information We Collect

We may use and disclose your information to service providers to provide (like https://bms.hkconcox.com, and etc.), maintain, and improve LOCATER Products and Services to develop new products and features, to determine which new products or services may be of interest to you and to promote our Products and Services.

We retain the information we collect for as long as necessary to provide our Products and Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

We may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.

3.1 Administrative Purposes

We may use information about you for our administrative purposes, including to:

  • Provide the Products and Service to you;
  • Measure interest in LOCATER Products and Services;
  • Develop new LOCATER Products and Services;
  • Ensure the integrity, security and perform internal quality control and optimization of LOCATER Products and Services;
  • Verify individual identity;
  • Commuicate about individual accounts and activities utilizing LOCATER Products, Services, and system;
  • Make changes to any LOCATER policies;
  • Send messages to the email address you provide to us to verify your User Account;
  • For informational, transactional, marketing and operational purposes, such as account management, customer service, or system maintenance;
  • To process applications and transactions;
  • To prevent potentially prohibited or illegal activities;
  • To enforce our Terms of Use and this Privacy Policy.
3.2 Marketing LOCATER Products and Services

LOCATER may use information, and individuals who provide us with personal information may receive periodic emails, newsletters, mailings, or phone calls from us, as allowed by applicable law, for marketing purposes such as to:

  • Provide you with information related to LOCATER or our business partners’ products and services that may be of interest to you;
  • Notify you of upcoming special offers/events we believe may be of interest;
  • Conduct individual or market research;
  • Conduct research and drive marketing analytics;
  • Conduct online behavioral advertising;
  • Tailor content, advertisements, and offers that may be of interest to you;
  • Introduce new content, features, LOCATER Products or Services;
  • For other purposes disclosed at the time that you provide us with your information, or otherwise with your consent.
3.3 Information Collected Automatically Through the Use of Tracking Technology

We use information collected through the use of Tracking Technologies to:

  • Remember information so that you will not have to re-enter it during your visit or the next time you visit our website or use our Services;
  • Authenticate your access;
  • Keep track of your in-app specified preferences or choices;
  • Display a personalized browsing history
  • Provide custom, personalized content and information, including targeted content and advertising;
  • Record your device’s location and movements;
  • Identify and contact you across multiple devices;
  • Provide and monitor the effectiveness of our services and our marketing campaigns;
  • Monitor aggregate metrics such as total number of visitors, members, traffic, and demographic patterns;
  • Provide specific technical support (diagnose or fix technology problems reported by our members or engineers that are associated with certain IP addresses or User IDs;
  • Detect or prevent fraud or other harmful activities;
  • Automatically update our mobile application on your system and related devices; and
  • Otherwise plan for and enhance our Services.
4. How We Storage, Transfer, and Disclose Your Personal Information
4.1 Storing of Personal Information

In order to improve efficiency and reduce costs, we may outsource third-party professional service providers to process your personal information on our behalf, for example, we may hire professional service providers to provide storage services. For the companies, organizations and individuals we outsource to process personal information, we will require them to comlpy with strict confidentiality obligations and take effective confidentiality measures through written agreemenets, and require them to process your personal information only within the agreed scope of the contract, and not to use your personal information for their own benefit. We currently outsource third parties with the processing of your personal information to Ali Cloud for storing your uploaded (e.g. Images, database data).

4.2 Transfer of Personal Information

We will not transfer your personal information to any company, organization or individual, except for the following:

  • Obtain your prior consent or authorization;
  • Provided in accordance with the relevant agreement or other legal document signed with you;
  • In the event of a merger, acquisition, transfer of assets, liquidation or similar situation involving the transfer of personal information, you understand and agree that your personal information will be transferred to the relevant third party company or organization. We may require the new company or organization holding your personal information to continue to be bound by this Policy, or we may require that company or organization to seek your authorized consent again.
4.3 Disclosure of Personal Information

We will only disclose your personal information if we take security measures that are consistent with industry standards and if:

  • After obtaining your consent;
  • In the case of laws and regulations, legal proceedings, litigation or mandatory requirements by government authorities.
5. How We Protect Your Personal Information

We have taken reasonable and practicable security measures, consistent with industry standards, to protect your information from unauthorized access, disclosure, use, modification, damage or loss of personal information. We take the following steps to keep your data secure:

  • Using encryption technology to improve the security of personal information, protected by SSL protocol encryption when exchanging data between your browser and the server, providing HTTPS protocol for secure browsing;
  • Use of trusted protection mechanisms to prevent malicious attacks on personal information;
  • Deploy access control mechanisms and make every effort to ensure that only authorized personnel have access to personal information;
  • Conducting security and privacy training courses to enhance employees’ awareness of the importance of protecting personal information;
  • Specialized data complicance management systems, processes and organizations are in place to safeguard information.

We will take all reasonably practicable steps to ensure that no unrelated personal information is collected. We will retain your personal information only for the shortest period necessary to achieve the purposes described in this Policy, unless otherwise required by the laws and regulations of your location.

The internet environment is not 100% secure and we will endeavor to ensure or warrant the security of any information you send us. If our physical, technical, or administrative safeguads are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legal rights and interests, we will assume appropriate legal liability. After the unfortunate occurrence of personal information security events, we will strictly follow the requirements of the laws and regulations of your location and inform you in a timely manner of: the basic situation and possible impact of the security event, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will promptly inform you of the event-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also take the initiative to report the disposal of personal information security incidents and fulfill the obligations stipulated in other laws and regulations in accordance with the requirements of regulatory authorities.

6. How You Manage Your Personal Information
6.1 Accessing Your Information

You have the right to access your personal information as provided by law and regulation. If you wish to access and edit your personal information in your account, you may do so by logging into your account on LOCATER Mobile Application and accessing the relevant pages for personal information, changing your password, changing your profile, etc.

6.2 Deleting Your Information

Request deletion of your personal information through the LOCATER app by clicking on “Settings”, and clicking on “Delete Account” and following the on-screen instructions.

If you delete your account or other personal information, the location information will no longer be associated with your account.

6.3 Communications from LOCATER

We may periodically send you promotional newsletters and emails. You have the ability to opt-out of these by following the unsubscribe instructions provided in the emails you receive. Certain communications, like billing information and Service updates are necessary for you to receive, you will not be able to opt-out of those communications.

6.4 Location and Movement Data Collection and Sharing in the App

We collect location data and driving events and movement data from LOCATER Products to provide the LOCATER Services, and may share your personal information, including location and movement data and with third parties for crash detection, research, analytics, attribution, and tailored advertising purposes. You have many options to control this data collection and sharing activity through the APP Settings.

7. Legal Basis

We process your data in accordance with the provisions of the following:

  • The American Data Privacy and Protection Act (ADPPA)
  • The General Data Protection Regulation (GDPR)
  • Austrian data protection laws, such as the Data Protection Act
  • Other countries, if applicable. These may be laws of the state you reside in.
8. Notification and Revision

This Policy may be updated to provide you with better service and as our business evolves. However, we will not reduce your rights under this Policy without your consent. We will notify you of updates to this Policy by posting updated versions on our website and LOCATER Mobile Application and by appropriate means before the become effective, and we invite you to visit our Platform to keep up to date with the latest Privacy Policy.

We will also provide more prominent notice of material changes.

Material changes within the meaning of this Policy include, but are not limited to:

  • Significant changes in our service model, such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;
  • Significant changes in our ownership structure, organizational structure, etc. Such as changes in ownership due to business restructuring, bankruptcy and mergers, etc;
  • Changes in the primary recipients of personal information sharing, transfer or public disclosure;
  • Significant changes in your rights to participate in the processing of personal information and how they are exercised;
  • In the event of a change in the department responsible for handling the security of personal information, our contact information and complaint channels;
  • When personal information security impact assessment report indicates a high risk.
9. How to Contact Us

If you have any questions, comments or complaints about our Privacy Policy, or wish to contact us, please do so as follows:

Specific issues related to the software or the user’s personal account (including access to one’s own personal information), please e-mail us at service@locater.cc

For general inquires or complaints about privacy issues, please e-mail us at service@locater.cc.

If you are not satisfied with our response, especially if our processing of personal information has harmed your legitimate rights and interests, you may also file a complaint or report to the regulatory authority in your area.