• Personal data means any information relating to an identified or identifiable natural person (“data subject/user”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

• Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member States of the European Union, and other provisions related to data protection is the Company.

• Processing is any operation or set of operations performed on personal data or on sets of personal data, whether by automated means or otherwise, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, or combination, restriction, erasure, or destruction.

• Data subject/user is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing; a user of Find Any Phone.

• Pseudonymization is the processing of personal data in such a manner that it can no longer be attributed to a specific data subject/user without the use of additional information, provided such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

• Encryption is a security protection measure for personal data; as a form of cryptography, it is a process whereby personal data is encoded into an unintelligible version using encryption algorithms and an encryption key, with a decryption key enabling decoding.

• Consent of the data subject/user is any freely given, specific, informed, and unambiguous indication of the data subject/user’s wishes by which they, by a statement or clear affirmative action, signify agreement to the processing of personal data relating to them.

Anyone can access our Website without needing to provide personal data.

The purpose of processing your personal data by the Company and collecting information about you are as follows (the “Purpose”):

• Your intention to use Find Any Phone;
• For the performance of a contract to which the user is a party, in accordance with Article 6.1.b of the GDPR, where the collected data are necessary for Find Any Phone to identify and bill the user and to charge its bank card number;
• For verifying your identity and providing customer care service and assistance;
• To analyze your use of our Website and Find Any Phone to better understand how they are being used, enabling us to improve our Services and the user experience, and to engage and retain users.
  
  

We may use your personal data to:

1. Improve your browsing experience by personalizing the Website and improving Find Any Phone;
2. Send information by email regarding registration status, password verification, and payment confirmation;
3. Send communications related to your use of Find Any Phone; and
4. Provide our partners with statistical information about our users through secure channels under data processing agreements (DPA);
5. Send you marketing and promotional materials and messages.
   
   

When you use Find Any Phone, you are required to provide your personal data (to register an account and purchase Find Any Phone), thus becoming a user of Find Any Phone.

Please note, you are not obliged to provide us with your personal data. However, if you do not provide us with your email address and payment information, you may be unable to create an account, log in, and make a purchase for Find Any Phone.

SCOPE AND CATEGORIES OF PERSONAL DATA, LAWFUL BASIS FOR PERSONAL DATA PROCESSING, AND DATA SUBJECT CATEGORIES. We strive to be compliant with GDPR and have implemented data minimization principles.

We have implemented security measures to safeguard your data, working with third-party providers that use encryption and authentication to maintain data confidentiality. We store user data with asymmetric RSA (4096-bit key) and symmetric AES (256-bit key) encryption systems, ensuring only encrypted storage.

Login process: We use your password to decrypt your private key during login.

Encryption: Data from devices is transmitted via an encrypted https protocol and immediately encrypted on our server in RAM without storing on server disks, using RSA with the user’s public key.

We consider your use of Find-any-phone to be private. However, we may disclose your personal information stored in your account and/or on our servers and databases, in order to:

(i) comply with the law or legal process served on us;

(ii) enforce and investigate potential violations of this Privacy Notice, Terms of Use; including use of this Service to participate in, or facilitate activities that violate the law;

(iii) investigate potential fraudulent activities; or

(iv) protect the rights, property, or safety of our Company, its employees, its customers, or the public.

In the event of a change of control of Find-any-phone (such as asset transfers through a merger, sale, assignment, or liquidation of the business entity, or any of its properties, assets, or equity), or in the event of a direct or indirect sale of any of its publishing properties and/or its Website(s) in our possession, your personal data will be transferred to the new owner/successor. You will be notified of any such transaction and have an ability to exercise your legal rights under GDPR. You may always change or delete your personal data or opt out by contacting us as provided below, or if the acquirer posts a new Privacy Notice with new contact information, you may change or delete your personal data or opt out by following any new instructions that are posted.

As a controller, we may also transfer to one or more processors (e.g., a payment provider under DPA) personal data of a data subject for (a) payment processing purposes, which is attributable to the controller and without which a user would not be able to purchase Find-any-phone; (b) telecommunication purposes without which users would not be able to use Find-any-phone.

As we use third-party technological services for the provision of Services, we may transfer your personal data internationally. Providers of such technological services may process personal data collected in the course of providing us their services as sub-processors only under DPA in accordance with GDPR.

In case there might be a risk of unauthorized disclosure of personal data, the controller communicates the personal data breach to the data subject without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, such as encryption, and it was applied to the personal data affected by the personal data breach, the controller is not required to communicate with the data subject.

However, the encryption is useless if the access password or other credentials are weakly protected and stored by the data subject. In this case, the controller is not responsible for personal data breach.

In the case of a personal data breach, we, as a controller, shall, without undue delay and, where feasible, no later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.

Usually, personal data provided by users and information collected from a target device are stored on servers in Germany and the Netherlands. This data may also be stored outside the EU. In some cases, these personal data and information may be stored in Canada. We have adopted all necessary security measures to protect your personal data according to best practices in security, protection, and confidentiality. If we transfer your personal data to third-party service providers, we will require each third-party service provider to implement necessary security measures to protect your personal data in accordance with our data protection agreement.

• Access: You have the right to request an explanation of the personal data we process about you and can request a copy of your personal data undergoing processing.
• Data Portability: You have the right to receive the personal data concerning you, which you provided to us. You may request to have this data directly transmitted to another data controller in a structured, commonly used, and machine-readable format, where technically feasible.
• Restrict Processing: You have the right to request that we temporarily or permanently stop processing all or some of your personal data.
• Rectification: You have the right to request corrections of any inaccurate data about you.
• Erasure: You have the right to be forgotten, meaning we will delete all personal data that you have provided to us. Note that we may retain certain information as required by law and for legitimate business purposes permitted by law.
• Object Processing: You can, at any time, object to the processing of your personal data on grounds relating to your particular situation. You also have the right to object to your personal data being processed for direct marketing purposes.
• Right to Lodge Complaints: You have the right to lodge complaints regarding our data processing activities with the competent data protection authorities.
• Not to be Subject to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated decision-making, including profiling, where such decisions would have a legal effect on you or produce a similarly significant effect.
• Right of Confirmation: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed.
• Right to Withdraw Data Protection Consent: You may withdraw your consent to the processing of your personal data at any time.
  
  

If any of the aforementioned rights apply, you may contact us as instructed at the end of this Privacy Notice, and we will promptly ensure that your request is fulfilled.

The provision of Find-any-phone is not aimed at children. This website is not intended for use by children under the legal age of adulthood in your country.

We comply with COPPA regulations and do not knowingly collect information from children or minors. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Notice by instructing their children to never provide information on our website without permission.

Our website and service are not directed to, nor do we knowingly collect personal data from children under 13. If we become aware that we have collected data from a child, we will promptly delete it unless we are legally required to retain it.

• Target Device Data: Find-any-phone collects data from a target device when a location link is sent, which may include personal data relating to a target device user(s) (“User Data”). User Data is collected and processed from the moment target device users allow the website to track their location via the browser. When a target device user permits tracking, they consent to store and transfer their current location data to third parties. We collect, store, and transfer only the address where the user allowed tracking after clicking on the location link received by SMS.

• Find-any-phone Obligations: We will (a) implement appropriate technical and organizational measures to safeguard any Target Device Data against unauthorized access, loss, destruction, theft, or misuse; (b) limit access to Target Device Data to employees who need to know it for service delivery; (c) process Target Device Data only as specified by this Privacy Notice and your instructions, and (d) refrain from using Target Device Data for purposes other than those related to service provision or your written instructions. Upon termination of this Agreement or at your request, we will cease any use of third-party data and destroy or return it, except for backed-up data and in cases of termination.

• Warranties: You are solely responsible for the use of your account and User Data. We follow your account configuration and instructions, for which you are solely responsible.

• Indemnity: You agree to indemnify and hold us harmless from all claims, damages, and losses arising from or related to the processing of Target Device Data and other third-party personal data submitted to our systems during service provision.

The storage duration for personal data is based on statutory retention periods. After these periods expire, and if we no longer need the data, we securely delete or destroy it if it is no longer necessary for service provision. As the data controller, we will process and store data only as long as necessary to provide Find-any-phone or as required by law.

In the case of ongoing conflicts, we may store personal data for up to 180 days or longer if required for legal claims or compliance with legal obligations. After this period or once the conflict is resolved, we delete all personal data and information gathered from the target device.

To opt out of future email communications from us, click on the opt-out button in the email or contact us as instructed at the end of this Privacy Notice. We may need up to 30 days to fulfill your request.

To update your personal data, contact us as instructed at the end of this Privacy Notice.

We may modify this Privacy Notice at any time and post changes to it on the website, so please review it frequently. We indicate the date of the latest version of this Privacy Notice below.

Changes to this Privacy Notice do not affect previously collected personal data unless you contact us.

This Privacy Notice is governed by and construed under the laws of England and Wales.

The courts of England and Wales have exclusive jurisdiction over any disputes arising out of this Privacy Notice.

For questions or requests, contact us at: contact@find-any-phone.com