SeatBell Privacy Policy

1. Who We Are & Scope of This Policy

SeatBell is developed and operated by Nanoologi Ltd. ("Nanoologi," "we"). This Privacy Policy applies to the SeatBell mobile application, any companion widgets, App Clips, and related backend services (collectively, the "App"). It applies to all users of the App regardless of country of residence, subject to the governing law provisions below.

2. Scope of Data Collection & Storage

Because the App functions by attempting to mathematically calculate your physical separation from an automobile, we must continuously collect, process, and store highly sensitive personal metrics. By enabling device permissions, you grant us an explicit license to collect and store:

• Persistent Precise Location Data: Real-time latitude, longitude, and altitude metrics, specifically including background location tracking when the App is closed, minimized, or your phone is locked.
• Biometric Motion & Activity States: Data from your physical accelerometer and gyroscope (e.g., walking, running, stationary, automotive transit states).
• Hardware Environment Data: Bluetooth connection states, paired device IDs, Wi-Fi networks, and OS battery metrics.
• Account Identity Data: Verified tokens provided during authentication (such as Apple ID profile metrics, name, or email).
• Device & Diagnostic Data: Device model, OS version, app version, crash logs, and push notification tokens, used solely to keep the detection pipeline functioning and to diagnose failures.

We do not collect microphone audio, camera images, contacts, photos, or browsing history. We do not request or process any data field not listed above.

3. Legal Basis & Explicit Consent for High-Risk Data Processing

By activating the App, you provide your unambiguous, explicit, and informed consent for SeatBell to collect, transmit to cloud servers, and store your historical and real-time location and motion data.

Purpose Statement: This data is collected and processed for the sole technical purpose of executing automated notification algorithms. The storage of this location history does not constitute an active safety guarantee or custodial backup of your movements. Where local law requires a specific legal basis, our basis is your explicit consent, granted and revocable at the operating-system permission level and within the App at any time.

4. How Data Is Used

Data collected under Section 2 is used exclusively to:

• Calculate the distance and motion-state relationship between your device and a paired Bluetooth vehicle connection.
• Trigger, schedule, and deliver push notifications and critical alerts.
• Diagnose and correct technical failures in the detection pipeline (e.g., missed disconnect events).
• Maintain your account, authentication session, and in-app preferences.
• Comply with legal, regulatory, or law-enforcement obligations where legally compelled.

We do not use your data to build behavioral advertising profiles, and we do not use your data to train third-party AI or machine-learning models beyond the on-device or vendor-hosted logic strictly necessary to run the App's core detection feature.

5. Children's Data

SeatBell is designed for use by adults (parents and legal guardians) and is not directed at children. The App does not knowingly collect account or authentication data directly from a child. Any reference to a "child" or "passenger" within the App's functionality (such as a seat label or reminder name) is data entered and controlled entirely by the adult account holder, is not linked to an independent child profile, and is treated by us as data belonging to the parent/guardian account. If we become aware that a child has independently created an account in violation of these terms, we will delete that account and associated data.

6. Data Sharing & Sub-Processors

We do not sell your data. We share data only with the following categories of recipients, each bound by contractual confidentiality and data-protection obligations:

• Cloud Infrastructure & Database Providers: to host, store, and process data described in Section 2.
• Push Notification Platforms (e.g., Apple Push Notification service): to deliver alerts to your device.
• Crash Reporting & Diagnostics Tools: to identify and fix bugs affecting notification reliability.
• Legal & Regulatory Authorities: where disclosure is required to comply with a valid legal process, protect our legal rights, or respond to an imminent safety emergency.
• Successors in a Corporate Transaction: if SeatBell or Nanoologi is involved in a merger, acquisition, or asset sale, data may be transferred as part of that transaction, subject to this policy or a policy offering materially equivalent protections.

7. Absolute Prohibition on Data Selling

SeatBell will never sell, lease, rent, profile, or monetize your location history or personal metadata to third-party advertising networks, data brokers, or commercial entities.

8. International Data Transfers

Our infrastructure providers may process and store data in countries other than your country of residence, including outside the European Economic Area, the United Kingdom, and Israel. Where such transfers occur, we rely on the provider's standard contractual safeguards and industry-standard encryption to protect data in transit and at rest. By using the App, you acknowledge and consent to such cross-border processing.

9. Data Storage, Security & Transmission Disclaimer

We host collected data using industry-recognized cloud architecture providers utilizing encryption protocols for data both in transit (HTTPS/TLS) and at rest.

Acknowledgment of Cyber Risk: You explicitly acknowledge that no wireless data transmission or cloud server database is completely bulletproof against state-sponsored or advanced cyber threats. You authorize the transmission and storage of your persistent location logs entirely at your own risk. In the event of a data breach affecting your personal data, we will notify affected users and applicable regulators as required by the Protection of Privacy Law, 5741-1981, and any other law that applies to you.

10. Data Retention & Direct User Purging Rights

Data is retained only for the operational life cycle necessary to execute safety detection or comply with statutory requirements in Israel. Location and motion logs are automatically rolled off after the period necessary for on-device and server-side detection logic to function, after which they are deleted or irreversibly anonymized, except where retention is required for fraud prevention, dispute resolution, or legal compliance.

You retain the absolute right under the Protection of Privacy Law to request data extraction or a total data purge. You may execute an instantaneous, irreversible data and account deletion directly via the App settings menu. Deleting your account removes your identity, location history, and hardware pairing data from our active systems, subject to residual copies in encrypted backups that are purged on our routine backup-rotation schedule.

11. Your Rights

Subject to applicable law, you may have the right to:

• Access a copy of the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request deletion of your data (available instantly via in-app account deletion).
• Withdraw consent to location, motion, or Bluetooth data collection at any time via your device's operating system settings — noting that doing so will disable the App's core detection functionality.
• Object to or request restriction of certain processing.
• Lodge a complaint with the Israeli Privacy Protection Authority or another competent supervisory authority in your jurisdiction.

To exercise any right not available directly in-app, contact us using the details in Section 15.

12. Hardware & Permission Dependency Notice

The App is non-functional without explicit device-level system overrides. You must manually grant "Always Allow" location tracking, motion/fitness tracking, and high-priority critical notifications. If the mobile operating system suspends these permissions due to system updates, battery levels, or user changes, the App will break completely. SeatBell assumes no responsibility for permission failures.

13. Third-Party Platform (Apple App Store) Compliance

We confirm absolute adherence to Apple's App Tracking Transparency (ATT) framework. Your data is strictly used for core local feature optimization and is never tied to external databases for user-profiling or ad-targeting networks. This Agreement, including this Privacy Policy, is executed solely between you and SeatBell, not with Apple Inc., which bears no obligation or liability with respect to the App or this policy.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be notified through the App or via the "Last updated" date at the top of this page. Continued use of the App after changes take effect constitutes acceptance of the revised policy.

15. Governing Law & Contact

This Privacy Policy is governed exclusively by the laws of the State of Israel, and any dispute arising from it is subject to the sole and exclusive jurisdiction of the competent courts located in the Center District, Israel.

For privacy-related inquiries, data access requests, or account deletion assistance, contact us at custumer.support@nanoologi.com.