360mods Global Privacy Policy

Scope, Applicability & Data Controller Identity

This Privacy Policy applies to all users worldwide who access or use the mobile applications, web portals, connected hardware, Bluetooth tags (including Tile devices), APIs, and services operated by 360mods, Inc. (referred to herein as "360mods", "we", "our", or "us").

For the purposes of the European Union General Data Protection Regulation (GDPR), the UK Data Protection Act 2018, the California Consumer Privacy Act as amended by the CPRA (CCPA), and other international privacy frameworks, 360mods, Inc. operates as the designated Data Controller for personal data collected through our platform.

When you create a "Circle" or join an existing family group, you enter a private peer network where members voluntarily share location, driving diagnostics, and safety statuses among authorized participants. By downloading, registering, or interacting with 360mods, you acknowledge that you have read and understood the practices described in this document.

Categories of Personal Data We Collect

We collect personal information directly from you, automatically through your device hardware, and through authorized Circle invitations:

• Account Registration Identifiers: First and last name, verified mobile telephone number, email address, profile avatar image, account password hash (stored via salted bcrypt), and third-party authentication tokens (Sign in with Apple, Google Single Sign-On).
• Circle & Family Profile Metadata: Names of private Circles (e.g. "Smith Family", "College Roommates"), custom Place names (e.g. "Home", "Oakridge High School", "Grandma's House"), member roles (Admin vs. Standard Member), and customized geofence radiuses.
• Emergency Contact Records: Names, relationships, and telephone numbers of individuals designated to receive automated SMS notifications during SOS triggers or vehicular collision alerts.
• Billing & Payment Details: Transaction records, subscription tier (Free, Silver, Gold, Platinum), renewal dates, and obfuscated payment tokens. Full credit card numbers are processed directly by certified PCI-DSS Level 1 payment processors (Stripe, Apple App Store, Google Play) and never stored on 360mods servers.

Precise Geolocation & Environmental Sensor Telemetry

Precise real-time location is essential to delivering core safety capabilities including live family maps, geofenced Place arrival/departure alerts, and emergency dispatch routing.

With your explicit mobile operating system permission ("Always Allow" on iOS, "Allow all the time" on Android), we collect:

• High-Precision Coordinates: Latitude, longitude, altitude, horizontal and vertical positional accuracy radii (measured in meters), bearing, and velocity.
• Ambient Wireless Telemetry: Basic Service Set Identifiers (BSSID), Wi-Fi network signal strengths (RSSI), and cellular tower identifiers (CID/LAC) used for low-power indoor triangulation when satellite GPS signals are obstructed.
• Adaptive Background Polling: Our patented motion algorithms poll location dynamically. When your device is stationary inside a designated Place, GPS sensors enter deep low-power sleep. When device accelerometers detect movement or transit speeds exceeding 5 mph, high-frequency location updates resume automatically.

Driving Telematics, Motion Sensors & Crash Diagnostics

For accounts with Driving Safety enabled, 360mods accesses your device’s internal hardware sensors to compute real-time trip analytics, safe driving feedback, and instant crash detection:

• Inertial Measurement Sensors: 3-axis accelerometer force readings, gyroscope angular rotation rates, and magnetometer orientation data sampled at high frequencies during detected drives.
• Drive Telematics Profile: Trip start time, trip conclusion timestamp, total mileage, route geometry, maximum and average speeds, high-speed threshold violations, rapid acceleration events, and hard braking instances.
• In-Transit Phone Usage: We detect whether the smartphone screen was actively unlocked, tapped, or manipulated while the vehicle was in motion at driving speeds. We do not record keystrokes, screen contents, or audio recordings.
• Crash Impact Vectors: In the event of sudden severe deceleration indicative of a vehicular collision (>25 mph pre-impact velocity), we capture multi-vector G-force metrics to verify crash probability and initiate emergency response protocols.

Tile Trackers & Bluetooth Beacon Mesh Network

When you pair a Tile hardware tracker or 360mods Pet Tag with your account:

• Device Telemetry: We collect the unique hardware MAC address, firmware version, battery voltage status, and cryptographic pairing credentials of each physical tracker.
• Community Find Mesh Network: If a tagged item (such as lost keys or a pet) is separated from your phone, our global Community Find network assists in finding it. When any active 360mods or Tile app user passes within Bluetooth range (up to 400 feet) of your lost tracker:
  1. The passerby’s phone detects the tracker's encrypted public beacon broadcast.
  2. The passerby’s app silently and securely transmits the location coordinates to 360mods servers.
  3. The update is relayed exclusively to your private map. The passerby is never notified of the tracker's presence or your identity, and you never see the identity or location of the passerby.

Cookies, Pixels & Automated Web Technologies

When interacting with our website and support portals, we utilize first-party and select third-party tracking technologies:

Purposes & Legal Bases for Data Processing

We process your personal information under the following recognized legal bases under international privacy law:

• Performance of Contract (Article 6(1)(b) GDPR): Delivering real-time location mapping, sending geofenced Place notifications, logging driving summaries, ringing Bluetooth tags, and administering account subscriptions.
• Vital Interests (Article 6(1)(d) GDPR): Dispatching emergency medical, fire, or police services and transmitting real-time GPS coordinates during verified severe vehicle crashes or SOS panic button triggers.
• Legitimate Interests (Article 6(1)(f) GDPR): Detecting and preventing account fraud, securing server infrastructure, analyzing aggregated crash telemetry to improve collision detection accuracy, and providing customer support.
• Explicit Consent (Article 6(1)(a) GDPR): Accessing Bluetooth radios for community mesh relaying, sending promotional newsletters, and collecting voluntary survey feedback. Consent can be revoked at any time.

Sharing & Third-Party Disclosures

360mods does not sell, rent, or trade raw family location histories or driver telematics to commercial data brokers, advertising aggregators, or predatory lead generators. We share data only in the following strictly limited circumstances:

• Authorized Circle Members: Your live position, battery percentage, and Place arrival/departure alerts are shared solely with users whom you have explicitly accepted into your private Circle.
• Emergency 911 / Public Safety Dispatchers: In the event of an uncancelled severe crash detection signal or manual SOS button activation, our 24/7 UL-certified emergency dispatch partners transmit your exact coordinates, name, vehicle information, and crash severity data to local emergency response authorities (PSAPs).
• Roadside Assistance Providers: For Gold and Platinum members requesting towing, fuel delivery, tire changes, or lockout support, dispatch details and vehicle location are shared with vetted roadside partner networks (e.g. Signature Motor Club).
• Cloud Infrastructure & Security Processors: We engage certified enterprise vendors (e.g. Amazon Web Services, Google Cloud Platform, Twilio for SMS verification, Stripe for payment processing) who operate under strict Data Processing Agreements (DPAs) with strict confidentiality and security covenants.
• Legal & Law Enforcement Compliance: We disclose user records to law enforcement only upon receipt of a valid, binding legal search warrant, court order, or subpoena, or when we reasonably believe in good faith that an emergency involving imminent danger of death or serious physical injury requires immediate disclosure. See our Law Enforcement Guidelines for additional information.

User Privacy Controls & In-App Opt-Outs

We provide comprehensive granular privacy controls built directly into every 360mods mobile app:

• Pause Location Sharing: You can temporarily disable location sharing for any specific Circle by opening Settings > Circle Management > Location Sharing > OFF. While paused, members will see a "Location Paused" badge with your last known timestamp.
• Drive Detection Toggle: Individual drivers can turn off telematics calculation and drive recording via Settings > Driving Safety > Drive Detection > OFF.
• Push & Place Notification Filters: Customize which Place alerts trigger notifications on your device to avoid alert fatigue.
• Global Privacy Control (GPC): Our web portals automatically recognize and respect Global Privacy Control signals transmitted by compliant browsers, disabling marketing trackers across all web sessions.

Children's Privacy Protection (COPPA & Minor Protections)

Protecting children is fundamental to 360mods's mission. We comply fully with the Children's Online Privacy Protection Act (COPPA) in the United States, GDPR-Kids in the European Union, and international minor safety standards:

• Children under 13 years of age (or under 16 in certain European jurisdictions) may only utilize 360mods when an adult parent or legal guardian creates the account, manages Circle membership, and provides verifiable parental consent.
• We do not condition a child’s participation in any activity on the disclosure of more personal information than is reasonably necessary.
• Child location data is accessible solely to authorized members of the child's private Circle and is never utilized for targeted behavioural marketing or third-party profiling.
• Parents may review, correct, or request the permanent deletion of their child's location logs and profile data at any time by contacting [email protected].

International Data Transfers & Cross-Border Protections

360mods operates globally with primary cloud server infrastructure located in the United States. If you access our platform from the European Economic Area (EEA), the United Kingdom, Switzerland, Canada, or Australia, your data will be transferred to and processed in the United States.

To safeguard international data transfers, 360mods utilizes European Commission-approved Standard Contractual Clauses (SCCs), UK International Data Transfer Agreements (IDTAs), and adheres to the principles of the EU-U.S. Data Privacy Framework (DPF) ensuring equivalent levels of data security and legal remedies.

Data Retention Schedules & Account Deletion

We retain personal information only for as long as necessary to fulfill the purposes outlined in this policy or to comply with statutory legal requirements:

• Live Location Telemetry: Free Tier accounts retain rolling 2 days of location history. Premium (Gold/Platinum) accounts retain a rolling 30-day location history log. Location points older than the applicable window are permanently purged from active query caches.
• Driving Diagnostics & Trips: Individual trip logs are retained for 30 days before being converted into anonymized, aggregated statistics (e.g. total miles driven) with personal identifiers severed.
• Crash Event Telemetry: Sensor data from verified vehicular collisions is retained for 90 days to support customer insurance and emergency review needs before anonymization.
• Account Deletion Protocol: When you tap "Delete Account" in the app settings, your profile is immediately de-identified, removed from all Circles, and permanently erased across our production databases within 30 days.

Regional Privacy Rights (CCPA/CPRA, GDPR, LGPD, PIPEDA)

Depending on your geographic location and applicable local legislation, you possess distinct legal rights regarding your personal data:

To exercise any of these statutory rights, submit a Data Subject Access Request (DSAR) by emailing [email protected] with the subject line "Privacy Rights Request". We verify identity via two-factor mobile authentication and respond within 30 days (or 45 days for CCPA requests).

Technical, Operational & Organizational Security Safeguards

360mods implements rigorous defense-in-depth technical and organizational controls to protect against unauthorized access, alteration, disclosure, or destruction of sensitive family data:

• Encryption in Transit & at Rest: All communications between mobile apps, connected tags, and cloud endpoints are encrypted using Transport Layer Security (TLS 1.3). All database storage volumes, telemetry clusters, and backup snapshots are encrypted using AES-256 military-grade encryption.
• Zero-Trust Access Architecture: Production database access requires multi-factor biometric authentication, hardware security keys (FIDO2), and role-based access control (RBAC) restricted to authorized engineers on a strictly audited, ephemeral basis.
• Independent Penetration Auditing: We undergo annual SOC 2 Type II compliance audits and engage independent third-party cybersecurity firms to conduct regular penetration testing and vulnerability assessments.

Changes to This Policy & Data Protection Officer Contact

We may update this Privacy Policy periodically to reflect enhancements to our safety technologies, new hardware features, or changing legal standards. When material changes are made, we will notify you via in-app banner, push notification, or email at least 30 days prior to the effective date.

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, please contact our dedicated Privacy Team and Data Protection Officer (DPO):