Table of Contents

  1. About This Privacy Policy
  2. Information We Collect
  3. How We Collect Information
  4. How We Use Your Information
  5. Legal Basis for Processing
  6. How We Share Your Information
  7. Data Storage and Security
  8. Your Rights and Choices
  9. Cookies and Similar Technologies
  10. Third-Party Services
  11. International Data Transfers
  12. Data Retention
  13. Children's Privacy
  14. Changes to This Policy
  15. Contact Information
  1. ABOUT THIS PRIVACY POLICY

1.1 This Privacy Policy explains how Loci App Ltd of 45 Gresham Street, London, EC2V 7BG ("we", "us", or "our") collects, uses, and protects your personal information when you use the Loci mobile application and related services (the "App") and/or our website at lociapp.co.uk (the “Website”).

1.2 We are committed to protecting your privacy and being transparent about how we handle your personal information.

1.3 This Privacy Policy should be read together with our Terms of Use and Cookies Policy.

1.4 If you do not agree with this Privacy Policy, please do not use the App or the Website.


  1. INFORMATION WE COLLECT

2.1 Information You Provide Directly
We may collect information that you provide directly to us, including:
(a) account registration information (name, email address, password);
(b) profile information;
(c) feedback, reviews, or comments you submit;
(d) correspondence when you contact us; and
(e) any other information you choose to provide.

2.2 Information We Collect Automatically
When you use the App, we automatically collect certain information, including:
(a) Device Information: device type, operating system, unique device identifiers, advertising identifiers, and mobile network information;
(b) Usage Information: features you use, actions you take, time and frequency of use, crash reports, and interaction patterns;
(c) Location Information: approximate location based on IP address or precise location if you enable location services;
(d) Technical Information: IP address, browser type, app version, and connection information; and
(e) Advertising Information: ad interactions, preferences inferred from your activity, and advertising engagement metrics.

2.3 Information from Third Parties
We may receive information from third-party sources, including:
(a) public service databases;
(b) government and local authority APIs;
(c) mapping and location service providers;
(d) analytics service providers; and
(e) advertising partners and networks.


  1. HOW WE COLLECT INFORMATION

3.1 We collect information through various methods:
(a) when you create an account or use the App;
(b) through cookies and similar tracking technologies;
(c) from third-party APIs and databases we use to provide service information;
(d) when you contact us or provide feedback;
(e) through analytics tools and crash reporting services;
(f) from publicly available sources; and
(g) through advertising networks and partners.

3.2 We use third-party APIs to obtain information about local public services, including contact details, opening hours, and service descriptions.

3.3 We work with advertising partners who may collect information about your device and usage patterns to provide relevant advertisements.


  1. HOW WE USE YOUR INFORMATION

4.1 We use your personal information for the following purposes:
(a) Service Provision: to provide, maintain, and improve the App's functionality;
(b) Personalisation: to customise your experience and provide relevant local service information;
(c) Communication: to send you service updates, notifications, and respond to your inquiries;
(d) Analytics: to understand how the App is used and improve our services;
(e) Security: to detect, prevent, and address technical issues and security threats;
(f) Legal Compliance: to comply with applicable laws and regulations;
(g) Business Operations: for internal business purposes such as administration and record-keeping;
(h) Advertising: measure marketing effectiveness, application installs, and attribution performance associated with promotional campaigns; and
(i) Marketing: to provide you with information about services and features that may interest you.

4.2 Advertising Purposes
We may use certain information to:
(a) measure application installs and campaign effectiveness;
(b) understand which marketing channels lead users to install the App;
(c) prevent fraudulent or duplicate attribution events;
(d) analyse aggregated campaign performance; and
(e) improve marketing efficiency and user acquisition activities.

We do not currently display third-party in-app advertising within the App.

(f) measuring application installs, campaign performance, and attribution using industry-standard attribution technologies and identifiers, including:

(i) Apple SKAdNetwork attribution postbacks;

(ii) the Android Install Referrer API;

(iii) advertising identifiers where permitted by your device settings and consent choices; and

(iv) campaign attribution parameters and click identifiers such as gclid, fbclid, gbraid, and wbraid.

4.3 We will only use your information for purposes that are compatible with those listed above or for purposes you have consented to.


  1. LEGAL BASIS FOR PROCESSING

5.1 We process your personal information based on the following legal grounds:
(a) Contract: to perform our obligations under the Terms of Use;
(b) Legitimate Interests: for our legitimate business interests, such as improving the App, ensuring security, and supporting our advertising-supported business model;
(c) Consent: where you have given specific consent for certain processing activities, including targeted advertising; and
(d) Legal Obligation: to comply with applicable laws and regulations.

5.2 For targeted advertising based on your activity and location, we rely on your consent, which you may withdraw at any time through the App settings.

(a) Certain analytics and attribution technologies are only activated after you provide consent through the App’s consent flow or, on iOS devices, through Apple’s App Tracking Transparency (“ATT”) framework where applicable.

(b) We may also use limited first-party analytics and diagnostics tools that are necessary to operate, maintain, secure, and improve the App. These tools do not use advertising identifiers for cross-platform tracking and are processed on the basis of our legitimate interests.

5.3 You have the right to object to processing based on legitimate interests, including general advertising.


  1. HOW WE SHARE YOUR INFORMATION

6.1 We do not sell your personal information to third parties. However, we may share certain information with advertising partners as described below.

6.2 We may share your information in the following circumstances:
(a) Service Providers: with trusted third-party service providers who assist us in operating the App;
(b) Advertising Partners: with advertising networks and partners to display relevant advertisements, subject to appropriate data protection agreements;
(c) Public Information: information about public services may be shared as this information is generally publicly available;
(d) Legal Requirements: when required by law, regulation, or legal process;
(e) Safety and Security: to protect the rights, property, or safety of users or the public;
(f) Business Transfers: in connection with a merger, acquisition, or sale of assets; and
(g) Consent: with your explicit consent for other purposes.

6.3 Advertising Data Sharing
We may share the following types of information with advertising partners:
(a) general demographic information (age range, general location);
(b) anonymised usage patterns and preferences;
(c) device identifiers for advertising purposes; and
(d) aggregated and anonymised analytics data.

6.4 Any third parties we work with are required to maintain appropriate security measures and use your information only for the purposes we specify.


  1. DATA STORAGE AND SECURITY

7.1 We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction.

7.2 Security measures include:
(a) encryption of data in transit and at rest;
(b) access controls and authentication procedures;
(c) regular security assessments and updates;
(d) staff training on data protection; and
(e) incident response procedures.

7.3 Your information is stored on secure servers located in the UK or Ireland and hosted by Amazon Web Services. Accordingly, please also see https://aws.amazon.com/compliance/data-protection/

7.4 While we take reasonable steps to protect your information, no system is completely secure, and we cannot guarantee absolute security.


  1. YOUR RIGHTS AND CHOICES

8.1 Under applicable data protection laws, you have the following rights:
(a) Access: to request access to your personal information;
(b) Rectification: to correct inaccurate or incomplete information;
(c) Erasure: to request deletion of your personal information;
(d) Restriction: to restrict processing of your information;
(e) Portability: to receive your information in a portable format;
(f) Objection: to object to certain types of processing; and
(g) Withdraw Consent: to withdraw consent where processing is based on consent.

8.2 Advertising Choices
You have specific choices regarding advertising:
(a) you can opt out of targeted advertising through the App settings;
(b) you can reset your advertising identifier through your device settings;
(c) you can object to processing for general advertising purposes;
(d) you can control location-based advertising by disabling location services; and
(e) you can withdraw consent for targeted advertising at any time.

8.3 To exercise these rights, please contact us using the details in clause 15.

8.4 You can also:
(a) update your account information through the App settings;
(b) delete your account at any time;
(c) control location sharing through your device settings;
(d) manage push notification preferences in the App; and
(e) adjust advertising preferences in the App settings.

8.5 If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection authority. In the UK, that is the Information Commissioner’s Office (ico.org.uk) whose telephone number is 0303 123 1113.


  1. COOKIES AND SIMILAR TECHNOLOGIES

9.1 We use cookies, SDKs, device identifiers, local storage technologies, and similar technologies in connection with the Website and App.

9.2 These technologies help us:

(a) operate and secure the App;

(b) understand usage patterns and improve functionality;

(c) measure installs and campaign performance; and

(d) provide analytics and attribution services.

9.3 Where required by applicable law, we obtain consent for non-essential tracking technologies through the App’s consent tools and, on iOS devices, through Apple’s App Tracking Transparency framework.

  1. THIRD-PARTY SERVICES

10.1 The App may integrate with third-party services, including:
(a) mapping and location services;
(b) analytics providers;
(c) government and local authority databases;
(d) ssocial media platform integrations used for install attribution and analytics; and
(e) advertising networks and partners;
(f) The App uses certain third-party software development kits (“SDKs”) and service providers to support analytics, diagnostics, attribution, messaging, and infrastructure functions, including:
(i) Firebase (Google LLC) — analytics, push messaging, and install attribution;
(ii) Google Ads — advertising attribution and conversion measurement;
(iii) Meta Platforms SDKs (Meta Platforms, Inc.) — install attribution and advertising measurement;
(iv) PostHog — first-party product analytics and usage analytics;
(v) Sentry — crash reporting, diagnostics, and performance monitoring; and
(vi) Amazon Web Services (“AWS”) — cloud hosting and infrastructure services.

10.2 Attribution and Analytics Partners
We work with third-party attribution, analytics, and measurement providers to understand App installs, usage patterns, diagnostics, and campaign effectiveness. These partners include:
(a) Firebase (Google LLC) — analytics, push notifications, and install attribution;
(b) Google Ads — install conversion measurement and campaign attribution;
(c) Meta Platforms SDKs (Meta Platforms, Inc.) — install attribution and advertising measurement;
(d) PostHog — first-party product analytics and feature usage analytics;
(e) Sentry — crash reporting, diagnostics, and performance monitoring; and
(f) Amazon Web Services (“AWS”) — cloud hosting and infrastructure services.

10.3 These third parties have their own privacy policies, and we are not responsible for their practices.

10.4 We encourage you to review the privacy policies of any third-party services you interact with.


  1. INTERNATIONAL DATA TRANSFERS

11.1 Your information may be transferred to and processed in countries other than your country of residence.

11.2 When we transfer information internationally, we ensure appropriate safeguards are in place, including:
(a) adequacy decisions by relevant authorities;
(b) standard contractual clauses; or
(c) other appropriate transfer mechanisms.

11.3 Some of our advertising partners may be located outside your jurisdiction, and appropriate safeguards will be implemented for any such transfers.


  1. DATA RETENTION

12.1 We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy.

12.2 Retention periods depend on the type of information and the purpose for processing:
(a) account information is retained until you delete your account;
(b) usage data is typically retained for up to [2 years];
(c) communications are retained for [1 year];
(d) attribution and advertising measurement data and preferences are retained for up to 3 years or until you opt out;
(e) aggregated and anonymised advertising analytics may be retained indefinitely; and
(f) legal records are retained as required by applicable laws.

12.3 When information is no longer needed, we securely delete or anonymise it.


  1. CHILDREN'S PRIVACY

13.1 The App is not intended for children under 16 years of age.

13.2 We do not knowingly collect personal information from children under 16.

13.3 We do not serve targeted advertising to users who we know are under 16 years of age.

13.4 If we learn that we have collected information from a child under 16, we will delete that information promptly.

13.5 If you believe we have collected information from a child under 16, please contact us immediately.


  1. CHANGES TO THIS POLICY

14.1 We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws.

14.2 We will notify you of material changes by:
(a) posting the updated policy in the App and/or the Website;
(b) sending you a notification through the App; or
(c) other reasonable means of communication.

14.3 Changes will take effect on the date specified in the updated policy.

14.4 Your continued use of the App after changes become effective constitutes acceptance of the updated policy.


  1. CONTACT INFORMATION

15.1 If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Email: trust@lociapp.co.uk
Address: 45 Gresham Street, London, EC2V 7BG

15.2 We will respond to your inquiry within 30 days or as required by applicable law.

15.3 For complaints or concerns about our privacy practices, you may also contact the relevant data protection authority in your jurisdiction.

Last updated: 3rd June 2026