1. Who we are
Friend Tracker is an app and website operated by Laraben BV (company number (CBE) 0756.758.069), Zandvoordedorpstraat 149, 8400 Oostende (Belgium), aimed at users in Belgium. Laraben BV is the controller of the personal data described in this policy. For any privacy questions, you can reach us at info@laraben.be.
2. What data we process
| Category | Data |
|---|---|
| Account | Name, email address (and whether you have verified it), password (stored only in encrypted form as a hash), username (handle), your personal friend code and the color the app assigns to you. |
| Friends and events | Who you are friends with, friend requests you send or receive (from whom, to whom, when, and whether they were accepted or declined), the events you create, are invited to or join (name, dates, place, who invited you) and pings you send or receive. |
| Email invitations | If a user invites someone without an account by email, we store that email address, who sent the invitation and when — solely for that invitation. |
| Alerts | If you send an alert: your message, the event, when you sent or stopped it and — if “Include my location” is turned on — your position at that moment. If you receive an alert: whether and when you responded (Got it, On my way, Mute) and whose alerts you have muted. |
| Location | Latitude and longitude, accuracy, heading (if available) and the time of measurement. |
| Technical | Platform (iOS or Android), app version and the time you last used the app. |
| Push notifications | If you allow notifications: the device token that Apple or Google issues to the app on your device, the platform, the app version and when the token was last registered. |
| Website downloads | When you download the app via this website: the platform, your browser (user agent, truncated) and an irreversible hash of your IP address. We do not store your full IP address. |
We do not ask for data about your health, religion, political opinions or other special categories of data, and we do not use your data for advertising or profiling.
3. Your location: who sees what, and when
- Participants only. Your location is visible exclusively to the other participants in an event you have joined yourself. Friends who are not taking part, people who are only invited and other users cannot see your location.
- Only after you tap “Join” yourself. An invitation to an event does not share anything yet. Only once you tap “Join” yourself do you see the locations of the other participants, and they see yours.
- Only during the event. Your location is only shared on the days of that event; never outside them.
- By default, only while the app is open. The app first asks for access to your location “while using the app”.
- Background sharing is optional. If you turn on “Background sharing” yourself, the app also shares your location when it is closed, so your friends can find you with your phone in your pocket. This only happens while an event you are a member of is running, stops automatically after the event, and is visible on your device (the blue location indicator on iPhone, a persistent notification on Android). You can turn it off in the app at any time.
- Alerts. If you send an alert with “Include my location” turned on, the other participants in that event see your position at that moment for as long as the alert is active (at most 5 minutes). Like your location history, that position is deleted after 7 days. Friend Tracker is not an emergency service: in an emergency, call 112.
- You decide. You can withdraw location permission at any time in your phone’s settings, or leave an event. The radar will then no longer show any new position for you.
4. Friends and invitations
- No one without your consent. Nobody becomes your friend or a member of an event unless you accept the request or invitation yourself. If you decline, the other person is not notified.
- Friend code. Your friend code (like FT-4K9Q-X2MZ) is hard to guess, and we limit how often anyone can try codes. You can always request a new code in the app; the old one then stops working immediately.
- Inviting someone by email. If you invite someone by their email address and that person does not have an account yet, we send one invitation email on your behalf, showing your name and username. We send at most one invitation per 7 days to the same address. We do not use that address for anything else, do not send it any other emails, and the email contains no tracking pixels.
- No lookup function. Anyone who invites someone by email is never shown whether an account already exists for that address.
- 30 days. An unanswered email invitation to someone without an account is automatically deleted after 30 days, together with the email address. If the sender withdraws the invitation, we delete it immediately.
- Don’t want an invitation like this? Then you don’t need to do anything. You can also ask us to delete the address straight away at info@laraben.be.
5. Email
We only send emails that are necessary for the service: the verification of your email address, a notice to your previous address if your email address is changed, a link to reset your password if you request one, and invitations that a user sends themselves. No newsletters, no advertising and no tracking pixels.
- Verifying your email address. After you register (and after you change your email address), you receive a verification link. We only link invitations that friends sent to your address to your account once you have verified that address — so nobody else can intercept them by creating an account with your address. The app also works without verification.
- Via Postmark. Emails are sent via Postmark (ActiveCampaign, LLC), which delivers them solely on our behalf. For this purpose, Postmark receives the recipient’s email address and the content of the email, and retains delivery data (such as address, subject and delivery status) for a limited period to monitor delivery and prevent abuse.
6. Push notifications
The app only asks whether you want to receive notifications after you log in. If you say yes, we store your device’s device token. We use it to notify you when a friend pings you, when you receive a friend request or someone accepts your request, when you are invited to an event or someone joins your event, when a participant in your event sends an alert (repeated until you respond, for at most 2 minutes) or responds to your alert, and on the morning an event you are taking part in starts.
- Via Apple and Google. Notifications are delivered via the Apple Push Notification service (iPhone) and Google Firebase Cloud Messaging (Android). They receive the device token and the content of the notification (for example the name of the friend pinging you or the name of the event), solely to deliver the notification.
- No location in notifications. A notification never contains your location or that of your friends.
- You decide. You can turn off notifications at any time in your phone’s settings. If you log out or delete your account, we delete the device token. We automatically remove tokens that Apple or Google report as invalid.
7. Purposes and legal bases
- Providing the service — account, friends, friend requests, events, radar, pings and the emails required for them (verification of your email address, notice of a changed address). Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
- Delivering an invitation to someone without an account — Legal basis: legitimate interest (Art. 6(1)(f) GDPR) of the user who wants to invite their friend, and our own interest in being able to deliver that invitation. We limit this to one email per 7 days per address and delete the address after 30 days.
- Sharing your location with event members — Legal basis: your consent (Art. 6(1)(a) GDPR), which you give through your phone’s location permission and can withdraw whenever you like.
- Sending push notifications — Legal basis: your consent (Art. 6(1)(a) GDPR), which you give through your phone’s notification permission and can withdraw whenever you like.
- Security and preventing abuse — for example blocking accounts that abuse the service and limiting the number of requests. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
- Anonymized statistics — such as the number of active users and downloads, to improve the app. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
8. Retention periods
- Location history: 7 days. Older locations are automatically deleted every day, including any position sent with an alert.
- Email invitations to someone without an account: 30 days, or deleted immediately if the sender withdraws them. If the recipient creates an account and verifies their email address, the invitation becomes a regular friend request.
- Account data, friends, friend requests, events and alerts: for as long as your account exists. If you delete your account, this data is erased, except for anything we are legally required to keep. You can read how to delete your account under Delete account.
- Device tokens for push notifications: until you log out, delete your account or Apple or Google declares the token invalid.
- Website download statistics: in hashed form only (without IP address) and no longer than necessary for the statistics.
9. Who we share data with
We never sell or rent out your data. Your location, name and color are visible to the members of your events, as described above. In addition, we work with a hosting partner that manages the servers; it processes data solely on our behalf, under a data processing agreement. For push notifications we use Apple (Apple Push Notification service) and Google (Firebase Cloud Messaging), as described under Push notifications. We send emails via Postmark (ActiveCampaign, LLC), acting as a processor under a data processing agreement, as described under Email. We only pass data on to public authorities where the law requires us to.
Data is processed within the European Economic Area as far as possible. Where a transfer outside the EEA is nevertheless necessary — for example with Postmark, Apple and Google, which (also) process data in the United States — this only takes place with appropriate safeguards, such as the European Commission’s standard contractual clauses or the EU-U.S. Data Privacy Framework.
10. Security
Traffic between the app, the website and our servers is encrypted (HTTPS). We store passwords only as a hash, access to the app works through personal tokens, and administration is restricted to a small number of administrators. Should a data breach nevertheless occur that poses a risk to you, we will report it to the Data Protection Authority and, where necessary, to you.
11. Your rights
Under the GDPR, you have the right to:
- access your data and obtain a copy of it;
- have inaccurate data rectified;
- have your data erased (the “right to be forgotten”) — you can also delete your account yourself in the app, see Delete account;
- have the processing restricted;
- receive your data in a commonly used format or have it transferred (data portability);
- object to processing based on legitimate interest;
- withdraw your consent to sharing your location at any time, without affecting the lawfulness of processing before the withdrawal.
Send your request to info@laraben.be. We will reply within one month. To protect your data, we may ask you to confirm that the request really comes from you.
12. Cookies
This website only uses strictly necessary cookies: a session cookie and a security cookie that protects against forged forms (CSRF). There are no tracking, advertising or analytics cookies, so we do not ask for your consent for them either. Fonts are loaded from our own server; your browser does not connect to any external font services.
If you close the notice suggesting another language, or choose that language, we remember this for one year in the preference cookie ft_lang, so the notice doesn’t keep coming back. It contains only that choice.
13. Minors
Friend Tracker is intended for people aged 16 or over. If you are younger, you may not create an account. If we find that an account was created by someone under 16, we will delete it.
14. Changes
As the app changes, this policy may change too. The date at the top shows the latest version. If there are significant changes, we will let you know in advance in the app or by email.
15. Contact and complaints
Questions or complaints? Email info@laraben.be — we’re happy to work out a solution together. You also always have the right to lodge a complaint with the Data Protection Authority (DPA), Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels, www.dataprotectionauthority.be.