Privacy Policy
This Privacy Policy describes how Pinchuk LLC collects, uses, processes, discloses, retains, and safeguards information in connection with your access to and use of the Migri mobile application and the related backend services operated by the Company. This Policy forms part of, and is incorporated by reference into, the Company’s Terms of Service.
By downloading, installing, accessing, or using the App, you acknowledge that you have read and understood this Privacy Policy. Where required by applicable law, your use of the App is conditioned upon the consents described herein. If you do not agree with this Privacy Policy, you must not access or use the App.
This Privacy Policy applies to all information collected or processed through the App and the Company’s associated server infrastructure. The App is intended for use by individuals located in the United States of America. The App is not directed to, intended for, or offered to individuals located in the European Union, the European Economic Area, the United Kingdom, or any other jurisdiction outside the United States.
Notwithstanding the foregoing, in the event that individuals protected by the European Union General Data Protection Regulation (“GDPR”), the United Kingdom GDPR, or the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, “CCPA”) nevertheless access the App, the Company affords the corresponding rights described in Section 19 to the extent such laws apply.
Migri is a personal-safety application designed to enable a user to share location information with that user’s own designated legal counsel and trusted contacts in circumstances the user identifies. The App is engineered to operate on a privacy-protective basis:
This Summary is provided for convenience only and is qualified in its entirety by the detailed provisions set forth below.
We collect the categories of information described in this Section. The provision of such information is, in most instances, initiated by you through your use of the App’s features.
| Category | Description |
|---|---|
| Your name | The first name and last name you choose to enter, used so that your designated counsel and contacts can identify and advocate for you. |
| Attorney information | The name, email address, and telephone number of the legal professional you nominate to receive alerts. |
| Trusted contact information | The name, telephone number, optional email address, and stated relationship of each person you nominate to receive alerts. |
| Category | Description |
|---|---|
| Location data | Precise geolocation, including latitude, longitude, accuracy, speed, altitude, course, and timestamp. See Section 5. |
| Proximity and zone state | Derived information indicating your proximity to, approach toward, entry into, or departure from geographic areas of interest, together with the most recently recorded coordinates and the identifier of the relevant area. |
| Device information | Operating system version, device model, platform, language/locale, time zone, and App version. See Section 6. |
| Push notification tokens | The push notification token issued to your device by Apple Push Notification service or Firebase Cloud Messaging. See Section 8. |
| Purchase verification data | The transaction or purchase token issued by the applicable app marketplace, used solely to verify and maintain your subscription entitlement. See Section 13. |
| Usage events | Anonymous, aggregate-oriented records indicating which screens of the App are reached, used to understand where users discontinue the setup process. See Section 7. |
When you use the App, certain data is collected automatically as a necessary incident of the App’s operation, including device information, push notification tokens, location data (subject to the permissions you grant), and the usage events described in Section 7. We do not employ web beacons, advertising identifiers, fingerprinting techniques, or third-party tracking software to build profiles of you across applications or websites.
Location is the core function of the App. With your express permission, the App collects precise location data on a continuous basis, including while the App operates in the background, in order to provide its protective features. On supported devices, location collection in the background is accompanied by a persistent system notification, and, where applicable, a system indicator, disclosing that location is being accessed.
You may grant, limit, or withdraw location permissions at any time through your device settings. You acknowledge that the App’s protective features depend on location access, and that restricting or withdrawing location permission will impair or wholly disable those features. The processing of your precise location, and the inferences the App may draw regarding your circumstances, are treated by us as sensitive information and are processed only on the basis of your explicit consent, as described in Section 14.
Location data is transmitted to our servers and may, upon your initiation or upon the occurrence of conditions you have configured, be transmitted to your designated counsel and contacts as described in Section 15.
We collect limited technical information about the device on which the App is installed, namely operating system version, device model, platform, language and locale, time zone, and the version of the App. This information is used to operate the service, to deliver notifications correctly, to diagnose operational issues, and to maintain the security and integrity of our systems.
We do not use any third-party analytics provider. The App transmits to our own servers a minimal record of which functional screens are reached during use, identified by numeric screen identifiers. We use this information exclusively to understand at which point users discontinue the initial setup process and to improve the usability of the App. This information is associated only with your randomly generated device identifier and is not enriched with, or sold to, any third party.
With your permission, the App sends push notifications to alert you to safety-relevant events, including proximity to or entry into areas of interest and the cessation of location tracking. To deliver these notifications, we transmit a push token to, and rely upon, Apple Push Notification service (for iOS devices) and Firebase Cloud Messaging operated by Google LLC (for Android devices). You may disable push notifications at any time through your device settings; doing so may prevent you from receiving time-sensitive safety alerts.
The App permits you to enter, manually, the contact details of an attorney and of trusted contacts. The App does not access, read, scan, or upload the address book or contact list stored on your device.
You represent and warrant that, prior to entering any other person’s personal information into the App, you have obtained that person’s informed consent to (i) the entry of their information into the App, and (ii) the transmission of your location and related information to them in the circumstances the App is designed to address. You are solely responsible for obtaining such consent, and you agree to indemnify the Company in respect of any claim arising from your failure to do so, as set forth in Section 24.
The current version of the App does not request or use access to your device’s camera, photo library, or microphone. Should a future version of the App introduce features requiring such access, we will request the corresponding permission at the point of use and will update this Privacy Policy accordingly before such features are made available.
The App is a native mobile application and does not use browser cookies. The App does not use advertising identifiers, cross-application tracking technologies, pixels, or third-party tracking software development kits.
The App incorporates a limited number of third-party services strictly necessary to deliver its functionality. Each such provider processes data under its own terms and privacy policy, over which the Company has no control.
| Provider | Function |
|---|---|
| Google LLC — Google Maps | Rendering of map tiles and display of geographic information within the App. |
| Google LLC — Firebase Cloud Messaging | Delivery of push notifications to Android devices. |
| Apple Inc. — Apple Push Notification service | Delivery of push notifications to iOS devices. |
| Apple Inc. — App Store / Google LLC — Google Play | Processing of purchases and management of subscriptions. |
THE COMPANY DOES NOT CONTROL, AND IS NOT RESPONSIBLE OR LIABLE FOR, THE PRIVACY PRACTICES, DATA PROCESSING, AVAILABILITY, SECURITY, OR CONDUCT OF ANY THIRD-PARTY SERVICE. Your use of any third-party service is governed by that party’s own terms and privacy policy, and we encourage you to review them.
The App may offer paid subscriptions or one-time purchases. All payments are processed exclusively by the operator of the marketplace through which you obtained the App — the Apple App Store or Google Play. We do not collect, receive, store, or process your payment card number, banking details, or other payment instrument information. We receive only a transaction or purchase token, which we use solely to verify the validity of your purchase and to maintain your subscription entitlement. The specific products offered, and their pricing, may change from time to time and are presented within the App at the point of purchase. Billing, renewals, refunds, and cancellations are administered by the applicable marketplace in accordance with its terms.
To the extent the GDPR or UK GDPR applies, we process personal data on the following legal bases:
Where you withdraw consent, or where consent is the sole applicable basis and is not given, the corresponding features of the App will not be available to you.
We disclose information only in the limited circumstances described below. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.
The central purpose of the App is to transmit your location and related information to the attorney and trusted contacts you have designated, either upon your express activation of the relevant feature or upon the occurrence of conditions you have configured. Such disclosure is initiated by you and made at your direction. Once your information has been transmitted to a recipient you designated, the Company has no control over, and accepts no responsibility for, that recipient’s use, retention, further disclosure, or safeguarding of the information.
We disclose information to the third-party service providers identified in Section 12 solely to the extent necessary for them to perform the functions described.
We may disclose information where we believe in good faith that disclosure is necessary to comply with applicable law or valid legal process, as further described in Section 26.
In the event of a merger, acquisition, reorganization, financing, sale of assets, or insolvency, information may be transferred as part of that transaction, subject to the surviving entity’s obligation to honor the commitments made in this Privacy Policy.
The Company and its server infrastructure are located in the United States of America, and all information collected through the App is processed and stored in the United States. The App is intended for users located in the United States. If you access the App from outside the United States, you understand and consent to the transfer, processing, and storage of your information in the United States, which may have data-protection laws that differ from those of your jurisdiction.
We retain personal information for as long as your installation remains active and your data has not been deleted, in order to provide the App’s functionality. You may delete your data at any time as described in Section 20. Upon deletion, your information is purged from our active production systems immediately, save where retention of specific records is required to comply with a legal obligation or to establish, exercise, or defend legal claims, in which case such records are retained only for so long as that purpose requires and are thereafter deleted.
We implement technical and organizational measures designed to protect information against unauthorized access, alteration, disclosure, or destruction, including encryption of sensitive identifiers on the device and the use of encrypted connections for transmission to our servers.
HOWEVER, NO METHOD OF TRANSMISSION OVER THE INTERNET, AND NO METHOD OF ELECTRONIC STORAGE, IS COMPLETELY SECURE. WE DO NOT AND CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR INFORMATION. You acknowledge that you provide your information at your own risk, and that the Company shall not be liable for any unauthorized access to, or acquisition, alteration, or loss of, information that occurs despite the implementation of reasonable security measures.
To the extent applicable, you have the right to request access to, rectification of, or erasure of your personal data; to restrict or object to processing; to data portability; and to withdraw consent at any time. You also have the right to lodge a complaint with a supervisory authority.
To the extent applicable, California residents have the right to know the categories and specific pieces of personal information collected; to request deletion of personal information; to correct inaccurate personal information; and to be free from discrimination for exercising these rights. The Company does not sell or share personal information as those terms are defined under the CCPA, and accordingly does not offer a “Do Not Sell or Share My Personal Information” mechanism because no such activity occurs.
Because the App is designed to operate without a registered account, the most direct and effective means of exercising your rights of erasure is to use the in-App deletion function described in Section 20. You may also submit a request using the contact details in Section 29. We may take reasonable steps to verify your request, and, given the anonymous design of the App, we may be unable to associate a request with specific data in the absence of information sufficient to identify it.
You may delete your data at any time through the deletion function provided within the App’s settings. Upon your confirmation, your name, attorney information, trusted-contact information, location records, proximity and zone-state records, device identifiers, and push tokens are purged from our active production systems immediately, subject only to the limited legal-retention exception described in Section 17. Deletion is irreversible.
The App is intended solely for individuals who are eighteen (18) years of age or older. The App is not directed to children, and we do not knowingly collect personal information from any individual under the age of eighteen. If we become aware that we have collected personal information from a person under eighteen, we will take steps to delete such information. If you believe a minor has provided us with personal information, please contact us using the details in Section 29.
THE APP AND ALL RELATED SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.
THE COMPANY DOES NOT WARRANT THAT THE APP WILL BE UNINTERRUPTED, TIMELY, SECURE, ERROR-FREE, OR FREE FROM LOSS OF DATA; THAT LOCATION DATA WILL BE ACCURATE, COMPLETE, OR TRANSMITTED WITHOUT DELAY OR FAILURE; THAT NOTIFICATIONS OR ALERTS WILL BE DELIVERED, DELIVERED ON TIME, OR RECEIVED BY ANY INTENDED RECIPIENT; OR THAT THE APP WILL PREVENT, DETECT, OR MITIGATE ANY HARM, DETENTION, OR ADVERSE EVENT. THE APP IS A SUPPLEMENTARY INFORMATIONAL TOOL AND IS NOT A SUBSTITUTE FOR EMERGENCY SERVICES, LEGAL ADVICE, OR PROFESSIONAL ASSISTANCE.
TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL THE COMPANY, ITS MEMBERS, MANAGERS, OFFICERS, EMPLOYEES, CONTRACTORS, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, DATA, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATING TO YOUR ACCESS TO OR USE OF, OR INABILITY TO ACCESS OR USE, THE APP, WHETHER BASED IN CONTRACT, TORT, STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
WITHOUT LIMITING THE FOREGOING, THE COMPANY SHALL NOT BE LIABLE FOR ANY HARM ARISING FROM (I) ANY FAILURE, DELAY, INACCURACY, OR INTERRUPTION IN THE COLLECTION OR TRANSMISSION OF LOCATION DATA OR NOTIFICATIONS; (II) ANY ACT OR OMISSION OF ANY ATTORNEY, CONTACT, OR OTHER RECIPIENT YOU DESIGNATE; (III) ANY ACT OF ANY GOVERNMENTAL OR LAW-ENFORCEMENT AUTHORITY; OR (IV) ANY CONDUCT OF ANY THIRD-PARTY SERVICE.
TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE AGGREGATE LIABILITY OF THE COMPANY FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THE APP SHALL NOT EXCEED THE GREATER OF (A) THE TOTAL AMOUNTS YOU PAID TO THE COMPANY FOR THE APP IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED UNITED STATES DOLLARS (US$100). Some jurisdictions do not allow certain limitations of liability, and accordingly some of the foregoing limitations may not apply to you.
YOU AGREE TO INDEMNIFY, DEFEND, AND HOLD HARMLESS THE COMPANY AND ITS MEMBERS, MANAGERS, OFFICERS, EMPLOYEES, CONTRACTORS, AND AGENTS FROM AND AGAINST ANY AND ALL CLAIMS, LIABILITIES, DAMAGES, LOSSES, COSTS, AND EXPENSES (INCLUDING REASONABLE ATTORNEYS’ FEES) ARISING OUT OF OR RELATING TO (I) YOUR USE OR MISUSE OF THE APP; (II) YOUR VIOLATION OF THIS PRIVACY POLICY OR ANY APPLICABLE LAW; (III) YOUR ENTRY OF ANY THIRD PARTY’S PERSONAL INFORMATION WITHOUT THAT PARTY’S CONSENT; OR (IV) ANY INFORMATION YOU PROVIDE THROUGH THE APP.
You are solely responsible for the accuracy, completeness, and lawfulness of all information you provide through the App, including your own information and any information concerning third parties. You are responsible for maintaining the security of your device, for granting and managing the permissions on which the App depends, and for ensuring that your device, network connectivity, and battery state permit the App to operate. You acknowledge that incomplete, inaccurate, or outdated information, or the absence of device permissions or connectivity, may render the App’s features ineffective.
The Company is subject to the laws of the United States. We may access, preserve, and disclose information where we believe in good faith that such action is reasonably necessary to (i) comply with applicable law, regulation, subpoena, court order, warrant, or other valid legal process; (ii) enforce our Terms of Service; (iii) detect, prevent, or address fraud, security, or technical issues; or (iv) protect the rights, property, or safety of the Company, our users, or the public as required or permitted by law. Where permitted by law and consistent with our obligations, we endeavor to limit such disclosure to that which is required.
The Company reserves the right, at its sole discretion and at any time, to modify, suspend, or discontinue the App or any feature thereof, in whole or in part, with or without notice, and to establish or modify limits on the use of the App. The Company shall not be liable to you or to any third party for any modification, suspension, or discontinuance of the App or any feature.
We may amend this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date at the top of this document and post the amended Policy at the URL identified above. Where required by applicable law, we will provide additional notice of, or seek your consent to, material changes. Your continued use of the App following the effective date of any amendment constitutes your acceptance of the amended Privacy Policy.
For questions about this Privacy Policy, or to exercise any privacy right, you may contact us: