Where Am I (WAI)

Last updated: 7 Sep 2026

1. Controller and Scope

This Privacy Policy explains how personal data is processed when you use the mobile application Where Am I (“WAI”, “App”, “Service”).

Data Controller

Stanislav Pelekhov

Flotowgasse 23/1/7

1190 Vienna

Austria

Email: privacy@jumpstartapp.at

This Privacy Policy applies to users located in the European Union (EU)/European Economic Area (EEA), the United Kingdom, and the United States.

This document applies regardless of whether you use the App actively, passively, in the background, or through future integrations (such as vehicle or system interfaces).

This Privacy Policy is intended to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), applicable Austrian data protection law, and other relevant data protection regulations.

2. Overview and Core Principles

The App is designed as a location-based informational and experiential service.

The operator processes personal data in accordance with the principles of:

• data minimization,
  
• purpose limitation,
  
• storage limitation,
  
• integrity and confidentiality.
  

Personal data is processed only to the extent necessary to provide the App’s core functionality and to measure the performance of the operator’s own marketing activity, as described in Section 6.3. Personal data is never sold and is never used for profiling unrelated to the App.

3. Categories of Personal Data Processed

3.1 Location Data (Core Functionality)

The App processes precise location data on a continuous basis while the App is in use.

This may include:

• latitude and longitude,
  
• timestamps,
  
• inferred movement patterns based on location signals.
  

Purpose

Location data is required to determine proximity to places, trigger narration, and associate generated content with passed locations. Without precise location data, the core functionality of the App cannot operate.

Storage

If you use the App without an account, the trips you record and the stories you like are transmitted to the operator’s servers together with a randomly generated installation identifier. 

This identifier is created when the App is installed and does not contain your name, email address or any other detail that identifies you directly. Location history is also kept locally on the device for up to 24 hours and is then automatically deleted unless you explicitly save it.

If you later sign in, the trips recorded on that installation before you signed in are associated with your account. From that point they are treated as account data under Section 3.4. If you are signed in, the trips you record are stored on the operator’s servers and linked to your account. 

A stored trip includes the coordinates of the route, the waypoints passed, the narrations that were played, and the stories you liked. Stored trips are retained until you delete them or delete your account. 

Reinstalling the App generates a new installation identifier. Data recorded under a previous installation identifier is no longer accessible from the App. 

Location data is not used to track users across unrelated services or applications and is not shared with advertising networks.

3.2 Generated Content and Usage Data

The App processes:

• AI-generated narration and textual descriptions,
  
• associations between locations and generated content,
  
• interaction data (e.g., narration started, skipped, saved).
  

This data is processed to provide continuity of experience, enable recap functionality, and improve content relevance.

Generated content may be stored temporarily on servers as part of the content generation process and may be retained in anonymized or aggregated form to improve the Service.

For signed-in users, the narrations that were played and the stories that were liked are stored with the user’s account as described in Section 3.4, and are retained until the user deletes them or deletes the account.

3.3 Technical and Diagnostic Data

The App processes limited technical and diagnostic data, including:

• device type and operating system version,
  
• app version,
  
• crash logs and error reports,
  
• anonymized performance metrics.
  

This data is processed strictly to ensure stability, security, and functionality of the App. It is not used to identify users personally.

3.4 Account Data

The App offers optional user accounts. You can use the App without an account. Signing in allows your trips and listening history to be saved to your account. 

Sign in with Apple is the only sign-in method offered. When you sign in, the operator receives and stores an email address and an account identifier provided by Apple. 

If you use Apple’s Hide My Email option, the operator receives a private relay address ending in @privaterelay.appleid.com instead of your real email address, and has no access to your real address. 

Data stored with an account: the email address, the account identifier, saved trips with their coordinates and waypoints, narrations that were played, and liked stories.

4. Use of Artificial Intelligence

The App uses artificial intelligence services, including third-party providers, to generate location-based content.

Location data and contextual signals may be transmitted to servers solely for the purpose of generating requested outputs. AI providers act on the operator’s instructions and do not independently determine the purposes of processing.

AI-generated content is produced automatically and is not reviewed or curated on an individual basis.

AI-related processing is conducted strictly within the scope of the legal bases described in this Privacy Policy and does not involve automated decision-making producing legal or similarly significant effects within the meaning of Article 22 GDPR.

5. Legal Bases for Processing (EU / UK)

Personal data is processed under the following legal bases:

• Performance of a contract (Art. 6(1)(b) GDPR): Processing necessary to deliver the App’s core functionality.
  
• Consent (Art. 6(1)(a) GDPR): Processing of precise location data where required by device or platform rules.
  
• Legitimate interests (Art. 6(1)(f) GDPR): Processing necessary to ensure security, prevent misuse, and improve the Service.
  

Where processing is based on consent, users may withdraw consent at any time via device settings. Withdrawal of consent may limit or disable App functionality.

6. Sharing of Personal Data

Personal data is shared only to the extent necessary to operate the App.

6.1 Service Providers

Personal data may be shared with service providers that support:

• AI processing,
  
• analytics,
  
• crash reporting,
  
• hosting and infrastructure.

The operator currently uses the following providers: OpenAI, Google (Gemini, Firebase Analytics and Crashlytics), Microsoft Azure (AI Speech), xAI (Grok), Meta Platforms, and hosting infrastructure providers. Geographic and encyclopaedic content is retrieved from OpenStreetMap, Wikipedia and Wikidata..

Such providers act as processors under applicable data protection law and are contractually bound to process data only on documented instructions and to apply appropriate security measures.

6.2 Third-Party Navigation Services

If you choose to open third-party navigation or mapping services (e.g., Google Maps), data processing is governed exclusively by the third party’s privacy policies.

The operator does not control, access, or receive data processed by such third-party services.

6.3 Analytics and Marketing Measurement

The App includes software development kits provided by Google (Firebase Analytics and Crashlytics) and by Meta Platforms (Facebook SDK). 

Firebase is used for usage analytics and crash reporting. The Meta SDK is used to measure the performance of the operator’s own marketing activity. 

For this purpose the following data may be processed: an app-level installation identifier, an app-level user identifier, and events describing interaction with the App. 

The App does not request access to the iOS advertising identifier (IDFA) and does not track users across other companies’ apps and websites. 

Your precise location is not transmitted to Meta and is not used for advertising purposes.

7. International Data Transfers

Some service providers may be located outside the EU/EEA or UK.

Where personal data is transferred internationally, appropriate safeguards are applied, including adequacy decisions, standard contractual clauses, or equivalent legal mechanisms. Transfers are limited to what is necessary for service delivery.

8. Data Retention

Personal data is retained only for as long as necessary for the purposes described:

• non-saved location data: automatically deleted within 24 hours;
  
• saved journeys: retained until deleted by the user;
  
• technical and diagnostic data: retained for limited periods necessary for stability and security.
• guest data that is associated only with an installation identifier and has not been linked to an account is deleted automatically after 6 months of inactivity.
  

Retention periods may vary depending on legal obligations, operational needs, or security requirements.

8.1 Deleting Your Account 

You can delete your account and all data stored with it at any time from within the App: open Settings, scroll to the Account section, tap “Delete Account and Data” and confirm. Deletion permanently removes your email address, account identifier, saved trips, location history and associated data from the operator’s servers, and revokes the Sign in with Apple token issued to the App. The data cannot be restored. You may also request deletion by writing to privacy@jumpstartapp.at.

9. User Rights (EU / UK)

Users have the following rights under applicable law:

• access your personal data;
  
• request rectification of inaccurate data;
  
• request erasure (“right to be forgotten”);
  
• request restriction of processing;
  
• receive data portability where applicable;
  
• object to processing based on legitimate interests.
  

Requests are handled in accordance with applicable law and may require verification of identity.

Where data is associated only with a randomly generated installation identifier and cannot be linked to an identifiable person, the operator may be unable to locate that data in response to an access or erasure request. In such cases the operator will explain this in its response.

10. US Users – State Privacy Rights

Depending on applicable state law, US users may have rights to:

• access personal data;
  
• request deletion or correction;
  
• limit certain processing activities.
  

The App does not sell personal data. Data shared with Meta Platforms to measure the operator’s own marketing activity, as described in Section 6.3, is limited to app-level identifiers and interaction events, and does not include location data.

11. Security Measures

The operator implements appropriate technical and organizational measures to protect personal data, including access controls, encrypted communications, and limited access to data.

While reasonable efforts are made to protect data, no system can guarantee absolute security, and residual risks may remain.

12. Children’s Privacy

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

The operator does not knowingly collect personal data from children under 16. If such data is identified, it will be deleted without delay.

13. Changes to This Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in functionality, legal requirements, or operational practices.

Material changes will be effective upon publication, and continued use of the App constitutes acceptance of the updated Privacy Policy.

14. Contact and Complaints

For privacy-related inquiries, requests, or complaints, contact:

Email: privacy@jumpstartapp.at

EU/UK users also have the right to lodge a complaint with a competent data protection authority.

For users in Austria, the competent authority is the Austrian Data Protection Authority (Datenschutzbehörde).

PRIVACY POLICY

Where Am I (WAI)

Last updated: 12 Mar 2026

1. Controller and Scope

This Privacy Policy explains how personal data is processed when you use the mobile application Where Am I (“WAI”, “App”, “Service”).

Data Controller

Stanislav Pelekhov

Flotowgasse 23/1/7

1190 Vienna

Austria

Email: [privacy@jumpstartapp.at]

This Privacy Policy applies to users located in the European Union (EU)/European Economic Area (EEA), the United Kingdom, and the United States.

This document applies regardless of whether you use the App actively, passively, in the background, or through future integrations (such as vehicle or system interfaces).

This Privacy Policy is intended to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), applicable Austrian data protection law, and other relevant data protection regulations.

2. Overview and Core Principles

The App is designed as a location-based informational and experiential service.

The operator processes personal data in accordance with the principles of:

• data minimization,
  
• purpose limitation,
  
• storage limitation,
  
• integrity and confidentiality.
  

Personal data is processed only to the extent necessary to provide the App’s core functionality and is never used for advertising, resale, or unrelated profiling purposes.

3. Categories of Personal Data Processed

3.1 Location Data (Core Functionality)

The App processes precise location data on a continuous basis while the App is in use.

This may include:

• latitude and longitude,
  
• timestamps,
  
• inferred movement patterns based on location signals.
  

Purpose

Location data is required to determine proximity to places, trigger narration, and associate generated content with passed locations. Without precise location data, the core functionality of the App cannot operate.

Storage

Location history is stored locally on the device for up to 24 hours and is automatically deleted unless explicitly saved by the user. The operator does not maintain a permanent server-side log of unsaved location histories.

Location data is not used to track users across unrelated services or applications.

3.2 Generated Content and Usage Data

The App processes:

• AI-generated narration and textual descriptions,
  
• associations between locations and generated content,
  
• interaction data (e.g., narration started, skipped, saved).
  

This data is processed to provide continuity of experience, enable recap functionality, and improve content relevance.

Generated content may be stored temporarily on servers as part of the content generation process and may be retained in anonymized or aggregated form to improve the Service.

3.3 Technical and Diagnostic Data

The App processes limited technical and diagnostic data, including:

• device type and operating system version,
  
• app version,
  
• crash logs and error reports,
  
• anonymized performance metrics.
  

This data is processed strictly to ensure stability, security, and functionality of the App. It is not used to identify users personally.

3.4 Account Data (Future Features)

At launch, the App does not require the creation of a user account.

If account functionality is introduced, the App may process identifiers such as email address or platform login credentials, together with user preferences and saved journeys. Any such processing will remain subject to this Privacy Policy and applicable law.

4. Use of Artificial Intelligence

The App uses artificial intelligence services, including third-party providers, to generate location-based content.

Location data and contextual signals may be transmitted to servers solely for the purpose of generating requested outputs. AI providers act on the operator’s instructions and do not independently determine the purposes of processing.

AI-generated content is produced automatically and is not reviewed or curated on an individual basis.

AI-related processing is conducted strictly within the scope of the legal bases described in this Privacy Policy and does not involve automated decision-making producing legal or similarly significant effects within the meaning of Article 22 GDPR.

5. Legal Bases for Processing (EU / UK)

Personal data is processed under the following legal bases:

• Performance of a contract (Art. 6(1)(b) GDPR): Processing necessary to deliver the App’s core functionality.
  
• Consent (Art. 6(1)(a) GDPR): Processing of precise location data where required by device or platform rules.
  
• Legitimate interests (Art. 6(1)(f) GDPR): Processing necessary to ensure security, prevent misuse, and improve the Service.
  

Where processing is based on consent, users may withdraw consent at any time via device settings. Withdrawal of consent may limit or disable App functionality.

6. Sharing of Personal Data

Personal data is shared only to the extent necessary to operate the App.

6.1 Service Providers

Personal data may be shared with service providers that support:

• AI processing,
  
• analytics,
  
• crash reporting,
  
• hosting and infrastructure.
  

Such providers act as processors under applicable data protection law and are contractually bound to process data only on documented instructions and to apply appropriate security measures.

6.2 Third-Party Navigation Services

If you choose to open third-party navigation or mapping services (e.g., Google Maps), data processing is governed exclusively by the third party’s privacy policies.

The operator does not control, access, or receive data processed by such third-party services.

7. International Data Transfers

Some service providers may be located outside the EU/EEA or UK.

Where personal data is transferred internationally, appropriate safeguards are applied, including adequacy decisions, standard contractual clauses, or equivalent legal mechanisms. Transfers are limited to what is necessary for service delivery.

8. Data Retention

Personal data is retained only for as long as necessary for the purposes described:

• non-saved location data: automatically deleted within 24 hours;
  
• saved journeys: retained until deleted by the user;
  
• technical and diagnostic data: retained for limited periods necessary for stability and security.
  

Retention periods may vary depending on legal obligations, operational needs, or security requirements.

9. User Rights (EU / UK)

Users have the following rights under applicable law:

• access your personal data;
  
• request rectification of inaccurate data;
  
• request erasure (“right to be forgotten”);
  
• request restriction of processing;
  
• receive data portability where applicable;
  
• object to processing based on legitimate interests.
  

Requests are handled in accordance with applicable law and may require verification of identity.

10. US Users – State Privacy Rights

Depending on applicable state law, US users may have rights to:

• access personal data;
  
• request deletion or correction;
  
• limit certain processing activities.
  

The App does not sell personal data and does not engage in targeted advertising or cross-context behavioral profiling.

11. Security Measures

The operator implements appropriate technical and organizational measures to protect personal data, including access controls, encrypted communications, and limited access to data.

While reasonable efforts are made to protect data, no system can guarantee absolute security, and residual risks may remain.

12. Children’s Privacy

The App is not intended for individuals under 18 years of age.

The operator does not knowingly collect personal data from minors. If such data is identified, it will be deleted without delay.

13. Changes to This Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in functionality, legal requirements, or operational practices.

Material changes will be effective upon publication, and continued use of the App constitutes acceptance of the updated Privacy Policy.

14. Contact and Complaints

For privacy-related inquiries, requests, or complaints, contact:

Email: [privacy@yourdomain.com]

EU/UK users also have the right to lodge a complaint with a competent data protection authority.

For users in Austria, the competent authority is the Austrian Data Protection Authority (Datenschutzbehörde).