TravelMate Privacy Policy

Last updated: 20 June 2026 Effective date: 20 June 2026

This Privacy Policy explains what personal data we collect, why, and what your rights are. It is incorporated by reference into the TravelMate Terms of Service.

We take your privacy seriously. TravelMate is offline-first: your trips, itineraries, schedules, and downloaded maps live on your device and work without an internet connection. We don't run a profile warehouse. We don't sell data. We don't show ads. We don't track you across apps or sites.

1. Data Controller

The data controller for personal data processed by TravelMate is:

Ilia Vlasov, operating as "w4app" (sole trader), domiciled in Finland. Contact: privacy@w4app.com (or support@w4app.com)

We plan to transfer the Service to w4app Oy in 2026 (expected Q3 2026). When that happens we will notify you and reissue this Policy under the new controller's name without reducing your protection — see Section 14.

We do not currently have a designated Data Protection Officer (DPO), as appointment is not mandatory under GDPR Art. 37 for an entity of our size and scope. We monitor this threshold; if our processing activities meet the DPO appointment criteria, we will appoint and disclose one.

2. What Data We Collect

Plain summary: location (only while you use a guide or discovery feature), your purchase/subscription status, crash diagnostics, a device token for notifications you turn on, and the trip text you type when you ask the AI for help. That's it. No contacts, no health data, no photos from your library, no advertising identifiers.

2.1 Location Data

TravelMate uses your device location to power nearby discovery, proactive suggestions, and the walking audio guide.

How location is handled:

2.2 Account and Subscription Data

2.3 Trip Content You Provide to AI Features

When you ask TravelMate to build an itinerary, narrate an audio guide, or answer a question about a place, the trip text, queries, and preferences you provide (e.g. a destination, dates, interests, or a question) are sent to our AI processor to generate the response (see Section 4). Where the app transcribes your voice into text (for a spoken query), the audio is sent transiently for transcription and is not retained on our servers after processing.

This content contains the text you choose to enter or speak. It does not include identifiers (no name, email, or account ID) at the AI-prompt layer.

2.4 Diagnostic Data

Crash and performance diagnostics, collected at the platform / billing-SDK level and via our error-monitoring tool (Sentry), to keep the app stable:

Hosting provider and region: [VERIFY — confirm production hosting provider and data-center region of the shared w4app backend / LLM proxy before publication. If outside the EEA, add transfer safeguards in Section 4/5.]

2.5 Payment Data

We do not collect or store payment card data. Apple (App Store) and Google (Google Play) process all payments via in-app purchase. We receive only subscription/entitlement status via Apple/Google and RevenueCat.

2.6 What We Do NOT Collect

We do not collect: contacts, health & fitness data, messages or calendar, your photo library (the imagery you see is Wikimedia Commons media rendered by the app, never your own photos), browsing or search history, advertising or device identifiers (no IDFA, no Android Advertising ID), or any "sensitive" special-category data. We do not use App Tracking Transparency (ATT) because the app does not track.

3. How We Use Your Data

Data Purpose Legal basis (GDPR)
Location (precise, session-scoped) Power the walking audio guide and proactive guidance you start Art. 6(1)(b) contract / Art. 6(1)(a) consent (device permission)
Location (coarse) Nearby discovery and proactive nudges Art. 6(1)(b) contract / Art. 6(1)(a) consent (device permission)
Trip text / queries / voice Generate itineraries, audio narration, and place answers via AI Art. 6(1)(b) contract
Account / entitlement data Authenticate, reconcile Pro entitlement, support Art. 6(1)(b) contract
Push device token Deliver notifications you have enabled Art. 6(1)(b) contract / Art. 6(1)(a) consent
Diagnostics (crash/performance) Keep the Service stable, fix bugs Art. 6(1)(f) legitimate interest
Payment / subscription status Operate the subscription Art. 6(1)(b) contract + Art. 6(1)(c) legal obligation

We do not use your data for:

4. Who We Share Data With (Sub-processors)

We engage carefully selected sub-processors. They process personal data only on our instructions and only as needed to operate the Service. The table below reflects the sub-processors used in production as of the last-updated date.

Sub-processor Purpose Data processed Location Safeguards
Apple Inc. iOS app distribution, In-App Purchase, Apple Push Notification service Account/entitlement identifiers, subscription status, push device token Ireland (EU) / Worldwide EU-US Data Privacy Framework
Google LLC Android app distribution (Google Play), Google Play Billing, Firebase Cloud Messaging (push) Account/entitlement identifiers, subscription status, push device token United States / Worldwide EU-US Data Privacy Framework + SCCs
OpenAI, L.L.C. AI processing — itinerary narrative (GPT-5.5), audio guide (text-to-speech), voice transcription (Whisper) — reached via the shared w4app LLM proxy Trip text / queries / preferences you provide; transiently, voice audio for transcription (no persistent identifiers) United States SCCs (2021 module 2) + API "no-training" / zero-retention provisions where available
RevenueCat, Inc. Subscription / entitlement management across stores Account identifier, subscription/entitlement state United States EU-US Data Privacy Framework + SCCs
Functional Software, Inc. (Sentry) Crash / error monitoring PII-scrubbed technical diagnostics (no trip text, no precise location) United States SCCs (2021 module 2)

Map, place, and imagery data (NOT third-party data sharing)

TravelMate's place and map data come from self-hosted OpenStreetMap services (Overpass + Valhalla) operated by us, GPT-5.5 model knowledge, and Wikimedia Commons imagery. We use no Google Places, Google Maps, Foursquare, Yelp, Mapbox, or any other paid third-party place / imagery / map-tile vendor. No third-party place vendor receives your data. When the app fetches a public map tile or a Wikimedia image, it retrieves public content; it does not send your personal data to a place vendor for that purpose.

How the w4app LLM proxy works

The trip text you provide is sent to a shared w4app LLM proxy operated by us. The proxy injects the API key server-side (the key is never on your device) and forwards your request to OpenAI (api.openai.com). The proxy does not attach your name, email, or account ID to the AI prompt. We do not retain your prompts and responses on our servers beyond ephemeral processing.

We do not share data with sub-processors not listed above without prior notice and, where required, your consent.

5. International Data Transfers

Where personal data is transferred outside the EEA (e.g., to our AI processor, billing processor, or error-monitoring processor in the US), we rely on:

You can request copies of the safeguards in place by emailing privacy@w4app.com.

6. How Long We Keep Data

Data Retention
On-device trips, itineraries, schedules, downloaded maps Until you delete them or uninstall the app (stored on your device)
Account / entitlement data Until account closure + 30 days
Subscription / billing records 7 years (legal obligation — accounting/tax)
AI prompt / response content Not retained on our servers beyond ephemeral processing
Location used in a guide session Not retained as a tracked trail; processed to produce the requested guidance only
Diagnostic / crash data [VERIFY — confirm Sentry retention window; default 90 days]
Support communications 24 months

When you delete your account (via the in-app account screen or the support route), server-side account deletion runs over the shared w4app identity stack. On-device data is removed when you delete it or uninstall the app. Subscription/billing records are retained for legal compliance, accessible only on legitimate request.

7. Your Rights (GDPR Articles 12–22)

If we process your personal data, you have the following rights:

Right What it means How to exercise
Access (Art. 15) Get a copy of your data privacy@w4app.com
Rectification (Art. 16) Correct inaccurate data In-app for most fields, OR email
Erasure (Art. 17) Have your data deleted In-app account screen → Delete account, OR https://w4app.com/travelmate/support
Restriction (Art. 18) Limit how we process your data Email
Portability (Art. 20) Get your data in a portable format Email
Objection (Art. 21) Object to certain processing Email
Withdraw consent (Art. 7(3)) Withdraw consent where consent is the basis (e.g., disable location in system settings) Device settings, or by email
Lodge a complaint Complain to a supervisory authority Finnish DPA (Tietosuojavaltuutettu): https://tietosuoja.fi/en

We respond within 30 days (extendable by 60 days for complex requests, with notice). We do not charge for these requests except where they are manifestly unfounded or excessive.

8. Children

The Service is a general-audience travel utility (age rating 4+ / PEGI 3) and is not directed at children. [VERIFY — Founder to set the minimum age: default here is "not intended for users under 16." Finland's GDPR-K digital-consent age is 13; the Terms of Service set the contracting age. Align this section with the Terms once decided.] We do not knowingly collect data from children below the applicable age threshold without verifiable parental consent. If you believe a child has provided us data, contact privacy@w4app.com and we will delete it promptly.

9. Security

We implement technical and organizational measures appropriate to the risk:

Despite our efforts, no system is fully secure. In the event of a data breach affecting your personal data, we will notify you and the supervisory authority as required by law.

10. Automated Decision-Making and Profiling

The Service uses AI to generate travel suggestions, itineraries, and narration personalized to your stated preferences and location. We do not make decisions with legal or similarly significant effects about you using automated means under Art. 22 GDPR.

You can always:

11. Cookies and Tracking

The mobile app does not use cookies in the web sense and does not track you.

Our marketing website (w4app.com, https://w4app.com/travelmate) may use:

We do not use advertising cookies, cross-site tracking, the IDFA, or the Android Advertising ID. We declare our Apple Privacy Manifest accordingly and do not declare the AD_ID permission on Android.

12. Store Privacy Disclosures (Apple App Privacy + Google Play Data safety)

This Privacy Policy is the canonical source. The Apple App Privacy survey (App Store Connect) and the Google Play Data safety form must be kept in exact sync with it and with the sub-processor table in Section 4.

Apple App Privacy — declared:

Google Play Data safety — declared:

[VERIFY before submission: that the App Store Connect App Privacy survey and Play Console Data safety form match this Section and Section 4 exactly, including the AI/error-monitoring processors. Note for reviewers: the store nutrition labels disclose declared-data only; this hosted policy is the full GDPR Art. 13/14 disclosure and is the document referenced by the mandatory Privacy Policy URL field in both stores.]

13. Changes to This Policy

We may update this Privacy Policy. For material changes, we will notify you in-app and (if you have provided an email) by email at least 30 days before the change takes effect, and make the prior version available on request. Continued use after the effective date constitutes acceptance.

14. Change of Controller

The data controller is currently the toiminimi listed in Section 1. We plan to transfer the Service to w4app Oy in 2026 (expected Q3 2026). When this transfer occurs:

The legal basis for the transfer is GDPR Art. 6(1)(b) and (f) — necessity for the contract and the legitimate interest of corporate reorganization that does not adversely affect you.

15. Contact

Hosted at: https://w4app.com/travelmate/privacy (the URL referenced in App Store Connect and Google Play Console).

Document control