Privacy Policy

Last Updated: March 19, 2026

Clueinit LTD ("we", "our", or "us") operates the Family Soul mobile application (the "App"). This Privacy Policy explains how we collect, use, store, share, and protect information when you use Family Soul.

1. About Family Soul

Family Soul is a family-oriented application that allows users to create and manage family tree records, connect with family members, share posts and media, store personal documents, create albums, use scannable cards, record finance-related notes, and optionally share live location with permitted family members.

2. Information We Collect

2.1 Information you provide directly

• Name
• Phone number
• Email address
• Date of birth
• Address or other profile information you choose to add
• Family relationship information you add to build or manage your family tree
• Posts, captions, comments, messages, audio, photos, videos, and other content you upload
• Documents you upload, such as licenses, ID-related files, certificates, and other records
• Loyalty/scannable card images or related information you choose to save
• Finance entries you create, such as money borrowed, lent, paid, or received

2.2 Information collected when you use certain features

• Location data: If you enable location-based features, we may collect your precise or approximate device location to provide live location or family tracking features.
• Activity recognition / physical activity data: If you enable safety features such as accident detection, we may access activity recognition or physical activity data to detect significant movement events and support safety-related alerts and family safety functionality. We do not sell this data. This data is only accessed when the feature is enabled and can be turned off at any time in your device settings.
• Notifications data: We may use push notification tokens and related device information to send alerts and updates.
• Media and file access: If you upload photos, videos, audio, or documents, we access only the files you choose to upload or capture.
• Camera access: If you use scanning or capture features, we may access your camera only when you use those features.

2.3 Automatically collected information

• Device type, operating system, app version, crash data, diagnostic data, and basic log information
• General usage information needed to maintain app performance, security, and reliability

3. How We Use Information

We use collected information to:

• Create and manage user accounts and family profiles
• Build, maintain, and sync family tree relationships
• Allow users to discover, connect with, and share content with family members based on app functionality and permissions
• Enable posts, albums, media sharing, and document storage
• Provide live location and family tracking features when enabled by the user
• Support scan, upload, and storage of cards and documents
• Support finance record features created by the user for personal/family tracking
• Send service notifications, reminders, and feature-related alerts
• Improve app reliability, performance, and security
• Detect abuse, unauthorized access, fraud, or policy violations
• Comply with applicable legal obligations

4. How Information Is Shared

We do not sell your personal information.

We may share information in the following ways:

• With family members or permitted users: Certain information, such as family tree entries, posts, albums, documents, live location, or other content, may be visible to family members or other users depending on the permissions, sharing settings, and feature design inside the App.
• With service providers: We may use trusted third-party service providers for hosting, cloud storage, notifications, analytics, security, and infrastructure support. These providers may process data on our behalf under contractual or legal restrictions.
• For legal reasons: We may disclose information if required by law, regulation, court order, or valid governmental request, or when necessary to protect rights, safety, or security.
• Business transfer: If our business is involved in a merger, acquisition, reorganization, or asset sale, information may be transferred as part of that transaction, subject to applicable law.

5. Cloud Storage and File Uploads

Media files, albums, documents, and other uploaded content may be stored using cloud infrastructure and object storage services, including Amazon S3-compatible storage or equivalent secure storage providers.

6. Permissions We May Request

Depending on which features you use, the App may request access to:

• Camera
• Photos / media / files
• Location
• Activity recognition / motion-related data
• Notifications

We request permissions only to provide relevant app functionality. You may decline certain permissions, but some features may not work properly without them.

7. Legal Bases and Consent

Where required, we rely on your consent to collect or process certain information, especially for optional permissions-based features such as location, notifications, media upload, camera access, and activity recognition. You can withdraw permission through your device settings, though this may affect feature availability.

8. Data Retention

We retain personal information for as long as necessary to provide the App, maintain your account, comply with legal obligations, resolve disputes, enforce our agreements, and support legitimate operational and security needs. Uploaded content, family tree records, and account-related information may remain stored until deleted by you, removed by an authorized user, or deleted in accordance with our retention practices.

9. Account Deletion and Data Deletion

You may request deletion of your account and associated data using the following link: https://profile.opensort.io/login/famtree

You may also contact us at [email protected] for privacy-related requests, including access, correction, or deletion requests, subject to applicable law and legitimate retention requirements.

10. Data Security

We use reasonable administrative, technical, and organizational safeguards to protect personal information from unauthorized access, loss, misuse, alteration, or disclosure. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Children’s Privacy

Family Soul is not intended to unlawfully collect personal information from children in violation of applicable law. If you believe personal data relating to a child has been provided improperly, please contact us so we can review and take appropriate action.

12. International Data Transfers

Your information may be processed and stored in countries other than your own, depending on where our service providers and infrastructure operate. Where required, we take reasonable steps to protect data during such transfers in accordance with applicable law.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the “Last Updated” date above. Material changes may also be communicated through the App or by other appropriate means.

14. Contact Us

If you have questions or requests regarding this Privacy Policy or our privacy practices, contact us at: [email protected]