Data Protection Notice — TAMI Guide App

• Lighthouse Tech SA
• Registered office: Via Maestri Comacini 10C, 6834 Morbio Inferiore, Switzerland
• Commercial register no. / VAT no.: CHE-417.550.044
• Email: info@lighthousetech.ch

Lighthouse Tech SA ("we", "our" or the "Company") is the controller of personal data collected through the TAMI Guide application (the "App").

We collect the following categories of personal data. Because the App and the TAMI device are designed for blind and visually impaired people, the fact that you hold an account and pair a device may reveal information about your health (a visual impairment). We therefore treat your account and usage data as a special category of personal data under Article 9 GDPR and as sensitive personal data under Article 5(c) FADP, and we process it on the basis of your explicit consent (see Section 3).

Google and Firebase act as our processors and process personal data on our behalf under a data processing agreement; they may engage sub-processors. For Google Sign-In, Google acts as an independent controller for the authentication it carries out. We remain the controller of the personal data processed through the App.

Special provisions for users under 16 years of age:

• Use of the App by minors under 16 requires verifiable consent from a parent or legal guardian
• We do not knowingly collect personal data from children under 16 without verifiable parental consent
• We verify parental or guardian consent by reasonable means proportionate to the risks of the processing (for example, confirmation through the parent's or guardian's email address), in line with Article 8(2) GDPR
• Parents/guardians may request access to, modification of, or deletion of their child's data by contacting us
• We limit the collection of minors' data to the minimum necessary for the App to function

We retain your personal data for as long as necessary to:

• Account data: until the account is deleted by the user
• Device configuration data: until the device is disconnected or the account is deleted
• Diagnostic logs: maximum 90 days
• Data for legal obligations: as required by applicable law (for example, accounting records are retained for about 10 years under the Swiss Code of Obligations)
• Inactive accounts: if an account remains inactive for 24 months, we will contact you and then delete the account and associated data
• After account deletion: personal data is removed from active systems within 30 days and from backups within 90 days

Your data may be transferred to and stored on servers located outside Switzerland/EEA, in particular in the United States (Google/Firebase servers). Such transfers are carried out on the basis of:

• Standard contractual clauses approved by the European Commission (the EU SCCs, with the "Swiss Finish" amendments for transfers from Switzerland), with Google LLC named as the data importer
• Provider certification under the EU-U.S. and Swiss-U.S. Data Privacy Framework (the Swiss-U.S. framework, effective 15 September 2024, applies to data transferred from Switzerland); Google LLC must be certified under the framework relevant to the transfer

In accordance with the GDPR, the Swiss FADP, and applicable regulations, you have the right to:

• Access: obtain confirmation of processing and a copy of your data
• Rectification: correct inaccurate or incomplete data
• Erasure: request deletion of your data ("right to be forgotten")
• Restriction: restrict processing in certain circumstances
• Portability: receive your data in a structured format
• Objection: object to processing based on legitimate interest
• Withdrawal of consent: withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal (Article 7(3) GDPR)

We adopt appropriate technical and organisational measures to protect your data, proportionate to the sensitivity of the data. These include encryption of data in transit and at rest, encrypted credential storage, strict access controls (including multi-factor authentication for administrative access), and regular monitoring and audits.

In the event of a personal data breach, we will notify the competent supervisory authority and, where required, affected individuals, in accordance with Articles 33 and 34 GDPR and Article 24 FADP, and we keep internal records of all breaches.

The App requires the following permissions:

• Bluetooth: required to connect to TAMI devices
• Location: on Android 12 and later, Bluetooth scanning uses the BLUETOOTH_SCAN permission declared with the "neverForLocation" flag, so location access is not requested. On Android 11 and earlier, the operating system still requires location permission for Bluetooth scanning; we do not use your location for any other purpose
• Notifications: to receive firmware updates (service notifications). Marketing newsletters are sent only with your separate, optional consent, which is not required in order to use the device
• Internet: for data synchronisation and updates
• Storage: to save logs and configurations locally

The App does not use cookies. We use local storage technologies (SharedPreferences, SecureStorage) exclusively to:

• Maintain the login session
• Save user preferences
• Store local configurations

We reserve the right to modify this Data Protection Notice. In the event of material changes:

• We will notify you via an in-app notification
• We will update the "last updated" date
• For changes requiring new consent, we will ask you to accept the updated Notice

You have the right to lodge a complaint with the competent supervisory authority:

• Switzerland: Federal Data Protection and Information Commissioner (FDPIC)
• EU: the data protection authority of your country of residence