Navigate 360: AR Map Camera

Privacy Policy

Effective Date: March 26, 2026

Issued by Blacksnowgames Inc.  ·  United States of America

Blacksnowgames Inc. (“we,” “us,” or “our”) respects your privacy. This Privacy Policy explains what information we collect when you use the Navigate 360: AR Map Camera mobile application (the “App”), why we collect it, how we use and protect it, and what rights you have with respect to your data. Please read this Policy carefully. By using the App, you agree to the practices described herein.

1. Who We Are and How to Contact Us

Blacksnowgames Inc. is the data controller responsible for your personal data collected through the App. We are incorporated and operate in the United States of America.

For all privacy-related questions, data access requests, deletion requests, or complaints, please contact us at:

Blacksnowgames Inc.

United States of America

Email: developers@blacksnow.tv

We aim to respond to all privacy inquiries within ten (10) business days and to all data subject rights requests within the timeframes required by applicable law.

2. What Personal Data We Collect

We collect the following categories of personal data when you use the App. We collect only the data necessary to provide the App’s functionality.

2.1 Precise Geolocation Data

We continuously access your device’s GPS receiver while the App is active to determine your precise geographic coordinates (latitude, longitude, and altitude). This constitutes “precise geolocation data” and “sensitive personal information” under applicable US privacy laws including the CCPA/CPRA, and “special category data” requiring careful handling under GDPR.

Why we collect it:  To anchor AR overlays to your physical location, calculate distances to nearby places, generate navigation routes, and provide spatially relevant AI-generated responses

How long we keep it:  Processed in real time during your active session. Not retained on our servers beyond the active session unless you have separately consented

Legal basis (GDPR):  Contractual necessity (Art. 6(1)(b)) — necessary to deliver the core navigation service you have requested

2.2 Compass, Orientation, and Motion Data

We access your device’s digital compass, gyroscope, and accelerometer to determine the direction you are facing and the tilt and motion of your device.

Why we collect it:  To render AR labels, arrows, and place information accurately oriented to your real-world viewpoint

How long we keep it:  Processed locally on your device in real time. Not transmitted to or stored on our servers

Legal basis (GDPR):  Contractual necessity (Art. 6(1)(b))

2.3 Camera Feed

We access your device’s rear camera to render augmented reality overlays onto your live camera view.

Why we collect it:  To superimpose AR labels, navigation arrows, and place information onto the real-world environment visible through your camera

How long we keep it:  Processed entirely on your device in real time. The camera feed is never recorded, stored, or transmitted to our servers or any third party

Legal basis (GDPR):  Contractual necessity (Art. 6(1)(b))

2.4 Voice and Microphone Data

When you activate the voice query feature, we capture audio from your device’s microphone. Your voice input is transcribed into text and the transcribed query — combined with your real-time spatial context — is transmitted to our servers and to third-party large language model (LLM) providers for processing.

Why we collect it:  To interpret your spoken query and return a spatially relevant result in your camera view

How long we keep it:  Voice audio is transcribed and the audio itself is not stored. Transcribed query text is retained only for the duration of the processing operation, typically seconds. Anonymised, aggregated query data may be retained for up to 90 days for service improvement purposes, unless you opt out

Legal basis (GDPR):  Consent (Art. 6(1)(a)) — you actively trigger the voice feature each time. Processing of voice data as a biometric identifier is subject to Art. 9 protections where applicable

2.5 Device and Technical Data

We collect technical data about your device and your use of the App, including:

• Device model, manufacturer, and operating system version
• App version and unique installation identifier
• Crash logs, error reports, and performance metrics
• Session duration and feature usage statistics (aggregated and anonymised where possible)
• IP address (used to determine approximate region for compliance purposes; not stored with your activity data)

Why we collect it:  To maintain and improve App stability and performance, diagnose technical issues, and ensure compatibility across devices

How long we keep it:  Up to twelve (12) months from collection, after which it is deleted or anonymised

Legal basis (GDPR):  Legitimate interests (Art. 6(1)(f)) — maintaining the security and performance of the App

2.6 Data We Do Not Collect

We do not collect: your name, email address, or other contact information (unless you contact us directly); payment or financial information; contacts, photos, or files stored on your device; social media profile data; advertising identifiers (IDFA/GAID) for targeted advertising; or any data not described in this Policy.

3. How We Use Your Personal Data

We use the personal data we collect solely for the following purposes:

• Providing the App’s core functionality: rendering AR overlays, processing voice queries, calculating navigation routes, and identifying nearby places using your GPS and orientation data
• Processing AI-powered voice queries: combining your transcribed voice input with your spatial context and transmitting it to LLM providers to generate spatially relevant responses
• Maintaining and improving the App: analysing crash reports, performance metrics, and aggregated usage data to identify and fix bugs, improve features, and optimise performance
• Ensuring security and preventing fraud: monitoring for anomalous usage patterns that may indicate unauthorised access or misuse
• Complying with legal obligations: retaining and disclosing data where required by applicable law, court order, or regulatory authority
• Responding to your requests: processing data access, deletion, correction, or portability requests you submit to us

We do not use your personal data for: targeted advertising or behavioural profiling; selling or renting your data to third parties; building user profiles for commercial purposes beyond App improvement; or any purpose not listed above.

4. How We Share Your Personal Data

We do not sell your personal data. We share your data only in the following limited circumstances:

4.1 Third-Party Service Providers

We engage third-party companies to process data on our behalf as data processors, subject to contractual data processing agreements that restrict their use of your data to the services they provide us. These categories of providers include:

AI and LLM Providers

Your transcribed voice query and associated spatial context (GPS coordinates and compass bearing) are transmitted to one or more third-party large language model providers to generate spatially relevant responses. These providers process data under our instructions and are contractually prohibited from using your data to train their models without your consent.

Cloud Infrastructure and Hosting

We use cloud computing infrastructure providers to host the App’s backend services. These providers process technical and usage data on our behalf under strict data processing agreements.

Analytics and Crash Reporting

We may use third-party analytics and crash reporting tools to collect aggregated, anonymised performance data. Where these tools process personal data, we ensure appropriate data processing agreements are in place.

Mapping and Location Data Services

The App integrates third-party mapping and points-of-interest databases to provide place information. Your approximate location may be transmitted to these providers to retrieve nearby place data.

4.2 Legal Disclosure

We may disclose your personal data without your consent where required by law, including: (i) in response to a valid court order, subpoena, or other legal process; (ii) to comply with applicable law or regulation; (iii) to enforce our Terms of Service or protect our legal rights; (iv) to protect the safety of users or the public; or (v) in connection with a legal investigation.

4.3 Business Transfers

If Blacksnowgames Inc. is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your personal data may be transferred as part of that transaction. We will notify you via in-App notification or email before your personal data is transferred and becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your data with third parties not listed above where you have provided explicit prior consent for a specific sharing activity.

5. International Data Transfers

Blacksnowgames Inc. is based in the United States. When you use the App, your personal data — including GPS coordinates, voice query data, and technical data — is processed on servers located in the United States and, through our third-party service providers, potentially in other countries.

The United States has not been found by the European Commission to provide an adequate level of data protection equivalent to that in the European Union or European Economic Area. Where we transfer personal data from the EU, EEA, or UK to the United States or other third countries, we rely on the following safeguards under GDPR Chapter V:

• Standard Contractual Clauses (SCCs) adopted by the European Commission (Commission Implementing Decision (EU) 2021/914), incorporated into our data processing agreements with all third-party processors receiving EU personal data
• UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs, as applicable, for transfers from the United Kingdom

A copy of the applicable Standard Contractual Clauses may be obtained by contacting us at developers@blacksnow.tv.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal obligations, or to resolve disputes. The following specific retention periods apply:

GPS / orientation / camera data  —  Processed in-session only. Not stored on our servers.

Voice transcription / query text  —  Retained only for the duration of query processing (typically seconds). Anonymised aggregate query data: up to 90 days.

Technical / diagnostic data  —  Up to 12 months from collection.

Legal / compliance records  —  As required by applicable law (typically 5–7 years for legal records).

Correspondence / support requests  —  Up to 3 years from last contact.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data destruction procedures.

7. Your Privacy Rights

Depending on your country or state of residence, you may have the following rights with respect to your personal data. We honour all rights available to you under applicable law.

7.1 Rights Available to All Users

• Right to be informed: The right to clear, transparent information about how we collect and use your data — which this Privacy Policy provides.
• Right to withdraw consent: Where we rely on consent as the legal basis for processing (e.g. voice queries), you may withdraw consent at any time by disabling the relevant feature in-App or contacting us. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to opt out of data sale: We do not sell your personal data. If this changes, we will provide a clear opt-out mechanism and update this Policy.

7.2 Rights for EU / EEA / UK Residents (GDPR)

• Right of Access (Art. 15): Request a copy of your personal data and information about how it is processed.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
• Right to Erasure (Art. 17): Request deletion of your personal data where no overriding legal basis for retention exists.
• Right to Restriction (Art. 18): Request that we limit the processing of your personal data in certain circumstances.
• Right to Data Portability (Art. 20): Receive your personal data in a structured, machine-readable format (JSON or CSV) for transfer to another service.
• Right to Object (Art. 21): Object to processing based on legitimate interests or for direct marketing purposes.
• Right not to be subject to automated decisions (Art. 22): Request human review of any automated decision that significantly affects you.
• Right to lodge a complaint: Lodge a complaint with your local data protection supervisory authority. EU authority list: ec.europa.eu/justice/article-29/structure/data-protection-authorities. UK: ico.org.uk.

7.3 Rights for California Residents (CCPA/CPRA)

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected, the sources, purposes, and third-party recipients.
• Right to Delete: Request deletion of your personal information, subject to permitted exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: We do not sell or share your personal information for cross-context behavioural advertising. If this changes, we will provide an opt-out mechanism.
• Right to Limit Sensitive Personal Information: Limit our use of precise geolocation data to what is necessary to provide the App.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

7.4 Rights Under Other US State Privacy Laws

If you are a resident of Virginia, Colorado, Connecticut, Texas, Utah, Oregon, or another state with a comprehensive privacy law, you have rights substantially similar to those described in Section 7.2 and 7.3 above, including rights of access, correction, deletion, portability, and opt-out of targeted advertising, to the extent applicable under your state’s law.

7.5 How to Exercise Your Rights

To exercise any of the rights described above, including requesting access to or deletion of your personal data, please contact us at:

Email: developers@blacksnow.tv

Subject line: Privacy Rights Request — [Right Type, e.g. Data Access / Data Deletion / Data Portability]

We will verify your identity before processing your request, using information we already hold or by asking you to confirm details associated with your use of the App. We do not charge a fee for reasonable requests. We will respond within the timeframes required by applicable law — thirty (30) days for GDPR requests and forty-five (45) days for CCPA/CPRA requests, each extendable once with notice.

8. Cookies, Tracking Technologies, and Advertising

The App does not use browser cookies. The App may use limited device-based identifiers for the following purposes:

• App analytics: anonymised identifiers to count unique users and measure feature usage (not linked to your identity)
• Crash reporting: session identifiers to associate crash logs with a device for debugging purposes

We do not use advertising identifiers (IDFA on iOS or GAID on Android) for targeted advertising. We do not serve in-App advertising. We do not use third-party tracking SDKs for marketing purposes. We do not employ fingerprinting or other persistent cross-app tracking technologies.

You may limit device-based analytics collection by using the privacy controls available in your device’s operating system settings (iOS: Settings > Privacy & Security > Tracking; Android: Settings > Privacy > Ads).

9. Children’s Privacy

The App is not directed to children under the age of 13 and we do not knowingly collect personal information from children under 13. If you are a parent or legal guardian and believe that your child has provided us with personal information without your consent, please contact us immediately at developers@blacksnow.tv. If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will take prompt steps to delete that information from our systems.

For users aged 13 to 17, parental or legal guardian consent is required as described in our Terms of Service. We encourage parents and guardians to monitor their children’s use of the App.

10. Security

We implement commercially reasonable technical, administrative, and physical security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Encryption of all data transmitted between the App and our servers using TLS 1.2 or higher
• Encryption of sensitive personal data at rest using industry-standard encryption
• Role-based access controls limiting access to personal data to authorised personnel only
• Regular security assessments and vulnerability testing
• Contractual security obligations imposed on all third-party data processors
• Incident response procedures for detecting, containing, and notifying affected individuals of data breaches

No security measure is perfect or impenetrable. While we strive to protect your personal data, we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify you in accordance with the timeframes and requirements of applicable law, as described in Section 11 below.

11. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify the competent data protection supervisory authority within seventy-two (72) hours of becoming aware of the breach, where required by GDPR (Art. 33)
• Notify affected EU, EEA, and UK residents without undue delay where the breach is likely to result in a high risk to their rights and freedoms (GDPR Art. 34)
• Notify affected California residents without unreasonable delay and no later than forty-five (45) calendar days after discovery of a breach of unencrypted personal information, in accordance with California Civil Code § 1798.82
• Comply with all other applicable state and federal breach notification requirements

Breach notifications will describe: the nature of the breach; the categories of personal data involved; the approximate number of individuals affected; the likely consequences of the breach; and the measures we have taken or propose to take to address the breach and mitigate its effects. Notifications will be delivered by email, in-App notification, or other appropriate means.

12. Third-Party Services and Links

The App integrates third-party services including mapping providers, AI and LLM providers, and location databases. When you use features that interact with these services, your data is processed in accordance with those providers’ own privacy policies in addition to this Privacy Policy. We encourage you to review the privacy policies of all third-party services you interact with through the App.

We are not responsible for the privacy practices, content, or security of third-party services. The inclusion of a third-party service in the App does not constitute our endorsement of that service’s privacy practices.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the App’s functionality. When we make material changes, we will:

• Update the Effective Date at the top of this Policy
• Provide an in-App notification or other prominent notice of the change
• Where required by applicable law, obtain your consent before the change takes effect

We encourage you to review this Privacy Policy periodically. Your continued use of the App after the effective date of any changes constitutes your acceptance of the updated Privacy Policy, to the extent permitted by applicable law.

14. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us at:

Blacksnowgames Inc.

United States of America

Email: developers@blacksnow.tv

Subject line: Privacy Policy Inquiry  |  Data Request  |  GDPR Request  |  CCPA Request

We aim to respond to all privacy inquiries within ten (10) business days. If you are an EU, EEA, or UK resident and are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

© Blacksnowgames Inc.  ·  All rights reserved.

Navigate 360: AR Map Camera  ·  Privacy Policy  ·  Effective March 26, 2026

This Privacy Policy should be read together with our Terms of Service.