Privacy Policy

1. Who We Are

Touge Atlas ("we", "us", "our") is a mobile application that helps drivers discover touge roads, circuits, and car-related locations in Japan.

For the purposes of the EU General Data Protection Regulation ("GDPR"), we are the controller of the personal data processed through the app.

Data Controller: Chris Lamb
Email: [email protected]

2. What Data We Process

We designed Touge Atlas to minimize personal data collection. While the app requires sign-in to access full features, we collect only the minimum data needed to operate the service.

2.1 Account and Authentication Data

To use Touge Atlas, you sign in using Apple Sign In (on iOS) or Google Sign In (on Android). When you sign in, we receive and store the following data from your authentication provider:

• Your email address (as provided by Apple or Google).
• A unique user identifier (UUID) generated by our authentication system.
• Your authentication provider (Apple or Google).
• Sign-in timestamps (account creation date, last sign-in).

We do not receive or store:

• Your Apple or Google account password.
• Your contacts, photos, or other data from your Apple or Google account.
• Payment information (handled entirely by Apple or Google — see Section 2.9).

If you sign in with Apple and choose to hide your email, we receive only the private relay address that Apple generates. We have no way to discover your real email address.

Your account data is stored securely by our database provider (see Section 5.4). A session token is stored securely on your device and is used to authenticate API requests. This token is never shared with third parties.

2.2 Driving Records (Check-in Data)

When you use the Logbook feature to log a location visit, we store a check-in record in our database. Each record contains:

• Your user ID (UUID).
• The identifier of the location you checked in at (a text slug, not GPS coordinates).
• The timestamp of the check-in.

We do not store your GPS coordinates server-side. Location proximity is verified on your device only. However, because a check-in record links your account to a known location at a specific time, this constitutes location data linked to your identity.

If you turn on Auto-log, Touge Atlas can use location in the background to record nearby Logbook places. Auto-log is optional and off by default. Proximity is evaluated on your device; only the location identifier and check-in timestamp are stored and synced, not your GPS coordinates. You can turn Auto-log off at any time in Logbook.

Legal basis: Art. 6(1)(b) GDPR — performance of a contract. Driving records are the core function of the Logbook feature you have chosen to use.

2.3 Location Data

If you enable location access in the app and grant permission, we read your device's current location.

We generally use this on your device only, to:

• Calculate approximate distance to routes and points of interest.
• Sort or filter lists by distance.
• Center the map around your position and show a "you are here" indicator.

A few specific features do send your location to a third-party service, only as needed to perform that feature:

• Place search (searching for a stop by name): your location is rounded to about 1km and sent, together with your search text, to our Place search service.
• Category search (tapping a category icon such as convenience store, gas station, parking, restroom, roadside station, or food): your location is rounded to about 1km, and the area within a 10km radius of that point is sent to our Category search service.
• Route waypoint snapping, including waypoints from an imported GPX file: your exact, unrounded waypoint location is sent to our Route calculation service, because snapping to the correct road requires precision.

When you tap Navigate, the app opens Google Maps or Apple Maps. Google Maps is given your position as the starting point; Apple Maps is given only the destination. That app's own privacy policy applies from there.

Cruises are the only feature that sends your location to our own servers on an ongoing basis, and only if you turn that on (see Section 2.16). Outside of Cruise sharing, we do not:

• Store your location long-term.
• Use location for advertising, profiling, or cross-app tracking.

2.4 App Usage and Performance Data (Optional Analytics)

If you choose to enable analytics, we collect certain information about how you use the app, such as:

• Which screens you open (Map, List, Events, Settings, route detail pages).
• Search terms and filter types you apply (for example category, prefecture, vehicle type).
• Non-identifying performance metrics (for example loading times and Web Vitals such as LCP, INP, CLS).
• Technical information from your device (for example OS version, device model, app version, approximate region via IP).

We do not intentionally send to analytics:

• Your precise GPS coordinates.
• Driving behaviour (for example speed, exact path driven).
• Names, email addresses, or free-text user content.

2.5 Technical Data and Logs (Necessary)

When you use the app or our backend API, we necessarily process:

• Standard HTTP request data: IP address, user-agent, requested URL, timestamp.
• Route and filter parameters: for example limit, offset, category, prefecture.

This is used strictly to deliver content, keep our service secure and reliable, and apply simple rate limiting to prevent abuse.

2.6 Local Preferences on Your Device

We store certain preferences in your browser or WebView storage (for example localStorage) so the app behaves consistently between sessions:

• Interface language (English or Japanese).
• Distance unit (km or miles).
• Whether you have completed the onboarding tutorial (touge-onboarding-completed).
• Whether you have enabled location access inside the app (separate from OS permissions).
• The set of locations you have "favorited".
• Whether you have enabled analytics.
• Technical cache data for performance optimization (last API fetch timestamps, schema versions, cache timestamps).

This information is stored locally on your device only; we do not read or sync it to our own servers. The one exception is saved routes: with an Atlas Pass, routes you save can be synced to our servers so you can restore them on another device (see Section 2.17).

2.7 Session Storage (Temporary UI State)

We use browser session storage (which automatically clears when you close the browser/app) to preserve temporary UI state within a single session:

• Map view position and zoom level.
• Active filters and search terms (categories, course-only, road-only filters).
• List view scroll position and filter selections (search terms, prefecture filters).
• Events view state.

This data is automatically cleared when you close the app and is never sent to our servers. It is used solely to improve user experience by maintaining your view state during a single session.

2.8 Website Contact and Submissions (Optional)

If you use our website forms to submit a spot, photo, or business inquiry, we collect the information you provide, including:

• Contact details (name, email, company/website if provided).
• Submission content (location name, description, coordinates, links).
• Photos you upload and the license consent you grant.

This information is used to review submissions, update the map, and respond to you.

2.9 User Submissions (Photo Contributions, Location Suggestions)

When you submit content via the app (e.g. Contribute Photos or Suggest a Location) or via our website and provide your name, handle, or email for credit or contact, you voluntarily provide personal data. We process it only to attribute your content, to process your submission, and to reply if needed. We do not use it for marketing or share it with third parties.

You can ask us to remove your credit or delete this data at any time by contacting [email protected].

2.10 Push Notifications (Optional)

If you enable push notifications, we store a device token (push notification service token) in our database. This token is encrypted at rest (AES-256-GCM) before storage. We also store:

• Your user ID (UUID).
• The platform (iOS or Android).
• Your preferred language (for localized notifications).

Push tokens are used solely to deliver notifications you have opted into (for example, event reminders or parking area status updates). You can disable push notifications at any time in your device settings or by revoking notification permissions.

Legal basis: Art. 6(1)(a) GDPR — consent. You explicitly grant permission for push notifications through your device's notification dialog.

2.11 PA Live Community Reports

When you submit a parking area status report through PA Live, we store:

• Your user ID (UUID).
• The parking area identifier.
• The status you reported (for example, crowded, closed, or open).
• Optional enforcement scale, enforcement type, route, and direction details you choose to report.
• The timestamp of the report.

Reports are used to provide real-time crowd information to other users. We do not store your GPS coordinates with PA reports.

Each report is removed after its report-specific expiry and is also removed immediately when a successful account-deletion request completes.

Legal basis: Art. 6(1)(b) GDPR — performance of a contract (providing the community feature you chose to use).

2.12 Subscription Feedback (Cancel Survey)

If you initiate the subscription cancellation flow in the app, we may ask you to complete an optional exit survey. If you respond, we store:

• Your user ID (UUID).
• The reason you selected.
• Any optional free-text feedback you provide.
• Your subscription type and platform.

This data is used to improve the product. It is not shared with third parties.

When you delete your account, the link to your user ID is removed. The survey response remains as an anonymized product-feedback record.

Legal basis: Art. 6(1)(f) GDPR — legitimate interests (understanding why subscribers cancel, to improve the service).

2.13 Service Usage Metadata

To maintain service quality and detect inactive accounts for operational purposes, we record when authenticated users last interacted with the service. This includes:

• Your user ID (UUID).
• The date and time of your most recent authenticated request.
• A session count (how many times the app has been opened).
• Your platform (iOS, Android, or web).

This is not behavioral analytics. It does not track which screens you visit, what you search for, or how you use the app. It records only that you used the app, not what you did in it. This data is collected regardless of your analytics consent setting, as it is operational data necessary for service delivery.

Legal basis: Art. 6(1)(f) GDPR — legitimate interests (maintaining service health and managing inactive accounts).

2.14 Purchases and Subscriptions

Touge Atlas offers optional paid features: Atlas Pass (a subscription with monthly, annual, or lifetime options) and Trip Plans (one-time purchases). All payments are processed entirely by Apple (via the App Store) or Google (via Google Play). We never receive or store your payment card details, bank account information, or billing address.

To manage subscriptions and restore purchases across devices, we use our subscription management provider. They receive:

• An anonymous app user ID (linked to your account for purchase restoration).
• Purchase and subscription status (which products you own, subscription expiry dates).
• Platform (iOS or Android) and app version.

Our subscription management provider does not receive your email address, name, location, or any other personal information. Information about its safeguards is available on request.

2.15 Friends and Social Connections (Optional)

If you set a screen name and use the Friends feature, we store the minimum needed to connect you with other drivers:

• Your screen name, optional bio and social handles, avatar color, account user ID, and permanent member number.
• Your privacy choices, including invite-code discoverability, profile privacy, and Cruise roster visibility.
• Your friend connections and any pending friend requests.
• Invite codes you generate (and their expiry).
• Users you have blocked.
• Crews you create or join, including the crew name, owner, and membership records.
• Reports you submit about another user, which we store to enforce our community standards and keep the service safe.

We do not store profile photos. The avatar is a color value rather than an uploaded image. We do not share your friends list with third parties or advertisers. Other users can find or invite you only through the visibility and invite controls you choose.

You stay in control: you can remove friends, block a user, revoke an invite code, and change or clear your screen name at any time from within the app. Deleting your account (see Section 4) removes this data. For our policy on protecting minors and reporting abuse, see our Child Safety Standards.

2.16 Live Cruises (Real-Time Position Sharing)

When you start or join a Cruise (a convoy of drivers), you can turn on "Share my position". This is off by default. While it is on, and only then, the app sends your exact, unrounded real-time location (latitude, longitude, and heading) to our servers so the other members of that cruise can see you on the shared map.

• It stays off until you turn it on, and it stops when you turn it off, leave the cruise, or the cruise ends.
• Your position is shared only with the other members of that same cruise, never with anyone outside it.
• A limited position history is stored on our servers so the cruise can be replayed on a timeline. It is deleted automatically up to 30 days after the cruise ends or lapses, and it is deleted when you delete your account. You can also delete your own position history for a cruise at any time from the app.
• Outside an active cruise with position sharing turned on, your GPS coordinates are not sent to or stored on our servers. (Place search, category search, and route snapping send location to a different set of third-party services on a per-request basis, described in Section 2.3.)
• A Cruise also stores the text you type into it, including its name and the note on each stop. This text is checked automatically (see Section 2.18). The Cruises you created are deleted, with their text, when the Cruise is deleted and when you delete your account.

2.17 Saved Routes (Cloud Sync for Atlas Pass)

Routes you build and save are stored on your device. If you have an Atlas Pass, you can also sync your saved routes to our servers so you can restore them after reinstalling the app or on another device. Each synced route contains only the route you created (its name, the points it links, and your drawn path). It is deleted from our servers when you delete the route or delete your account.

2.18 Reports, Blocks and Moderation

When you report another user or their content, or block someone, we store what we need to act on it and to stop it happening again.

• A report: your user ID, the ID of the drive it was filed in, what was reported (a drive name, a member, or a stop note), the reported user's ID, an optional reason you type, the status, the time, and an internal score we use to weigh the report. The reported wording itself is not copied into the report record.
• A screen name report: your user ID, the reported user's ID, an optional reason, and the status.
• A block: the user IDs of both sides and the time.
• A suspension (ban): the user ID, who issued it, the reason, and when it was lifted.

Separately from reports, text you type into a Cruise (see Section 2.16), such as its name or a stop note, is checked automatically for prohibited content when it is saved. If the check flags it, the save is refused, or the text is hidden from the other members without a person reviewing it first. We do this to prevent abuse of the service (APPI, and GDPR Article 6(1)(f)).

When a report is filed, a notification is sent to a private moderation channel we run on a third-party messaging service, and the operator (the business named in Section 1) reviews it. The notification contains the drive and the field reported, the member numbers of both sides, your user ID, the reported user's ID when the report is about a member, the internal score we use to weigh the report, and a link to the operator's review view.

The same channel also receives a notification when content is hidden by the automatic check. It identifies the Cruise, the field, and the type of content the check flagged, and carries no user ID. The flagged text itself is not sent. A person reviews a hide when you ask us to, as set out at the end of this section.

If an unusual cluster of reports is detected in a short space of time, a further notification goes to the same channel, and it names up to five of the user IDs involved in that cluster. Apart from these notifications, we do not pass report data to anyone else. We never sell it, and we never use it for advertising.

How long we keep it: reports you filed are deleted along with the report record when you delete your account. If a report named you as its target, the report record stays but the link to you (the target user ID) is deleted. A block is kept until it is undone, or until either side deletes their account. Suspension records have no automatic deletion date at present. Saving different text that passes the check replaces the hidden text: the other members then see the new text, not the hidden wording. There is no automatic expiry: unless it is replaced, or lifted after you contact us, it stays hidden for as long as the Cruise exists, and it is deleted when the Cruise is deleted.

These report, block and suspension records may survive the deletion of your account. We keep them only so far as we need them to prevent abuse (APPI, and GDPR Article 6(1)(f)) and to establish or defend legal claims (GDPR Article 17(3)(e)).

If you disagree with a report, a hidden item, a refused save, or a suspension, contact [email protected]. The operator will review it and lift a hide or a suspension where that is the right outcome.

3. Purposes and Legal Bases

Under GDPR we must have a lawful basis for each purpose of processing. The following bases refer to Article 6 GDPR.

3.1 Providing the App and Core Features (Contract / Legitimate Interests)

Purpose:

• Serve maps, lists of routes and events.
• Apply search, filters, and sorting.
• Load our static datasets and call our Touge Atlas API.

Data involved: technical data (IP, user-agent, request parameters), local UI preferences.

Legal basis: Art. 6(1)(b) — performance of a contract (providing the app you choose to use) and Art. 6(1)(f) — legitimate interests (operating and securing the service). These operations are strictly necessary to provide the service you request.

3.2 User Account and Authentication (Contract)

Purpose:

• Authenticate you and maintain your session across the app.
• Restore your purchases and subscription status across devices.
• Deliver authenticated API responses and protected content.

Data involved: email address, user ID, authentication provider, session tokens, sign-in timestamps.

Legal basis: Art. 6(1)(b) — performance of a contract (providing the service you signed up for). Account creation is necessary to deliver the app's core functionality and to manage purchases.

3.3 Purchases and Subscription Management (Contract)

Purpose:

• Verify your purchase and subscription status.
• Unlock premium features (Atlas Pass, Trip Plans).
• Enable purchase restoration across devices.

Data involved: anonymous app user ID, purchase records, subscription status.

Legal basis: Art. 6(1)(b) — performance of a contract (fulfilling your purchase).

3.4 Optional Geolocation for Distances, Search, and Route Snapping (Consent)

Purpose:

• Show distances to locations from your current position.
• Sort and filter lists by distance.
• Center the map around your approximate location.
• Resolve a place-name or category search, and snap route or GPX waypoints to real roads (see Section 2.3).

Data involved: your current location, processed on-device for distance calculation and map centering. A coordinate rounded to about 1km is sent to our place-search and category-search providers; your exact waypoint position is sent to our route-snapping provider.

Legal basis: Art. 6(1)(a) — consent. You grant or deny permission through your system or browser location dialog, and you can also turn location on or off in the app Settings.

3.5 Optional Usage and Performance Analytics (Consent)

Purpose:

• Understand which screens and filters are used, to prioritise improvements.
• Measure performance and reliability (for example loading speed, layout stability).

Data involved: screen views, searches, filters, performance metrics, and technical identifiers from our analytics service.

Legal basis: under the ePrivacy Directive (Article 5(3)), analytics SDKs such as our analytics service are considered "cookies or similar technologies" that are not strictly necessary and therefore require prior consent. Under GDPR we rely on Art. 6(1)(a) — your consent before enabling analytics.

Analytics are disabled by default. You can enable or disable Analytics & Performance in the app Settings or via the optional choice on the final onboarding step. No analytics events are sent unless and until you opt in, and you can withdraw consent at any time.

3.6 Security and Anti-Abuse (Legitimate Interests / Legal Obligations)

Purpose:

• Protect our service from abuse and attacks.
• Monitor API health and error rates.

Data involved: limited logs from our API (IP address, timestamps, error messages/traces) and the text you type into a Cruise (a Cruise name and stop notes), as described in Section 2.18.

Legal basis: Art. 6(1)(f) — legitimate interests and, where applicable, Art. 6(1)(c) — legal obligations (for example responding to lawful requests).

3.7 Handling Submissions and Inquiries (Consent / Legitimate Interests)

Purpose:

• Review user-submitted locations and photos.
• Update our database and showcase approved content in the app.
• Respond to business inquiries.

Data involved: contact details, submission content, and uploaded photos.

Legal basis: Art. 6(1)(a) — consent (for your submission and photo license) and Art. 6(1)(f) — legitimate interests (running and improving the service).

3.8 Website Analytics (Legitimate Interests)

Purpose:

• Understand which pages on our website (tougeatlas.com) are viewed and where visitors come from.
• Improve the website's content and performance.

Data involved: aggregated, cookieless technical information such as the page path, referrer, and general country or device type. This analytics service does not use cookies, does not access or store any information on your device, and does not track you across other websites.

Legal basis: Art. 6(1)(f) — legitimate interests (understanding and improving website usage). Because this analytics service does not store or access information on your device, the consent requirement under Article 5(3) of the ePrivacy Directive does not apply.

4. Data Storage Locations

Your data is stored in the following locations:

• On your device: Preferences, favorites, cache data, and your authentication session token are stored locally on your device.
• Database provider: Your account data (email, user ID, auth provider, sign-in timestamps) is stored by our database provider (servers in Tokyo, Japan). See Section 5.4.
• Subscription management: Your anonymous app user ID and purchase/subscription status are stored by our subscription management provider. See Section 5.5.
• Infrastructure/CDN (API and submissions): Technical API logs and any submissions you make (photos, location suggestions) are stored in our infrastructure provider's systems.

Except for real-time position sharing during a Cruise when you turn it on (see Section 2.16), we do not store your GPS coordinates or driving behavior on our servers. Place search, category search, and route or GPX waypoint snapping send your location to third-party services on a per-request basis for processing, not storage (see Section 2.3). Your favorites and app preferences remain on your device only.

5. How and Where Your Data is Processed

5.1 Backend API (Infrastructure Provider)

Our API is hosted on our infrastructure provider and accessed over HTTPS. Requests include non-personal parameters (limits, categories, prefectures) and standard HTTP metadata (IP address, user-agent). Our infrastructure provider acts as our processor and CDN provider and may process limited traffic data for security and performance in line with its own privacy policy.

5.2 Weather Data

When you view weather information for a location, the app requests weather data via our API from our weather-data provider. The provider receives the latitude and longitude of the location you are viewing (not your personal location) and standard HTTP request metadata. Information about its safeguards is available on request.

5.3 Analytics Service (Only if You Opt In)

If you enable analytics, we send usage events to our analytics service. Our analytics service processes app usage data and certain device identifiers as an independent or joint controller under their terms and privacy policy.

Data may be stored on servers outside the EEA (for example in the United States). We rely on our analytics provider's use of Standard Contractual Clauses and other safeguards as provided in their data protection terms.

5.4 Database Provider (Authentication and Database)

We use our database provider to manage user authentication and as our backend database. Our database provider stores your account data (email, user ID, auth provider, timestamps) and acts as our data processor under GDPR.

Our database provider's servers for this project are located in Tokyo, Japan. Information about its safeguards is available on request.

5.5 Subscription Management Provider

We use our subscription management provider to manage in-app purchases and subscriptions. They receive an anonymous app user ID and purchase transaction data from Apple or Google to verify and manage your subscription status. Our subscription management provider acts as our data processor under GDPR. Data may be stored in the United States.

Information about its safeguards is available on request.

5.6 Local Storage on Your Device

Preferences, favorites, and cache data are stored locally on your device. Persistent data (preferences, favorites) remains until you clear app data or uninstall. Temporary data (map position, filters) clears automatically when you close the app.

Deleting the app or clearing your app data removes all locally stored entries.

5.7 Location Search and Routing Services

Place search, category search, and route or GPX waypoint snapping are each handled by a separate third-party service, described in Section 2.3. Place search and Category search each receive your location rounded to about 1km. Route calculation receives your exact, unrounded waypoint position, because snapping to the correct road requires it. The same service also supplies our map tiles (see Section 10). None of these providers receive your name, email, or account identifiers.

5.8 Automated Content Checking

Text you type into a Cruise is checked automatically when it is saved, as described in Section 2.18. The check is carried out by our infrastructure provider as our processor, under the same terms described in Section 5.1.

5.9 Account Deletion Confirmation

After a successful account deletion, our transactional account email service receives the verified email address from your deleted authentication record solely to send the deletion confirmation. No confirmation is sent if that service is unavailable or not configured; this does not undo the deletion.

6. Data Retention

• Account data (email, user ID, auth provider) is retained for as long as your account exists. A successful in-app account-deletion request deletes the authentication record immediately.
• Driving records (check-in history) are stored for as long as your account exists. They are deleted as part of the successful account-deletion request.
• Push notification tokens are stored (encrypted) for as long as your account exists or until you disable notifications. They are deleted when you delete your account.
• PA Live reports are stored only until their report-specific expiry. A scheduled cleanup removes expired reports, and account deletion removes the user's reports immediately.
• Cancel survey responses are retained indefinitely in anonymized aggregate form for product improvement. The association with your user ID is deleted when you delete your account.
• Service usage metadata (last active date, session count) is stored for as long as your account exists. It is deleted when you delete your account.
• Purchase and subscription data is retained by our subscription management provider for as long as your account exists, and by Apple/Google as part of your purchase history with them.
• Cruise text (a Cruise name and stop notes) is stored for as long as the Cruise exists. The Cruises you created are deleted, with their text, when the Cruise is deleted and when you delete your account.
• Local preferences (language, units, favorites, location/analytics toggles, cache data) remain on your device until you clear app data or uninstall.
• Session storage (map position, filters, search terms) is automatically cleared when you close the app.
• Backend logs (API access logs, error logs) are kept for a maximum of 72 hours for security and troubleshooting, after which they are deleted or irreversibly anonymised.
• Analytics data retained by our analytics service is subject to retention settings in our analytics project and to our analytics provider's own policies. We configure retention to the shortest period consistent with meaningful aggregate statistics (typically 14 months).

7. Your Rights

If you are in the EU/EEA, UK or Switzerland, you have the following rights under data protection law, subject to conditions and exceptions:

• Right of access (Art. 15 GDPR) — ask us to confirm whether we process your personal data and receive a copy.
• Right to rectification (Art. 16 GDPR) — ask us to correct inaccurate or incomplete data.
• Right to erasure (Art. 17 GDPR) — ask us to delete your personal data where there is no longer a lawful basis to keep it.
• Right to restriction (Art. 18 GDPR) — ask us to restrict processing in certain circumstances.
• Right to data portability (Art. 20 GDPR) — where processing is based on consent or contract and carried out by automated means, request a copy of your data in a structured, commonly used, machine-readable format.
• Right to object (Art. 21 GDPR) — object to processing based on our legitimate interests.
• Right to withdraw consent (Art. 7(3) GDPR) — where we process data based on your consent (location, analytics), withdraw that consent at any time.

Withdrawing consent does not affect the lawfulness of processing that took place before withdrawal. To exercise your rights, contact us at [email protected]. We may need to reasonably verify your identity before responding.

You also have the right to lodge a complaint with your local data protection authority (for example, in the EU the supervisory authority of your habitual residence or place of work). A list of EU supervisory authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en.

Japan APPI Rights

Under Japan's Act on the Protection of Personal Information (APPI), all users whose data is handled by Touge Atlas have the following rights:

• Right to disclosure (Art. 33): Request disclosure of your retained personal data. We will respond without delay.
• Right to correction (Art. 34): Request correction, addition, or deletion of inaccurate personal data.
• Right to cessation of use (Art. 35): Request that we stop using or erase your personal data if it was processed beyond the stated purpose or obtained improperly.
• Right to cessation of third-party provision (Art. 35): Request that we stop providing your personal data to third parties.
• Right to receive data electronically (Art. 33(2)): Request a copy of your personal data in electronic format.

To exercise any of these rights, contact us at [email protected]. We will respond without undue delay.

Obligation to Provide Data

Creating an account (via Apple Sign In or Google Sign In) is required to use the app. Without an account, you cannot access the app's features. This is a contractual requirement, not a statutory one.

8. Children's Data

Touge Atlas is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can delete it.

9. International Data Transfers

Where data is transferred outside the EEA, the UK or Switzerland (for example, by our analytics service, our infrastructure provider, our database provider, or our subscription management provider), we rely on appropriate safeguards under GDPR, such as Standard Contractual Clauses (Art. 46 GDPR), or transfers to countries for which the European Commission has issued an adequacy decision (including Japan, which has an adequacy decision from the European Commission). Further details are available in the respective provider's data protection documentation, and we can provide more information upon request.

Cross-Border Transfer Details (APPI Art. 28)

Under Japan's APPI, the following countries receive personal data from Touge Atlas:

• Japan: Our database provider (database hosting, Tokyo region). Domestic processing, no cross-border transfer.
• United States: Our infrastructure/CDN provider (CDN, API proxy), our subscription management provider, our analytics service (opt-in analytics), the moderation notification service described in Section 2.18, and our transactional account email service. The United States does not have a personal data protection system recognized by Japan's Personal Information Protection Commission (PPC) as equivalent to APPI. We ensure these providers maintain organizational and contractual safeguards that meet APPI standards, including encryption of data in transit and at rest, access controls, and data processing agreements.

Japan and the EU have mutual adequacy recognition. For transfers from the EU to Japan, Japan's supplementary rules under the adequacy framework apply.

10. External Transmission of User Information

In accordance with Article 27-12 of Japan's Telecommunications Business Act, we disclose the following information about data transmitted to third parties when you use the Touge Atlas app or website.

Every recipient above receives your IP address as a property of the request itself. Anything beyond that is limited to what each purpose needs.

Weather data, the automated check on Cruise text, moderation notifications, and account deletion confirmation emails are sent from our servers, not from your device. Those are covered by the service providers listed in Section 5.

Information about safeguards for our processors is available on request. The recipient names for direct external transmissions are listed above.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest.
• Secure hosting infrastructure.
• Secure token storage on device.
• Token-based authentication with expiry and refresh.
• Regular security assessments and updates.
• Limited access controls to personal data.

12. Data Breach Notification

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority without undue delay, in accordance with Art. 33-34 GDPR.

Where Japan's APPI applies, we also report the incident to the Personal Information Protection Commission and notify the affected users, within the periods the law sets. We take the steps needed to establish what happened and to prevent a recurrence, and we tell the affected users what we find. If you have questions, contact us using the details in Section 16.

13. Automated Decision-Making

We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

One automated process we do run, which does not produce legal or similarly significant effects, is the check on Cruise text described in Section 2.18. If that check refuses a save, or hides your text from other members, contact us at [email protected] and the operator will review it.

14. How to Delete Your Data or Stop Processing

Delete Your Account

You can delete your account at any time by going to Settings > Account > Delete Account in the app. A successful request immediately deletes or anonymizes the following account-linked data:

• Your authentication record (email, user ID, sign-in history) from our database provider.
• Your driving records (check-in history, locations visited and timestamps) from our database provider.
• Your push notification tokens from our database provider.
• Your PA Live reports and PA subscriptions from our database provider.
• The user-ID link on your cancel survey responses; the responses remain as anonymized product-feedback records.
• Your service usage metadata (last active date, session count) from our database provider.
• The Cruises you created, including their names and stop notes, from our database provider.
• Community-photo credit text linked to your account; the public photo and its internal submitter reference remain.

We send a confirmation email after the in-app deletion succeeds. Moderation and suspension records, trial or promo redemption records, public submitted photos and their internal submitter references, store purchase history, and provider-held subscription records may remain for the purposes and periods described in this policy. Active subscriptions should be cancelled through the App Store or Google Play before deleting your account, as account deletion does not cancel a store subscription or issue a refund.

Delete Local Data

Preferences, favorites, and cached data are stored only on your device. To delete this data:

• Uninstall the app from your device; or
• Clear app data in your device settings.

Withdraw Consent for Analytics

Turn off Analytics & Performance in the app Settings. This stops future analytics events. If you ask us to delete data and we can reasonably identify data relating to your device in a third-party service, we will delete or anonymise it to the extent technically possible.

Request Data Export

You can request a copy of all personal data we hold about you by contacting [email protected]. We will provide your data in a structured, machine-readable format within 30 days.

For more information, see our Data Deletion Request page.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date below and, where appropriate, show a notice in the app. Please review this policy periodically.

16. Contact

If you have questions about this policy or how we handle your data, or if you want to exercise your rights, you can contact:

Data Controller: Chris Lamb
Email: [email protected]