Privacy Policy for MojPas

Version 2.1 — Last Updated: September 10, 2026

Controller: MultiOne d.o.o., Republic of Croatia · privacy@mojpas.net

1. Introduction

MojPas (the "Application") is committed to protecting your privacy in compliance with Regulation (EU) 2016/679 (GDPR) and the Croatian Personal Data Protection Act. This Privacy Policy explains in plain language what personal data we collect, on what legal basis, how long we keep it, who we share it with, and how you can exercise your rights.

2. Data We Collect & Legal Basis

Data	Purpose	Legal basis (Art. 6)	Retention
Email, username, password hash	Account creation, login	Contract (b)	Until account deletion + 30 days
Profile avatar	Profile personalization	Contract (b)	Until account deletion or replacement
Pet profile (name, age, traits)	Service functionality	Contract (b)	Until account deletion
Walk GPS track (LineString)	Walk tracking, distance, map	Contract (b)	24 months, then pseudonymised to ~1 km grid
Background location	Continuous walk tracking	Consent (a)	Until revoked + 30 days
Safe Zones (coordinates & radius)	Safety alerts and geofencing	Contract (b)	Until deleted by user or account erasure
Community pin photos / GPS	Map sharing	Consent (a)	Until withdrawn
Chat messages	In-app messaging	Contract (b)	12 months, then hard-deleted
AI chat prompts & history	Dog-care assistant	Consent (a) — opt-in	Until revoked
Device push token (FCM)	Push notifications & group invites	Contract (b) / Consent (a)	Until logout or 90 days inactivity
Feedback messages & attachments	User support & issue reporting	Consent (a)	Until resolution / account erasure
Aggregated telemetry & sessions	Product analytics and stability	Legitimate interest (f) / Consent (a)	180 days, then hard-deleted

3. Background Location (Crucial Disclosure)

MojPas collects location data even when the app is closed (background).

Why: Continuous walk-route tracking during calls, screen-off, or app-switching.
What: Latitude, longitude, timestamp, speed.
Consent: Prominent disclosure screen before first activation; revocable anytime in OS settings.

4. Third Parties & International Transfers

We do not sell your data. We share only what is necessary to deliver the service:

Processor	Purpose	Data shared	Location	Safeguard
Google Gemini	AI chat assistant	Last 10 messages + new prompt	USA	EU-US DPF
Google Firebase (FCM)	Push notifications & group invites	Device token, notification title & body	USA	EU-US DPF + DPA
Google Places API	Location autocomplete	Search query + coordinates	USA	EU-US DPF
Postmark	Transactional email	Email, name	USA	EU-US DPF + DPA
Cloudflare R2	Photo / video storage	User-uploaded media	EU	DPA + SCC

Important: Photos you upload to community pins are currently stored in a bucket with publicly accessible URLs. Do not post photos containing faces, documents, license plates, or other identifying details unless you intend them to be public.

5. Your Rights (GDPR Art. 15–22)

Access (Art. 15) — Export all your data as a ZIP from Settings → Privacy.
Rectification (Art. 16) — Edit profile and pet data in-app.
Erasure (Art. 17) — Delete your account from Settings → Privacy. Hard-deleted within 30 days.
Restriction (Art. 18) — Email privacy@mojpas.net.
Portability (Art. 20) — JSON + GeoJSON in the export ZIP.
Object (Art. 21) — Opt out of analytics or AI processing at any time.
Withdraw consent (Art. 7(3)) — Toggle AI chat or background location off; effect immediate.
Complain to AZOP (Croatian Personal Data Protection Agency).

6. Security Measures (Art. 32)

Passwords hashed with Django's PBKDF2 / Argon2.
HTTPS-only in production; HSTS enabled.
Auth tokens for API; tokens are not logged.
All personal-data access recorded in a separate audit log with 12-month rotation.
Database backups encrypted at rest.

7. Automated Decision-Making (Art. 22)

The AI chat assistant (Gemini) provides information only. No automated decisions with legal or similarly significant effects are made about you.

8. Contact

MultiOne d.o.o. (controller)

Privacy requests: privacy@mojpas.net

General: multione@multione.hr

Supervisory authority: AZOP — azop.hr

This document is the legally binding Privacy Policy for the MojPas mobile application, version 2.1, effective 10 September 2026.