European Data Act
Data Handling Overview
1. Hardware Products (Smartwatches & Smartphones)
| Data Collected | Location, steps, device status (battery, connectivity), messages/calls metadata (not content), guardian settings, phone number, nickname of the phone contact. |
|---|---|
| Format | Structured digital data (JSON/CSV via APIs; encrypted in transit and at rest) |
| Estimated volume of product data | 1–5 MB per device per day (depending on use). The device collects the data every 5 mins or as required from the guardian app by parents. |
| Continuous/real-time capability | The device can support near real-time capability if the guardian app requires real-time location update. |
| Data storage on-device or on a remote server | Minimal temporary storage on-device; primary storage and processing on secure remote servers (EU-based). |
| Duration of retention | Location data is automatically and permanently deleted after 72 hours. We retain deactivated account data for 45 days. |
| How to access, retrieve or erase the data? | Users can access and view data through the guardian app (Xplora App). Data export available in machine-readable formats. Data can be deleted in-app or by contacting Xplora customer support. |
2. Xplora App
| Service Data (Application Data) | User ID, password (encrypted), guardian & registered contacts phone numbers, and steps |
|---|---|
| Estimated volume of service data | Less than 1MB per user |
| How to access and retrieve service data | Guardian can see the data via the guardian app |
| Where service data is stored | Primary storage and processing on secure remote servers (EU-based) |
| Duration of retention | Location data is automatically and permanently deleted after 72 hours. We retain deactivated account data for 45 days. |
| Use of data by Xplora | Used for providing services, improving app stability, and ensuring safety features. |
| Third-party use of data | Only with explicit user consent. |
| Data holder | Xplora Technologies AS |
| Address | Nedre Slottsgate 8, 0157 Oslo, Norway |
| Other data processing parties | Infomark Co Ltd, 360 Kids Guard Co., Ltd., Amazon Web Services, ATENDER AS, Zendesk Inc. |
| Contact | https://support.xplora.com/hc/en-gb |
| Sharing with third parties | Users can authorise sharing via app settings or customer support. Sharing can be stopped at any time. |
| Complaints | Users may lodge complaints to their local supervisory authority under Article 37 of the Data Act. |
| Trade secrets | Data does not include Xplora trade secrets. |
| Contract duration and termination | App use is ongoing while device/account is active. Users can request Xplora to delete their account at any time; data is deleted within 30 days after the request. |
3. Parental Guardian App
| Service Data | User ID, password (encrypted), guardian & registered contacts phone numbers, and steps |
|---|---|
| Estimated volume of service data | Less than 1MB per user |
| How to access and retrieve service data | Guardian can see the data via the guardian app |
| Where service data is stored | Primary storage and processing on secure remote servers (EU-based) |
| Duration of retention | 12 months active, archived up to 36 months, then deleted. Location data is automatically and permanently deleted after 72 hours. |
| Use of data by Xplora | Used for providing services, improving app stability, and ensuring safety features. |
| Third-party use of data | Only with explicit user consent. |
| Data holder | Xplora Technologies AS |
| Address | Nedre Slottsgate 8, 0157 Oslo, Norway |
| Other data processing parties | Not specified |
| Contact | https://support.xplora.com/hc/en-gb |
| Sharing with third parties | Users can authorise sharing via app settings or customer support. Sharing can be stopped at any time. |
| Complaints | Users may lodge complaints to their local supervisory authority under Article 37 of the Data Act. |
| Trade secrets | Data does not include Xplora trade secrets. |
| Contract duration and termination | App use is ongoing while device/account is active. Users can delete their account at any time; data deleted within 30 days of termination. |
4. Xplora GoPlay Platform
| Service data collected | User ID, password (encrypted), type of device, device nick name, steps |
|---|---|
| Estimated volume of service data | Less than 1MB per user |
| How to access and retrieve service data | Guardian can see the data from the Goplay web site such as type of device, device nick name, steps, and data usages |
| Where service data is stored | Primary storage and processing on secure remote servers (EU-based) |
| Duration of retention | Location data is automatically and permanently deleted after 72 hours. We retain deactivated account data for 45 days. |
| Data used by Xplora | Via the app’s data settings. Support team can assist if needed. Export available on request. |
| Use data for own purposes | Used for providing services, improving app stability, and ensuring safety features. |
| Third party use for agreed purpose | Third-party use only with explicit user consent. |
| Data holder | Xplora Technologies AS |
| Address | Nedre Slottsgate 8, 0157 Oslo, Norway |
| Contact | https://support.xplora.com/hc/en-gb |
| Sharing with third parties | Users can authorise sharing via app settings or customer support. Sharing can be stopped at any time through the same channels. |
| Complaints | Users may lodge complaints to their local supervisory authority under Article 37 of the Data Act. |
| Trade secrets | Data does not include Xplora trade secrets. |
| Contract duration and termination | App use is ongoing while device/account is active. Users can delete their account at any time; data deleted within 30 days of termination. |
5. Mobile Subscription
| Service data collected | Outgoing call-logs (which number is called, when the call was made and which country the user was in when the call was made), data usage (only date and not data via Wi-Fi), SMS log (which number sent to and when), User data: Name, Address, Phonenumber, Email, Date of Birth, SIM-card number, PIN code (only the original one), PUK code, Previous network operator |
|---|---|
| Estimated volume of service data | 5–20MB |
| How to access and retrieve service data | Data can be accessed through customers on MyPage and Customer Support. |
| Where service data is stored | Primary storage and processing on secure remote servers (EU-based and in Norway). |
| Duration of retention | We retain deactivated account data for 45 days. Specified traffic data is stored for 6 months. |
| Use data for own purposes | Used for billing and services. |
| Third party use for agreed purpose | Telavox supplies the CRM systems and collects the traffic data from Network Providers. |
| Data holder | Xplora Technologies AS |
| Address | Nedre Slottsgate 8, 0157 Oslo, Norway |
| Other data processing parties | Telavox |
| Contact | https://support.xplora.com/hc/en-gb |
| Complaints | Users may lodge complaints to their local supervisory authority under Article 37 of the Data Act. |
| Trade secrets | Data does not include Xplora trade secrets. |
| Contract duration and termination | Monthly rolling plan and up to 24 months subscription commitment period. |
