App Privacy policy
Last updated: 2026-06-22
Version: 1.1
This Privacy Policy explains how GreatGuide BV (“we”, “us”, or “our”) processes personal data when you use the mobile application (the “App”).
We publish the App on the Apple App Store and Google Play. This policy is designed to meet the privacy disclosure requirements of those platforms and the EU General Data Protection Regulation (GDPR), where it applies.
If you do not agree with this policy, please do not use the App.
1. Who is responsible for your data?
| Role | Details |
|---|---|
| Data controller | GreatGuide BV, Hulswitweg 77, 2031 BG Haarlem, Netherlands |
| Contact (privacy) | privacy@greatguidemagic.com |
| Website | www.greatguidemagic.com |
| App support | info@greatguidemagic.com |
Technology provider. The App is built on the Great Guide tour-guide platform. GreatGuide BV (https://www.greatguidemagic.com) hosts the backend services that deliver map content, live vehicle positions, operational messages, and optional features such as the AI travel assistant. Global Guide Systems acts as a data processor on our instructions for data sent to those services.
We have not appointed a Data Protection Officer. For privacy questions, contact privacy@greatguidemagic.com.
2. Scope
This policy applies to personal data processed through:
- the App on iOS and Android;
- our tour-guide backend at
tracker.globalguidesystems.com; and - integrated third-party services described below.
The App is intended for visitors and tourists. We do not require you to create an account to use the core features.
3. Summary — what the App does with data
| Data | Collected? | Stored on device? | Sent off device? | Main purpose |
|---|---|---|---|---|
| Precise location (GPS) | Yes, if you grant permission | Yes, while in use | Only when you use certain features (see §4.2) | Map, nearest stops, walking tours, directions |
| Approximate location | Derived from GPS | Same as above | Same as above | Same as above |
| AI assistant questions | Only if you use AI chat | During the chat session | Yes, to our backend | Answer travel questions in context |
| Push notification token | Only if push is enabled and you allow notifications | Yes | Yes, via Google Firebase | Deliver operational messages |
| App preferences (language, city, theme) | Yes | Yes, on device | No | Remember your settings |
| Offline map cache | Yes, after content is loaded | Yes, on device | No | Use the map without connectivity |
| Ticket / social / weather links | Only if you open them | Browser/WebView cache may apply | Yes, to the third-party site | Booking and external content |
We do not sell your personal data. We do not use the App for behavioural advertising. The App does not include third-party advertising or analytics SDKs (such as Firebase Analytics).
4. Personal data we process
4.1 Data you do not need to provide directly
The App does not ask for your name, email address, or phone number to use standard features.
4.2 Location data
When we access location
- On first launch, the App may ask for permission to access your location while you are using the App.
- If walking audio tours are enabled for your edition of the App, the App may later ask for “always” / background location permission when you start a walking route, so audio triggers can work while your screen is off or you use other apps.
- You can refuse or revoke location permission in your device settings. Some features (map centreing on your position, nearest stops, walking directions, walking-tour audio, and the AI assistant) will then be limited or unavailable.
How location is used on your device
- Showing your position on the map.
- Finding nearby stops and points of interest.
- Triggering walking-tour audio near route points.
- Calculating walking directions when that feature is available.
When location is sent off your device
Location coordinates are transmitted only in these situations:
- AI travel assistant (if available): when you send a question, the App sends your question, approximate coordinates, language, an anonymous city access token, and optionally a nearby stop identifier to
tracker.globalguidesystems.comso the assistant can answer in context. A conversation identifier may be returned and reused for follow-up questions in the same session. - Walking directions (if configured for your App): when you request directions to a stop or place, your origin coordinates and destination are sent to Google Maps Directions API to calculate a route.
For all other map features, location is processed locally on your device and is not transmitted to us for tracking your movements over time.
Legal basis (GDPR): consent (Article 6(1)(a)), given through your device’s location permission and, where applicable, your choice to start a walking tour or use the AI assistant. For strictly necessary processing to deliver a feature you request (e.g. directions), we may also rely on performance of a service you request (Article 6(1)(b)).
4.3 Push notifications (optional)
If push notifications are enabled for your edition of the App:
- The App uses Google Firebase Cloud Messaging (FCM).
- When you allow notifications, FCM assigns a device token to your installation. The App subscribes that installation to a topic related to the App edition and, where applicable, your selected city and language (for example
tracker-messages-[client]-[city]-[language]). - We use this only to deliver operational messages (service updates, disruptions, or similar information). We do not use push for marketing unless we clearly tell you otherwise in the message and you have a separate legal basis to receive it.
- You can disable notifications at any time in your device settings.
Legal basis: consent (Article 6(1)(a)).
4.4 App settings and local storage
The App stores the following on your device using local storage (SharedPreferences / app storage):
- selected language and city;
- light/dark theme preference;
- whether permission prompts were already shown;
- walking-tour progress and access codes you enter;
- which operational messages you have read or dismissed;
- a cached copy of map content (routes, stops, places, categories, messages) for offline use;
- the last FCM topic subscribed to (if push is enabled).
This data stays on your device unless you uninstall the App or clear app data.
Legal basis: legitimate interests (Article 6(1)(f)) in providing a stable, personalised experience, or consent where required by platform rules.
4.5 Content loaded from our servers
When the App is online, it downloads public tourism content from our backend using an anonymous city token embedded in the App configuration (not linked to you personally): routes, stops, vehicle positions, points of interest, categories, messages, and media URLs.
Standard web server logs at our hosting provider may include your IP address, request time, and user-agent string.
Legal basis: legitimate interests (Article 6(1)(f)) in operating and securing the service.
4.6 Ticket booking and external links
The App may open ticket booking pages, social networks, or weather sites:
- in your system browser, or
- inside an in-app browser (WebView) when configured.
Those third parties process data under their own privacy policies. We do not control their processing. Common providers include ticketing partners (e.g. FareHarbor or your operator’s website) and social networks you choose to open.
4.7 Map tiles and imagery
The App displays maps using MapLibre and map tile services configured for your edition. Loading tiles sends technical data (such as IP address, tile coordinates, and device information) to the tile provider. Cached tiles may be stored on your device.
4.8 Support enquiries
If you contact us by email or through a support URL, we process the information you provide (such as your email address and message content) to handle your request.
Legal basis: legitimate interests (Article 6(1)(f)) or steps prior to a contract (Article 6(1)(b)).
5. Automated processing and the AI assistant
If your App includes the AI travel assistant, your questions are processed automatically to generate replies. This is not used to make legal or similarly significant decisions about you. Replies are informational only and may be inaccurate; you should verify important information independently.
You are not required to use the AI assistant.
6. Who we share data with
We share personal data only as needed to operate the App:
| Recipient | Role | Data shared | Location |
|---|---|---|---|
| Global Guide Systems BV | Processor — tour-guide platform | AI questions, coordinates, language, city token; server logs | EU / as contracted |
| Google LLC (Firebase Cloud Messaging) | Processor — push delivery | Device token, topic subscription metadata | USA / global infrastructure |
| Google LLC (Maps Directions API) | Processor — routing | Origin/destination coordinates when you request directions | USA / global infrastructure |
| Map tile provider(s) | Processor — map display | IP address, tile requests | Depends on provider |
| Apple Inc. / Google LLC | Platform providers | As part of normal app distribution and OS services | Per their policies |
| Ticketing / social / weather sites | Independent controllers | Data you submit when you visit them | Per their policies |
We may also disclose data if required by law or to protect rights, safety, and security.
We do not sell personal data.
7. International transfers
Some processors (notably Google) may process data outside the European Economic Area (EEA), including the United States.
Where GDPR requires it, we ensure appropriate safeguards such as the EU Standard Contractual Clauses and supplementary measures. You may request more information about transfers by contacting privacy@greatguidemagic.com.
8. How long we keep data
| Data | Retention |
|---|---|
| Location on device | Until you stop the feature, revoke permission, or uninstall |
| AI assistant requests on servers | e.g. up to 90 days for support and abuse prevention, unless law requires longer |
| Server access logs | up to 90 days |
| FCM / push topics | Until you unsubscribe, disable notifications, or uninstall |
| Local app preferences & offline cache | Until you clear app data or uninstall |
| Support emails | up to 24 months after the case is closed |
When retention ends, we delete or anonymise data unless we must keep it for legal obligations.
9. Security
We use appropriate technical and organisational measures, including encrypted transport (HTTPS/TLS), access controls, and processor agreements. No method of transmission or storage is 100% secure.
10. Your rights under GDPR
If GDPR applies to you, you have the right to:
- Access — obtain confirmation and a copy of your personal data;
- Rectification — correct inaccurate data;
- Erasure — request deletion in certain circumstances;
- Restriction — limit processing in certain circumstances;
- Data portability — receive data you provided in a structured, machine-readable format where applicable;
- Object — object to processing based on legitimate interests;
- Withdraw consent — at any time, without affecting prior lawful processing (e.g. disable location or notifications in device settings);
- Lodge a complaint with a supervisory authority — in the EU, typically in your country of residence, work, or where the alleged infringement occurred.
To exercise your rights, email privacy@greatguidemagic.com. We may need to verify your request. We respond within one month, extendable where permitted by law.
Because most App data is stored on your device or processed with anonymous tokens, we may not be able to identify you from backend logs alone. Uninstalling the App and clearing app data removes locally stored information.
11. Children
The App is a general-audience tourism app and is not directed at children under 16 (or the age defined by local law). We do not knowingly collect personal data from children. If you believe a child has provided personal data, contact privacy@greatguidemagic.com and we will take appropriate steps.
12. Changes to this policy
We may update this policy to reflect legal, technical, or business changes. We will post the new version at www.greatguidemagic.com/privacy-app/ and update the “Last updated” date. For material changes, we may also notify you in the App or through other appropriate channels where required by law.
13. Platform-specific notes
Apple App Store
- Location: collected for app functionality (map, walking tours, directions, AI context) — not used for tracking across apps or websites for advertising.
- Push notifications: used for operational messages if enabled.
- Data linked to you: limited; the App does not require an account. Location and AI questions are tied to your use session. FCM token is tied to your device installation.
- Data not used for tracking (as defined by Apple) for advertising purposes.
Google Play
- Data safety alignment: Location (precise), app activity (in-app actions such as AI questions), device or other IDs (FCM token), and app info/performance (crash logs only if added in future) should be declared in Play Console consistent with this policy.
- Encryption in transit: Yes (HTTPS).
- Deletion request: Contact privacy@greatguidemagic.com or uninstall the App and clear app data for on-device information.
14. Contact
GreatGuide BV
privacy@greatguidemagic.com
www.greatguidemagic.com
CONTACT