Privacy Policy

1. What the Service does, in one paragraph

Shadow+ lets you keep track of, and protect, things you own — a car, a boat, a trailer, a bag. You attach hardware to an asset (a ShadowTag that is located through a crowd-sourced network, a GT06 cellular tracker with its own GPS, or a KillSwitch engine-immobiliser that the app talks to over Bluetooth), and the app shows you where that asset is, tells you when it moves or crosses a boundary you drew, and lets you arm or disarm it. Dealerships can additionally use the app to manage their vehicle inventory, test drives and customer enquiries.

Almost everything in this policy follows from that: to show you where your asset is, we have to know where your asset is.

2. Information we collect

2.1 Information you give us

WhatWhenWhy
Email address and password creating an account to identify you and secure your account. Passwords are stored hashed; we never see the plain text
Phone number (optional) creating an account account recovery and, if you are dealership staff, so colleagues can reach you
Preferred language (English / French) Settings so notifications and emails reach you in the language you chose
Asset details — name, type, an optional photo adding an asset to identify your asset in the app. The photo is intended for insurance purposes and is stored with the asset
Geofence zones — the boundaries you draw, their names and messages creating a zone to alert you when the asset enters or leaves
Hardware identifiers — a ShadowTag serial and claim code, a tracker's IMEI, a KillSwitch device ID attaching hardware to link the hardware to your account and your asset
A transfer code accepting an asset from another user to move that asset into your account

2.2 Information the hardware you own generates

This is the core of the Service and the largest category of data we hold about you.

WhatFromDetail
Location of your assets ShadowTag, GT06 tracker the last known position, its address, when it was recorded, and a history of previous positions so you can play back where the asset has been
Movement and geofence events server-side detection that the asset moved after being armed; that it entered or left a zone you drew; when
Tracker telemetry GT06 tracker ignition on/off, whether it is charging, battery / vehicle-battery voltage, cellular signal strength, speed, whether the immobiliser is engaged, and alarms (SOS, power cut, collision, tamper, tow, overspeed, harsh driving, door)
ShadowTag battery level, over time ShadowTag so you know when to charge it
KillSwitch state KillSwitch, via your phone whether it is armed or disarmed, and when the app changed that

How ShadowTag location works. A ShadowTag has no GPS of its own. It is located when a nearby phone in a crowd-sourced network — which may be a stranger's — hears its Bluetooth signal and reports the position to the network operator, who passes it to us. This is why ShadowTag positions can be delayed, approximate, or absent. Our EULA §6 describes the accuracy limits.

2.3 Information your phone provides

WhatDetail
Device fingerprint — manufacturer, model, Android/iOS version, app version, language setting recorded each time you sign in or bring the app to the foreground, so you can see the devices signed into your account and their "last seen" time, and so we can investigate a problem you report
Push notification token issued by Apple or Google's notification service; lets us send you alerts. Stored with your account and removed when you sign out
Bluetooth diagnostics (KillSwitch only) when the app talks to a KillSwitch, it may upload a technical log of that exchange — the device ID, which step was attempted, whether it succeeded, the error code if not, and the raw bytes that went over Bluetooth. The bytes are encrypted between the phone and the KillSwitch and are meaningful only to our engineers; they contain no message content you could read. This exists so an administrator can see why a KillSwitch failed to arm
Camera used to scan a QR code, VIN barcode or IMEI barcode when you attach hardware, and to take an asset or vehicle photo. Frames from barcode scanning are processed on your phone and never leave it

2.4 What we do not collect

We want to be explicit about this, because it is the first question people ask about a tracking app.

3. How we use information

We rely on your consent (given when you create an account and accept the EULA) for the collection described in §2, on the performance of our contract with you to provide the Service, and on our legitimate interest in keeping the Service secure and working. You can withdraw consent at any time — see §8 — but the Service cannot locate an asset without its location.

4. Alerts and notifications

You can turn each category of alert on or off, per asset and per channel (push, email), in the app. Alert wording is prepared on our servers in the language you chose, which is why that language preference is stored with your account rather than only on your phone.

5. Dealerships — information about people who are not Shadow+ users

Dealerships use Shadow+ to manage their business, and in doing so their staff enter information about their customers — people who may never have installed the app.

What a dealership may recordAbout whom
Name, phone number, email address, and the message left a person who enquired about a vehicle (a "lead")
Name and phone number, the vehicle taken, and when it is due back a person on a test drive
Name and contact details a person booked for a hardware installation

For that information, the dealership is the organisation responsible under privacy law, and Shadow+ processes it on the dealership's behalf. If you are such a customer and want to know what a dealership holds about you, or want it corrected or deleted, please contact the dealership; we will assist them in responding. Dealerships agree, in using the Service, to have a lawful basis for entering their customers' information and to honour their customers' rights.

Dealership staff should also know: the app shows each colleague only what their assigned role permits; every action on a vehicle (arming, marking sold, moving it through reconditioning, starting a test drive) is logged with who did it and when, and that activity is visible to the dealership's managers.

Hardware on sold vehicles. Tracking hardware left on a vehicle after it is sold continues to report that vehicle's location. Shadow+ surfaces those vehicles to the dealership and expects the hardware to be recovered, transferred to the new owner, or a reason recorded — because continuing to track a car that now belongs to someone else, without their knowledge, would be a privacy violation under Quebec's Law 25 and Canada's PIPEDA. This is a deliberate feature, not an accident.

6. Who we share information with

We share personal information only with the providers we need to run the Service, and only what each one needs:

ProviderWhat they receiveWhy
Our ShadowTag network provider tag identifiers; they provide us the tag's position to locate ShadowTags
Cellular network / tracker vendor tracker IMEI; the tracker's own reports GT06 trackers report over the mobile network
Google Maps map tile requests, which include the map area being viewed and standard device information to draw the map. Governed by Google's privacy policy
Firebase Cloud Messaging (Google) and Apple Push Notification service your device's push token and the notification content to deliver alerts
Stripe your email, and what you are buying payment processing. Stripe's privacy policy governs card handling
Apple and Google standard app-store data distribution of the apps
WhatsApp none. An earlier version of the app could open a WhatsApp chat to our monitoring line; the current line is a toll-free telephone number reached through your phone's dialler
Our hosting provider everything, encrypted at rest to run the servers

We may also disclose information when the law requires it, to protect someone's safety, or to enforce our terms. We will tell you if we can lawfully do so.

We do not share your data with data brokers, advertisers, or anyone who would use it for their own purposes.

7. How long we keep information

CategoryKept for
Account (email, phone, preferences) while the account exists, and after you delete it only for as long as we still need it or the law requires
Asset location and history while the asset is on your account and you need to be able to play its history back; deleted with the asset, and with your account
Events, alerts, activity logs while the asset is on your account; deleted with the asset, and with your account
Device fingerprint / sign-in registry until you sign that device out, or the account is deleted
Push token until you sign out on that device
Bluetooth diagnostics only as long as needed to investigate the problem they were recorded for
Billing records as long as tax law requires (typically seven years in Canada)
Dealership customer records for as long as the dealership keeps them — this is the dealership's decision

When a retention period ends, information is deleted or irreversibly anonymised.

8. Your rights and choices

Under Canada's PIPEDA and, if you are in Quebec, the Act respecting the protection of personal information in the private sector (Law 25), you have the right to:

In the app, you can already: rename or delete assets; delete an asset's photo; detach hardware; adjust or switch off every alert category; see and sign out the devices on your account; change your language; and sign out. Signing out removes the push token and the local caches from that phone.

To delete your account entirely, see §9. To exercise any other right, write to us (§12). We will respond within 30 days, as the law requires, and we may ask you to verify your identity first.

Automated decisions. The Service does not make decisions about you by automated means that have legal or similarly significant effects. Alerts are triggered by rules you set.

9. Deleting your account

You can ask us to delete your Shadow+ account, and the data associated with it, at any time. You do not need to give a reason.

How to request deletion

  1. From the email address on your account, email support@shadowplus.ca with the subject Delete my Shadow Plus account.
  2. Reply to our confirmation message to verify it is you — we ask so that nobody else can delete your account.

If you cannot email us from your account address, write to us anyway and we will find another way to verify your identity.

We acknowledge every request within 2 business days and complete deletion within 30 days of verifying your identity.

What is deleted

Deletion is permanent. We cannot restore an account, an asset or a location history afterwards, so export anything you want to keep before you write to us.

What is kept

Billing records outlive the account, because tax law requires us to keep them for the period set out in §7. They record what was purchased and when; they contain no location data. If you are the customer of a dealership that uses Shadow+ — you left an enquiry, or took a test drive — that record belongs to the dealership rather than to us and is kept for as long as the dealership keeps it; see §5.

Deleting some data without closing your account

You do not have to delete your account to remove data from it. §8 lists what you can already do in the app at any time — delete an asset and its history, delete a photo, detach hardware, remove a zone, switch off alerts, and sign a device out.

10. Security

No system is perfectly secure. If we become aware of a breach that creates a real risk of serious harm, we will notify you and the relevant privacy regulator as the law requires.

11. Children

The Service is for adults. Our EULA requires users to be at least 18. We do not knowingly collect personal information from anyone under 18, and if we learn we have, we will delete it.

12. Contact

For any question, request or complaint about privacy:

13. Changes to this policy

We will post any change here and update the date at the top. For a change that materially affects how we use your personal information, we will also tell you in the app or by email before it takes effect, and where the law requires, ask for your consent again.

14. Governing law

This policy is governed by the laws of the Province of Ontario and the federal laws of Canada, consistent with our EULA. Nothing in it limits rights you have under the privacy law of the province where you live.