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Privacy Policy – Xplora Technologies Denmark ApS – Xplora service [ December 2025 ]

Article 1 – General provisions

In the following section, you can read about our privacy policy, which describes the collection and processing of personal data for our Xplora service.

Personal information

Personal information is information and data that identifies or can identify you or your child.

This may be name, address, location data, traffic data or other information that can be linked to an identifiable person.

Why do we collect personal data?

In order to provide the User with the best possible experience with our services, relevant personal data is collected. The Xplora service, which consists of the Xplora mobile application (“Xplora watch”) and a SIM card, is a communication service that allows you to communicate with your child. The service also allows you, as well as others with your permission, to find out where your child is. This technology only works if we can collect and process certain personal data about you and your child.

The Xplora service will therefore collect, process and transfer personal data, including location data, to Xplora Technologies Denmark ApS (also referred to as “Xplora Technologies Denmark” or “we”).

Our collection and use of data is carried out in accordance with strict privacy and security guidelines. In developing the Xplora service, special consideration is given to user privacy and we do not collect more personal data than is necessary for the Xplora service to function.

Xplora Technologies Denmark takes your privacy seriously. We comply with current legislation for the processing of personal data and the EU General Data Protection Regulation (GDPR). Our privacy policy is also designed in accordance with Danish law.

We do our best to protect your personal data by implementing appropriate security measures, and by keeping you informed about the purpose and methods of our processing of personal data and about the measures we take to protect it.

Article 2 – Data controller and data processors. Access, rectification and deletion. Transfer abroad.

The person responsible for handling personal data for the Nordic users (Norway, Sweden, Denmark, Finland and Iceland) is Xplora Mobile AS, Munkedamsveien 35, 0250 Oslo. Org. no. 814499022. Xplora Mobile AS can be contacted via e-mail at policy@xplora.com

You always have the right to contact Xplora Technologies Denmark ApS regarding your rights in accordance with the regulations for personal data, including the right to information, access, correction, deletion, data portability and the right to object to certain processing of personal data. You can at any time request to see the data processed about you. Your data will be delivered as soon as possible - but always with a response within 4 weeks.

You have the right to lodge a complaint about our handling of your personal data with the competent supervisory authority. In Denmark, this authority is the Danish Data Protection Authority, Borgergade 28, 5., 1300 Copenhagen K, telephone number: 33 19 32 00. More information can be found at www.datatilsynet.dk

We work with several partners to make the Xplora service work.

We use Telavox as a data processor for traffic data related to the use of the SIM card. This data is processed and stored in Norway. We also use SMS sending services from Link Mobility via their servers in Norway. We use Maksimer AS to develop our platform for registering customers and orders, and they therefore have access to personal information on the platform. When registering and following up on inquiries to our customer service, we use Zendesk inc., which is a provider of a cloud-based “ticketing” system. Personal information included in your inquiries to our customer service will therefore be stored in the cloud, both in Europe and the USA. Invoicing and debt collection are carried out by Collectia on our behalf.

In addition, we use Xplora Technologies AS as a data processor to provide the Xplora app so that the app and the watch can communicate with each other. With our permission, they have engaged Infomark Co Ltd, 360 Kids Guard Co., Ltd, ATENDER AS and Amazon Web services as their data processors. Here, data is stored either in Norway, all on Amazon Web Service servers in Dublin (Ireland) and Frankfurt am Main (Germany).

Article 3 - Description of types of personal data we collect and how the information is used

Through our provision and billing of the Xplora Service to you, as well as your and your child's use of the Xplora Service, we collect or process the following types of information from you and your child:

Location information.

Your name.

Telephone number.

Username and email address, as well as postal address, if you have entered this.

Traffic data from SIM card.

IP address, Mac address, and mobile device identification number (Device ID or IMEI).

History of logins and incorrect login attempts.

The identity of the people you allow to contact your child, including their phone numbers.

Information you may voluntarily enter into the Xplora service, such as nicknames for contacts or pictures associated with contacts.

Our legal basis for processing this information is to fulfill the agreement with you to provide the Xplora Service. In addition, we process personal data if applicable law, regulations, legal proceedings or government orders require us to do so.

We may use AI-based tools to support customer support and troubleshooting (responding to customer inquiries via tickets, live chat and chatbot), which may involve analyzing customer interactions and data solely for the purpose of providing accurate and effective assistance. In doing so, we comply with applicable data protection principles of personal information, including data minimization, purpose limitation and retention limitation, and ensuring the integrity and confidentiality of your data.

Article 4- Processing of personal data with consent

We do not process your personal data for marketing purposes without your consent. If consent has been given, you have the right to withdraw it at any time.

Article 5 - Disclosure of personal data

We do not disclose your personal information to third parties, except in special cases.

We will be able to disclose personal information, including location data, to emergency services when there is a legitimate reason to do so.

In addition, we will disclose personal information that we are legally required to disclose. In the event that we appear in an insurance case, we will share the information necessary for the insurance company to process a possible insurance case.

We will also be able to create and provide aggregated data about our customers' use of the Service. Aggregated data is statistical and does not contain information that can identify you.

We ensure that information about the owner of the phone number associated with the SIM card in Xplora is not disclosed to information services.

Article 6 - Deletion of personal data

Location data is deleted after 72 hours.

Traffic data related to the use of SIM cards is deleted or anonymized after 6 months.

Your Xplora account, including information registered to your account, will be deleted 45 days after you close your account. These 45 days are a so-called closure period, during which the information will not be available to you. During this time, you have the option to reactivate your account. At the end of the closure period, all data associated with your account will be deleted and you will not be able to reactivate your account at this time.

Other customer information about you in connection with your mobile subscription will be deleted 6 months after your subscription has stopped generating traffic.

Chat messages
The chat message history is saved and automatically deleted after 1 month.

Article 7 - Changes to Privacy Policy

If laws and regulatory changes, security technology or other circumstances make it necessary for us to make significant changes to our privacy policy, we will inform you in good time via SMS or email.

Minor adjustments and updates to the privacy policy will only be announced on our website www.xplora.dk

If you have any questions regarding this privacy policy, the website's practices, or your dealings with the website, please feel free to contact us at:

Xplora Technologies Denmark ApS
Njalsgade 76 3rd floor UNIVATE,
2300, Copenhagen S
Tel.: + 45 70 71 50 75
Email: policy@xplora.com

CVR: 41352159

Xplora Technologies Denmark ApS policy was last updated on 08.12.25

Privacy Policy – Xplora Technologies Denmark ApS – Xplora service related to smartphones [December 2025]

Article 1 – General provisions

In the following section you can read about our privacy policy, which describes the collection and processing of personal data in our Xplora Service.

By clicking here , you will be directed to the child-friendly version of the smartphone privacy policy.

Personal information

Personal information is information and data that identifies or can identify you or your child. This may include name, address, location data, traffic data or other information that can be linked to an identifiable person.

Why do we collect personal information?

In order to provide the User with the best possible experience with our services, relevant personal data is collected. The Xplora service, which consists of the Xplora mobile application, a smartphone and a SIM card, is a communication service that allows you to communicate with your child. The service also allows you, as well as others with your permission, to find out where your child is. This technology only works if we can collect and process certain personal data about you and your child.

Article 2 – Data controller and data processors. Access, rectification and deletion. Transfer abroad.

The person responsible for handling personal data for the Nordic users (Norway, Sweden, Denmark, Finland and Iceland) is Xplora Technologies AS, Munkedamsveien 35, 0250 Oslo. Org. No. 814499022. Xplora Technologies AS can be contacted by email at policy@xplora.com

We work with several partners to make the Xplora service work.

In addition, we use Xplora Technologies AS as a data processor to provide the Xplora app so that the app and the watch can communicate with each other. With our permission, they have engaged Infomark Co Ltd, ATENDER AS and Amazon Web Services as their data processors. Here, data is stored either in Norway, all on Amazon Web Service servers in Dublin (Ireland) and Frankfurt am Main (Germany).

Description of types of personal data we collect and how the information is used

Location information.

Your name.

Telephone number.

Username and email address, as well as postal address, if you have entered this.

Traffic data from SIM card.

IP address, Mac address, and mobile device identification number (Device ID or IMEI).

History of logins and incorrect login attempts.

The identity of the people you allow to contact your child, including their phone numbers.

Information you may voluntarily enter into the Xplora service, such as nicknames for contacts or pictures associated with contacts.

Information about mobile apps that are installed or have ever been installed on the phone and app usage statistics.

Article 4- Processing of personal data with consent

The Teens app is intended for children and can only be used in conjunction with a guardian's app. A parent or guardian must provide consent in the app before a child under 16 can use the service.

We do not process your personal data for marketing purposes without your consent. If consent has been given, you have the right to withdraw it at any time.

Article 5 - Disclosure of personal data

We do not disclose your personal information to third parties, except in special cases.

We will be able to disclose personal information, including location data, to emergency services when there is a legitimate reason to do so.

We will also be able to create and provide aggregated data about our customers' use of the Service. Aggregated data is statistical and does not contain information that can identify you.

We ensure that information about the owner of the phone number associated with the SIM card in Xplora is not disclosed to information services.

Article 6 - Deletion of personal data

Location data is deleted after 72 hours.

Traffic data related to the use of SIM cards is deleted or anonymized after 6 months.

Other customer information about you in connection with your mobile subscription will be deleted 6 months after your subscription has stopped generating traffic.

Chat messages

The chat message history is saved in, and automatically deleted after 1 month.

Article 7 - Changes to Privacy Policy

Minor adjustments and updates to the privacy policy will only be announced on our website www.xplora.dk

Contact us

If you have any questions regarding this privacy policy, the practices of the Website, or your dealings with the Website, please feel free to contact us at:

Xplora Technologies Denmark ApS
Njalsgade 76, 3rd floor UNIVATE,
2300, Copenhagen S
Tel.: + 45 70 71 50 75
Email: policy@xplora.com

CVR: 41352159

Xplora Technologies Denmark ApS policy for smartphones was last updated on 08.12.25

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Xplora's privacy policy - child-friendly version

1. Why we collect information

When you use your Xplora Teens phone and the Teens app, we collect some information to make sure everything works properly. This includes your location so your family knows where you are. Your privacy and security are very important to us!

2. Who handles your information?

Xplora is responsible for keeping your data safe. We also partner with trusted companies to store it securely. If you or your parents have any questions, please email us at policy@xplora.com.

3. What information do we collect?

To make your Xplora Teens phone and Teens app work, we collect:

Your name and phone number

Your phone's location

Contacts you add (e.g. family)

Messages you send and receive

4. When do we collect additional information?

If you enter competitions or special events, we may need additional information, such as your mailing address, to send prizes, but we always ask for your permission first.

5. Who do we share your information with?

We never share your data for advertising. We only share it with:

Trusted companies that help maintain functionality on the app and phone

Emergency services if necessary for your safety

If the law requires it

For research, but never in a way that identifies you

6. How long do we keep your information?

Location history: Deleted after 72 hours
Account information: Deleted 45 days after you request it
Chat messages: Deleted after 1 month

We take your privacy seriously! If you have any questions, please ask your parents to contact us.

Privacy Policy – Xplora One and services

Article 1 - General Provisions

By clicking here , you will be redirected to the child-friendly version of the privacy policy for smartphones.

Xplora One can, together with the accompanying app and mobile telephone services subscription, collect and transmit data two X plora Mobile AS / XPLORA TECHNOLOGIES AS/ Xplora Technologies Ltd, such as location data. Such detailed data collection and use is critical to the successful operation of Xplora One . Data collection, storage and use of data will be managed with strict privacy and security measures.

Xplora App and Platform collect personal information when a user (hereinafter "you" or "Member") registers with Explore .

"Personal information" is information which identifies or can identify you or the User, such as your name, address, location data, or other data which can be reasonably linked to such information.

We very much appreciate the importance of your personal information complying with all regulations and telecommunication acts, including but not limited to national Data Protection regulation as well as EU GDPR.

We do our best to protect your personal information by implementing reasonable security standards and hereby inform you of the purposes and methods by which we may use your personal information and of the actions taken to protect your privacy.

Article 2 - Data Controllers and Data Processors. access, rectification and deletion

For Nordic users (Norway, Sweden, Denmark, Finland and Iceland) Xplora Mobile AS, org. no. 814 499 022, is the Data Controller. For users in the other EU countries Xplora Technologies AS, Reg no: 916 752 628, is the Data Controller. For UK users, Xplora Technologies Ltd, Reg.no 10864147 is the Data Controller. You can contact us via the following email address for all the countries: policy@xplora.com

You are entitled to contact one of these Data Controllers for questions related to your rights of access, rectification and deletion according to GDPR and national personal data legislation.

As part of providing our service, we use the company H MD Global OY (“HMD”), located in Finland , as a data processor to improve the speed and accuracy of location data related to Xplora One . HMD uses sub-processors located in China to deliver this service. We limit our data transfer to what is strictly necessary to deliver the service, meaning the device ID and LAC.

To protect this information, we have implemented the following measures:

Category	Measure	Purpose
Technical	Proxying (Germany)	The Xplora proxy acts as a "buffer." It strips IP addresses and any PII (names/phone numbers) before the data leaves the EU.
	Encryption	The Device ID is encrypted. The decryption keys are held in Germany and not shared with Unisoc .
	Data Minimization	Only Cell ID and LAC are sent. No "User ID" or "Account ID" is included in the AGPS request.

Our legal basis for this transfer under the GDPR is the EU Standard Contractual Clauses (SCC).

For the registration and follow-up of inquiries to our customer service, we use Wait AS. All your data and personal information collected from you is subject to be processed and stored in Amazon Web Services hosted in Dublin (Ireland) and Frankfurt (Germany) on our behalf and we sometimes handle transfers from your home country to these services in Dublin (Ireland) and Frankfurt (Germany).

HMD, Amazon Web Services, and Wait AS are Data Processors according to data processing agreements between us and these entities.

Article 3 - Categories of personal data that we collect from you and how we use it

We may, when we provide our services to you, or in relation to our provision of services to you, collect from you and from your XploraOne the following types of information:

Service usage information, access information, cookie , IP address , mobile phone identification numbers (phone ID or IMEI), unauthorized or inappropriate access information, Location information stored on your XploraOne or your location information.

Other detailed information on data we collect:

Data	Retail
Installation information of the mobile app	Type of device
	Device token
	Installation ID
	Phone number
User information of the guardian's mobile app	Username and password
	Phone Number
	Devices managed by the user
	Installation information
	Email address
Contact Icon	Contact icon image link of phone contact information
Phone Contact	Phone number
Phone Contact	First name and last name (optional) of the phone contact
Device info. of XploraOne	Device model name
	Device model number
	Device App key
	Device operating system name
	Device language
	Device product name ???
	MNC and MCC of the SIM card inserted into the phone
	IMSI of the SIM/ eSIM card inserted into the phone
	IMEI1 and IMEI2
	B/W version including variant code
	TA code
	Location
	Time Zone
Device Settings	Setting values of the device
Device Icon	Device icon image
Location	Coordination and time stamp of a phone
Location	Location
MCC+MNC+ LAC + CID (Cell ID)	In cellular networks, MCC+MNC+ LAC + CID (Cell ID) are identifiers that tell the network which cell site sector your device is attached to, and which “location area” that cell belongs to.
Chat History	History of chat messages from chat conversations
Chat History	Audio, image and video files uploaded in chat conversations
Step Count	Number of steps taken by the user over a period of time
Step Count	Derived data from steps includes but not limited to usage statistics, coins, campaign ranking, auctions, etc.
Call History	Call history for parent app
Data Usage	Information of data usage (not including WIFI data)

We may collect data from you through the following channels or methods:

through the webpage, paper form, fax, telephone, customer service board, email, promotional event application, logistics service

automatically collect from you executing or using our services

collected when you voluntarily register for or use our service

The legal basis for the processing of this data is for the performance of the contract of the provision of our services, entered into between you and us.

In addition, we may process personal data if applicable law, regulation, legal process or enforceable governmental request, obliges us to do so, or if GDPR art 6 (1) (f) is applicable, namely in cases where we have legitimate interests that are not overridden by data protection interests.

We may use AI-powered tools to assist with customer support and troubleshooting (answering customers' requests through tickets, live chat, and chatbot), which may involve analyzing customer interactions and data solely for the purpose of providing accurate and efficient assistance . In doing so, we comply with privacy principles, including data minimization, purpose and storage limitations, and ensuring the integrity and confidentiality of your data.

Article 4 – Information we collect based on actions on your side or if you have consented

We may also collect the following personal information case that you use additional services or personalized services or if you participate in various events we host.

In case you win an event we will process information required to provide a gift and mailing address. In case you use fee-based services we will process payment information.

We do not use your personal information for direct marketing purposes, unless freely given, specific, informed and unambiguous consent has been obtained from you.

Article 5 - Disclosure of Personal Information – transfer to third parties

Your personal information will not be shared with third parties other than the ones that need this information to execute the Agreement and will not be provided to third parties or organizations beyond the scope set forth in Privacy Policy Policy, unless you have given consent.

For the avoidance of doubt, we will not share your personal information with third parties for marketing purposes unless you give us your consent through an opt-in.
However, we may disclose or use your personal information without your consent if there is any applicable law, regulation, legal process or enforceable governmental request that obliges us to do so.

We may also transfer personal data to third parties if GDPR art 6 (1) (f) is applicable, namely in cases where we have legitimate interests that are not overridden by data protection interests. We may therefore pass information about the location of your XploraOne two emergency services.

Furthermore, we may provide location information or any other usage data in a non-personal, aggregate format for statistical and research purposes to third parties. Such data is not considered as personal data.

Article 6 – Data retention policy

In general, we store personal data as long as legitimate interests and/or applicable legislation, justify storage.

Location data
We automatically delete your location history data after 72 hours.

Account data
If you decide to deactivate your account by sending us an email, we keep your data for 45 days from the date of deactivation request. This is called the deactivation period and during this process your data is not accessible.

Within the deactivation period you have the option to reactivate your account, unless there is a separate agreement between you and XPLORA Mobile AS or XPLORA TECHNOLOGIES AS/ Xplora Technologies Ltd to begin the process of deleting your data immediately after the deactivation period has started.

After the deactivation period, we will start the process of deleting your account. Deletion from our systems and backups may take up to a week.

Chat messages
History of chat messages are stored for, and automatically deleted , after 1 month.

Article 7 - Notifications on amendments to this Privacy policy
In the event of any material change, addition, or deletion to the privacy policy due to related laws, security technology, or due to any other matters, we will notify you of all changes 30 days in advance via email.
Non-material changes will be notified through these websites only.

Article 8 - CHILDREN'S PRIVACY POLICY

We know it's important to treat data you tell us is from children under 18 carefully. This Notice explains what we do (and don't do) when it comes to children's data.

What Children's Data We Collect
We don't knowingly collect data from or about children without the permission of their parent or guardian. When we do collect that data, we might do it directly, like when you sign up for a service. We might also collect it automatically if your child uses the products or services we offer. We collect the following data:

Geolocation Data – we collect data that tells us the location of your child XploraOne .

Unique Identifiers – we collect phone and network identifiers - basically, ways for us to tell which feature phone on our network is your child's.

Customer Proprietary Network Information (“CPNI”) generated by your child's use of our wireless voice communications services.

Information from your child's use of our products, services, and network (and other carriers' networks when roaming domestically or internationally) like usage of connecting carriers and Internet service providers, the Internet Protocol (“IP”) address, text messages, and data use history, content interactions (eg, how long you use an app), language settings, and other network and phone analytics and Wi-Fi connection and usage data.

Phone and service performance and diagnostic information – this includes reports from your child's feature phone about signal strength, speeds, app and service performance, dropped calls, call and data failures, geolocation information, and phone data.

Back-up information , including data stored in back-ups and cloud services if your child's feature phone uploads information to XPLORA Mobile AS / XPLORA TECHNOLOGIES AS/ Xplora Technologies Ltd

Audio information, including voice commands your child provides to our app (for example, for accessibility or hands-free use).

Child's username – For joining child-friendly activity-based platform Xplora Activity Platform.

Data Usage – this tells us the amount of data the hotspot uses, and IP addresses associated with websites visited.

How We Use Children's Data
The main reason we collect children's data is to provide the product or service in accordance with the Agreement . But we may also use children's data to for the following purposes:

Create and administer accounts, complete transactions, payments, billing, and requests related to our products and services and third-party products and services charged to your accounts.

Check eligibility for a particular product or service.

Help stop fraudulent, malicious, deceptive, abusive, or unlawful activities.

Fix errors and ensure the quality, security, and safety of our products and services and network

Cooperate with law enforcement and protect the rights, safety, or property of our customers, XPLORA Mobile AS / XPLORA TECHNOLOGIES AS/ Xplora Technologies Ltd and others.

Comply with and enforce legal and regulatory obligations and respond to government requests.

Enforce our policies, terms and conditions, or other agreements.

Defend against or pursue claims, disputes, or litigation.

When We Share Children's Data
Sometimes third parties , such as Google, assist us in provision a product or service, and these service providers may need access to children's data. They are required to keep children's data we provide them confidential and to use it only to provide the services we requested . We may also share children's data with third parties, including the government, for legal processes or to protect life and safety where we believe that access, use, preservation, or disclosure of the data is reasonably necessary .

As part of providing our service, we use the company H.M. , located in Finland , as a data processor to improve the speed and accuracy of location data related to each Xplora device HMD uses sub-processors located in China to deliver this service. We limit our data transfer to what is strictly necessary to deliver the service, meaning the device ID and LAC. To protect this information, we have implemented the following measures:

Category	Measure	Purpose
Technical	Proxying (Germany)	The Xplora proxy acts as a "buffer." It strips IP addresses and any PII (names/phone numbers) before the data leaves the EU.
	Encryption	The Device ID is encrypted. The decryption keys are held in Germany and not shared with Unisoc .
	Data Minimization	Only Cell ID and LAC are sent. No "User ID" or "Account ID" is included in the AGPS request.

Our legal basis for this transfer under the GDPR is the EU Standard Contractual Clauses (SCC).

Your Rights as a Parent or Guardian n
Parents and guardians have rights when it comes to their children's data:

To change their mind and withdraw consent to the collection of their child(ren)'s personal data.

To see the personal data XPLORA Mobile AS / XPLORA TECHNOLOGIES AS/ Xplora Technologies Ltd has collected about their child(ren).

To ask us to delete personal data XPLORA Mobile AS / XPLORA TECHNOLOGIES AS/ Xplora Technologies Ltd has collected about their child(ren).

You can take any of these steps by writing an email to policy@xplora.com . We may need to collect some data from you confirm you're the parent or guardian.

Important : We need to collect your child's data (as described above) to provide the relevant products or services. If you change your mind about giving consent or ash us two delete your child's data, the product or service may no longer work.

These terms were last updated: February 202 6 . You will be notified if the Terms of Service in case of material changes to these Terms of Service.

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Privacy Policy – Xplora Technologies Denmark ApS – Xplora service [ December 2025 ]

Privacy Policy – Xplora One and services

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Privacy Policy – ​​Xplora Technologies Denmark ApS – Xplora service [ December 2025 ]

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Privacy Policy – Xplora Technologies Denmark ApS – Xplora service [ December 2025 ]