Privacy Policy

Last updated: June 2026

Spitzbergen Reisen AS ("we", "us", "our") operates the Svalbard Audio mobile app and the website at svalbardaudioguide.no (together, the "Service"). This policy explains how we handle personal data in connection with the Service.

The short version: The Svalbard Audio app requires no registration and no personal information. You are entirely anonymous to us. We do not track you, we do not run ads, and we do not sell data.

1. Who We Are

Spitzbergen Reisen AS
Postboks 75, N-9171 Longyearbyen
Organisation Nr: 817 187 072
Email: app@spitzbergen-reisen.no

2. Data We Collect and Why

2.1 Location Data (App)

The app can access your device's GPS location if you grant permission through your operating system's standard permission prompt. This data is used solely to:

• Show your current position on the map
• Order sightseeing points by distance from your current location

Your GPS location is processed on your device and is not transmitted to our servers. It is not used for any purpose beyond the two listed above. While we have disabled Mapbox's location telemetry within the app, map tile requests do result in your IP address being sent to Mapbox's servers (see Section 2.4). Your device's locale settings (language and region) may be accessible to third-party processors for functional purposes such as displaying the correct currency — this is not GPS data.

You can revoke location permission at any time via your device settings. The app continues to work without location access, though distance-based features will be unavailable.

Legal basis: Consent (Art. 6(1)(a) GDPR), given via the operating system permission prompt. You may withdraw consent at any time by revoking the permission in your device settings.

2.2 In-App Purchases (App)

One-time purchases (lifetime access) are processed by RevenueCat, Inc. together with the respective app store (Apple App Store or Google Play Store). RevenueCat assigns a randomly generated, anonymous ID to each app installation to manage your purchase status. We receive no personal information — no name, no email address, no payment details.

Payment details (credit card, etc.) are handled exclusively by the app stores under their own privacy policies. We never see or store payment information.

Data processed by RevenueCat on our behalf: anonymous installation ID, purchase receipt data, device type, OS version, app version.

RevenueCat stores data on servers in the United States. RevenueCat acts as a data processor on our behalf under a Data Processing Addendum. For details, see RevenueCat's Privacy Policy.

Customer support via RevenueCat Customer Center: The app includes an optional in-app support feature (RevenueCat Customer Center). If you choose to use it and voluntarily provide your email address to submit a support request, we will receive that email address together with the following account metadata: country of last use (derived from device locale), anonymous app user ID, total amount spent, account creation date, last seen app version, last opened date, active entitlements, and device OS version. This data is used solely to respond to your support request and is not used for any other purpose.

Legal basis: Performance of a contract (Art. 6(1)(b) GDPR) — necessary to verify and maintain your lifetime purchase.

2.3 App Updates — Expo EAS Update (App)

We use Expo's EAS Update service to deliver over-the-air updates to the app. When the app checks for updates, Expo receives:

• A randomly generated installation ID (non-identifying, changes per install)
• Your device's operating system and version
• The app and runtime version
• Our project ID

No personally identifying information is transmitted. Expo does not associate this data with you as an individual.

Expo stores data on servers in the United States. For details, see Expo's Privacy Policy.

Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — delivering security patches and improvements is a necessary operational interest that does not override your privacy rights, given the non-identifying nature of the data involved.

2.4 Map Display — Mapbox (App)

We use the Mapbox Maps SDK to display maps within the app. When the app loads map tiles (the visual map data), requests are sent to Mapbox's servers. We have disabled Mapbox's location telemetry within the app. The data Mapbox receives through standard tile requests includes:

• Your IP address, used by Mapbox for service delivery and security purposes — Mapbox deletes IP addresses within 30 days
• App and SDK version information

Your precise GPS location is not included in tile requests. Mapbox acts as an independent data controller for the data it receives through tile requests. If this configuration changes in a future version of the app, this policy will be updated accordingly.

For details, see Mapbox's Product Privacy Policy.

Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — displaying maps is a core feature of the audio guide.

2.5 Content Delivery — Supabase (App)

All Content delivered through the app — audio recordings, images, and text — is hosted and served by Supabase (Supabase Inc.). When you stream audio or load images, your device makes network requests to Supabase's servers. These requests include your IP address and standard HTTP metadata (the resource requested, timestamps).

Supabase stores our content in the EU (Frankfurt, Germany) — no transfer outside the EEA occurs. Supabase acts as a data processor on our behalf under a Data Processing Agreement.

For details, see Supabase's Privacy Policy.

Legal basis: Performance of a contract (Art. 6(1)(b) GDPR) — content delivery is essential to providing the Service.

2.6 Website (svalbardaudioguide.no)

Our website does not require registration and does not collect personal information. Our web hosting provider may automatically record server logs containing IP addresses and access timestamps for security and diagnostic purposes. These logs are retained for a limited period and are not used for tracking or profiling visitors.

Google Fonts: Our website loads fonts from Google's servers (fonts.googleapis.com). When a page loads, your browser sends a request to Google — which includes your IP address — so that the fonts can be delivered. This transfer is governed by Google's Privacy Policy. We are working to replace this with self-hosted fonts to eliminate the transfer entirely.

3. What We Do Not Collect

To be explicit, we do not collect:

• Your name, email address, or any contact information
• Payment details of any kind
• Device identifiers linked to your identity
• Behavioural or analytics data about how you use the app
• Any data from children or any other special categories of data under GDPR Art. 9

We do not run advertising, analytics tracking, or remarketing scripts. We do not sell or share your data with third parties beyond the processors described in Section 2.

4. Cookies

The Svalbard Audio app does not use cookies.

The website (svalbardaudioguide.no) may use essential technical cookies required for basic site functionality (e.g., remembering your cookie preference). Non-essential cookies — such as analytics or advertising cookies — are not used. Where required by law, any non-essential cookies will only be set with your prior consent.

5. International Data Transfers

Our third-party service providers (RevenueCat, Expo, Mapbox) are based in the United States and process data there. Each provider ensures that transfers of personal data from the EU/EEA comply with GDPR through one or more of the following mechanisms:

• Certification under the EU–U.S. Data Privacy Framework
• Standard Contractual Clauses as approved by the European Commission (Art. 46 GDPR)
• Data Processing Addendum governing processor obligations

Supabase hosts all app content in the EU (Frankfurt) — no international transfer occurs for content delivery.

Links to each provider's transfer documentation are included in Section 2.

6. Data Retention

We do not store personal data on our own servers. Retention is determined by our third-party processors:

Preferences stored locally on your device (language, theme, etc.) can be cleared at any time by uninstalling the app.

7. Your Rights

Under GDPR and Norwegian data protection law (Personopplysningsloven), you have the right to:

• Access — request a copy of personal data we hold about you
• Correction — request correction of inaccurate data
• Erasure — request deletion of your data ("right to be forgotten")
• Restriction — request that we limit how we process your data
• Objection — object to processing based on legitimate interests
• Portability — receive your data in a structured, machine-readable format
• Withdraw consent — revoke location permission at any time via your device settings, without affecting the lawfulness of prior processing

Because the app operates without accounts or identifying information, we have no means of identifying or retrieving data linked to you from our side. For data held by our processors, requests should be directed to them directly using the contact details in their respective privacy policies. We are happy to assist you in identifying the right point of contact.

To exercise your rights or with any questions about this policy, contact us at: app@spitzbergen-reisen.no

8. Right to Lodge a Complaint

You have the right to lodge a complaint with the Norwegian Data Protection Authority at any time:

Datatilsynet
Postboks 458 Sentrum, 0105 Oslo, Norway
Website: www.datatilsynet.no
Email: postkasse@datatilsynet.no

If you are located in another EU/EEA country, you may also contact your local supervisory authority.

9. Children

The Service is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided personal data through our Service or its third-party processors, please contact us at app@spitzbergen-reisen.no and we will take appropriate steps.

10. Changes to This Policy

We will update this policy when our data practices change materially. The "Last updated" date at the top of this page will be revised accordingly. We encourage you to review this policy periodically. Continued use of the Service after changes are posted constitutes acceptance of the updated policy.

11. Contact

Spitzbergen Reisen AS
Postboks 75, N-9171 Longyearbyen, Norway
Email: app@spitzbergen-reisen.no