Privacy Policy

This Privacy Policy was last updated on 17.04.2020.

We are committed to the respect and protection of your personal data. 

This Privacy Policy was created by HALFWAY UP S.R.L. (“”, “we”, “our”) to disclose our policy regarding private and non-private information collected from our visitors and Subscribers (“you”, “your”). This PRIVACY POLICY shares how utilizes, stores, disseminates, and protects information collected via the website and any Services offered through our brand. We commit to handling any and all personal data collected through this process in a transparent manner, in accordance with Applicable Law and Regulation, and ensuring its confidentiality and security. 

This PRIVACY POLICY applies to Data collected about you as an individual through our Website and through related mobile phone tracking services (Services). By accessing the Site or Services, you agree to this PRIVACY POLICY and to the processing of your Data, as stipulated by this Policy. If you do not agree with this Policy, your only recourse is to refrain from accessing or using our Website or our Services. 

We reserve the right to update this PRIVACY POLICY at any time, with notice to Subscribers. Non-Subscribers are responsible for checking this page for updates. We will post the date of the previous modification at the top of the page. Any access or usage of the Website or Services entails a full agreement with this Privacy Policy, including any modifications thereof. 

1. What is Personal Data? 

1.1 Personal data includes any data which can be used to identify an individual, either directly (e.g., first and last name, email address), or indirectly (e.g. IP address, credit card, telephone number). 

2. What Data do We Collect and Process? 

We collect Personal and Impersonal data in order to run and maintain the Website and Services and to improve the Website and Services. 

Data we may collect includes: 

  1. Data which you provide to us during Registration for an Account or Subscription, as stipulated under the General Terms and Conditions and the Contract for use of our Services. 
    • Your Email Address
    • Your First Name 
    • Your Last Name 
    • Your Address
    • Your City
    • Your Country 
  1. Data you may provide during interactions with via the contact page, contact details, or otherwise. Any communication with us may be recorded and retained in records. Contacting us assumes your consent. 
  2.  Data which is automatically collected during visitor navigation of the Website. With the exception of Internet Protocol Address, this data does not include Personal Information. 
    • Device information such as hardware model, operating system, or unique device ID 
    • Server logs including Internet protocol address, device and event information such as outages and system activity, browser type, browser language, and date and time of browsing activities. 
    • Cookies and “Cookie-like” technologies, which are used to collect and store information to provide, improve, and optimize services, such as by identifying the browser and device, saving Preferences, etc. These may be opted out of at any time. To see our Cookie Policy, move to Section 8 of this document. 

3. For What Purpose(s) Do We Process Your Data?

3.1 We collect data for the purpose of providing and improving the Website and Services. It is also used to: 

    • enable the mobile phone geolocation service offered under Services
    • provide and maintain, at our sole discretion, to provide the services that you agree to. 
    • contact Subscribers with the intent of discussing, its’ services, its’ Policies, its’ Terms, or its’ Offers. This Newsletter may be opted out of at any time by the subscriber.
    • answer direct questions posed by the Subscriber to us. and to offer assistance related to our Website or our Services
    • bill Subscribers for Services 
    • comply with legal processes or law enforcement requests under Applicable Law
    • conduct or transact business as you have contracted with us, as we, in our sole discretion, deem reasonable. 
    • develop and improve the Website and Application based on user data and behavior 
    • analyze user patterns to improve UX 
    • generate visitor behavior and Subscriber behavior statistics 
    • adapt and develop new products and services
    • correct errors
    • identify users who commit illegal acts or infringe on our rights 

Your consent to this PRIVACY POLICY is implied by your usage of the Website and Services. You may withdraw your consent at any time by contacting us at Any request to terminate this agreement will be treated as a request to Unsubscribe and Terminate any Subscription Agreement or Contract Agreement which may exist between and the individual making the request. Contract termination will take effect on the first day of the next Payment Period. 

4. With Whom Do We Share Your Data?

We may disclose and share Personal and Impersonal Data with the following parties: 

  • Services providers and processors we use to ensure the functioning of the Site. In particular,’s hosting provider and payment processing provider. These suppliers may access and/or process your Data on our behalf.  We take commercially reasonable steps to require third parties to adequately protect your Data and to only process it in accordance with our instructions, in accordance with Applicable Law.
    • We utilize the services of third-party hosting provider A3 Hosting, Inc for hosting. Visit for more information about our Hosting provider’s Privacy Policy. 
    • We utilize the services of third-party payment processor STRIPE for payment processing. We do not process or hold your credit card information. never has access to your payment information and cannot be held liable or accountable for this Data. Visit for more information regarding STRIPE’s treatment of your Personal Data. 
  • Any third party to whom we have been ordered or obliged to disclose your Data to because of a court order or from a government authority under Applicable Law. This is pursuant to any legal obligations which we may hold in connection to legal proceedings. 
  • An entity likely to intervene for emergency purposes, which requires such disclosure for emergency intervention

Under no circumstances will your data be sold to third parties, for any purpose, but especially for marketing or promotional purposes. In the event that all or part of HALFWAY UP S.R.L. is sold, you have the right to delete or terminate your data before the transaction takes place. We will notify Subscribers of any such purchase or transfer no less than 30 (thirty) days preceding the transfer. 

5. Where do We Store Data?

We take every commercially viable step to ensure that Data is processed in accordance with this Policy and with Applicable Laws. 

We store Data on servers provided by A2 Hosting. A2 Hosting maintains its servers in The Netherlands. Your Data may occasionally be processed outside of the Netherlands, especially if the mobile phone numbers you wish to locate are in another region. Your data will only be transferred in this way on your request. 

6. How Do We Protect Your Data?

We are committed to ensuring the security of your Data. To this end, we employ all reasonable technologies and security measures to protect your Data from unauthorized access, use, modification, or disclosure at any level, as appropriate to the type of Data involved. 

In addition, we endeavor to protect your Data as stored and processed by third-party service providers. Stipulations requiring that your Data be treated and processed in a similarly secure manner to ensure confidentiality, integrity, and security are part of our contracts with third-party suppliers. 

Despite these efforts, we cannot guarantee the security of Data transferred over the Internet. Any Data transferred is done so at your own risk and does not assume any liability, except in the instance where data loss, harm, damages, use, access, disclosure, or unauthorized access are the direct result of neglect or malignant intent on the part of or our employees. 

7. How Long Do We Store Your Data? maintains Data for the duration of an Account. Following Termination, we may retain data when required by Law or until any contractual claims made in connection with the account become time barred. 

8. Cookie Policy 

A cookie is a small text file stored on your computer’s local hard drive and utilized to deliver Services and Collect Information. makes use of Cookies across our Website and Services. First-time visitors to the Website or those who have recently cleared Browser Cookies or History will see a message concerning the use of cookies. You may accept or deny our right to deliver cookies at this time. However, refusal to do so may impact the quality and deliverability of Services and Features across the Website and Services. The message includes options to Opt-in or Opt-out of Cookies on the Website. uses cookies for the following purposes: 

  • Statistical purposes, including to evaluate the frequency of use of the Website, in order to continuously improve the navigation and relevance of Content on the Website. 
  • To automatically record general information concerning your navigation. We utilize Google Analytics for this purpose. All Data collected by Google Analytics is anonymized to the fullest extent possible. This Data is never shared with or transmitted to other organizations for commercial purposes. You may visit to read more about Google Analytics’ Privacy Policy. This data includes: 
    • IP address
    • Geographical origin 
    • Date/time of visit 
    • Duration of visit
    • Pages visited 
    • Sequence of pages visited and their order
    • Pages shared visa social media 

All Cookies used on’s website are stored for a period of 90 (ninety) days, after which they are automatically deleted. You may delete cookies at any time by choosing to delete or erase cookies using the dedicated function in your browser. Following cookie deletion, you will see a message asking you to accept or deny cookies on your next visit to the Website. 

9. Social Media and Other Websites makes use of various websites, services, and social media websites which may include Facebook, Twitter, Pinterest, Instagram, LinkedIn, YouTube, etc. We take and hold no responsibility, liability, or control over the Privacy Policies maintained by these websites. It is the visitor’s sole responsibility to read and understand the Privacy Policies of these services, as well as the tools provided by the platforms. 

In addition, the Website and Services may contain references to or links to third party websites, services, and social media, including through social media feeds. Clicking on these links means that you are leaving’s website and are leaving our sphere of control. We have no influence whatsoever on any content, Data Policies or Practices, or practices of any linked site. Any access and use of third-party sites is solely your responsibility. 

10. What Rights do You Have in Regard to Your Data?

Pursuant to Applicable Law, you have the right to:

  • See and View any Data processes about you, for what purposes, how we share it, and how long we keep it
  • To rectify any inaccurate Data about you on our Website or Services 
  • To request that we stop or limit the processing or your Data. In practice, this request may have to be treated as a request to Unsubscribe and Terminate the Contract Agreement and Services. 

You may submit such a request or a question regarding the processing of your Data by emailing 

You have the right to complain to a supervisory authority regarding’s processing of your personal Data. 

Residents of Switzerland may file the complaint at: 

Feldeggweg 1, 3003, Bern, Switzerland. 

For more information, please visit

Residents of the EU may file a complaint with the Data protection authority in their country of residence. 

11. Contact

Contact with questions, concerns, or clarification of this Policy via 

12. Legal Notice

 Any legal notice should be sent via registered mail to: 

Halfway UP S.R.L

Fundac Bucium nr.10A, Iasi, Romania

Further contact may be initiated via the website or via email at, but will not constitute full legal notice. 

  1. Legal Disclaimer operates “As-Is” and “As-Available” without any warranties of any kind. We are not responsible for any events beyond our direct control. 

This Privacy Policy is governed by the laws of Romania and held to the standards of the European Union, including the regulations of the General Data Protection Regulation (GDPR).