Personal data protection policy
Last updated: 29 September 2026
This policy describes what personal data TSNav (tsnav.app) processes, for what purpose, who it is shared with and what rights you have. We process data in accordance with the Law of Georgia “On Personal Data Protection”.
1. Data controller
Individual entrepreneur Duda Elbakidze (small business status)
Email: support@tsnav.app
TSNav is an independent service and is not affiliated with Tesla, Inc.
2. What data we process and why
| Data | Purpose | Legal basis |
|---|---|---|
| Email, name, password (only as an encrypted hash, PBKDF2) | Creating an account and signing in | Performance of a contract |
| Subscription plan, amount, date, payment status and the payment provider's transaction number | Payment records and access management | Performance of a contract, legal obligation |
| Name of the connected phone (e.g. “Pixel 8 · Android”) and time of last activity | Linking the phone to the account and managing the connection | Performance of a contract |
| Saved addresses (home, work, favourites), only if you save them | Quick navigation to frequent addresses | Performance of a contract |
| Phone location (coordinates, accuracy, speed, heading) | Navigation on your car's screen | Performance of a contract, your consent in the form of the location permission on your phone |
| Search phrases, route start and end points | Address search and route calculation | Performance of a contract |
| Technical logs (request time, address, IP address, errors) | Security and operation of the service | Legitimate interest |
We don't receive or store card details: payments are processed on the payment provider's (Flitt) secure page.
3. Location
- The TSNav phone app sends your location only while sharing is on and you have granted the permission yourself. You can turn sharing off in the app at any time.
- Your location is passed through the server in real time only to the car screen opened with your account.
- We don't store trip history or location records in the database. Only the last point stays in the server's temporary memory, so the car screen can show it as soon as it opens. It's deleted automatically when the connection is no longer active.
- The current trip (destination and stops) is stored only in your car's browser, so navigation continues after the page reloads, and is deleted after 6 hours.
4. Who we share it with
We don't sell data or use it for advertising. To run the service we use the following providers, who receive data only for the stated purpose:
| Provider | What for | What data it receives |
|---|---|---|
| Cloudflare, Inc. | Hosting, database, real-time connection | Account data, location stream, technical logs |
| Flitt | Payment | Payment amount and order number; you give your card details directly to Flitt |
| Contabo GmbH (Germany) | Hosting of our routing server | Route points |
| Mapbox, Inc. | Traffic-aware arrival time and the traffic layer | Route start and end points |
| Komoot (Photon), TomTom | Address search | The search phrase and approximate location to sort the results |
| Microsoft Azure (EU) | Voice guidance | Instruction text (e.g. “In 200 meters, turn right”), without location or account |
| OpenFreeMap, Esri | Map and aerial imagery tiles | The area of the map you are viewing |
Some providers process data outside Georgia (EU, USA). In such cases we choose providers that offer appropriate data protection safeguards. We disclose data to public authorities only where required by law.
5. Retention periods
- Account data and saved addresses: while the account is active. Deleted within 30 days of a request to delete the account.
- Payment records: for the period required by tax and accounting law.
- Connected phone: until you disconnect it from the account or connect another phone.
- Sign-in session: 180 days or until you sign out.
- Technical logs: no more than 7 days, then deleted automatically.
- Location: not stored in the database (see section 3).
6. Security
- All connections are encrypted (HTTPS / TLS).
- Passwords and phone access keys are stored only as hashes.
- One phone at a time can be connected to an account. When a new one is connected, the previous one is disconnected automatically.
- Access to data is restricted and used only to support the service.
7. Cookies and data stored on your device
We use only the necessary cookie for the sign-in session. We don't use advertising or tracking cookies. Your browser stores settings (theme, map layer, voice), recent searches and the current trip. You can delete them in your browser settings.
8. Your rights
Under the law, you have the right to:
- receive information about the processing of your data and a copy of it;
- request the correction of inaccurate data;
- request the deletion of your data and the closure of your account;
- withdraw your consent (e.g. the location permission on your phone) at any time;
- request the restriction of processing or the transfer of your data to another service;
- file a complaint with the Personal Data Protection Service of Georgia (pdps.ge).
For requests, write to us: support@tsnav.app. We will reply within the period set by law. You can also disconnect a phone from your account page.
9. Minors
The service is intended for adult drivers. We don't knowingly process data of persons under 18.
10. Changes
If the policy changes significantly, we will publish the updated version on this page and notify registered users by email.