Effective as of August 1, 2019
2. INFORMATION WE COLLECT ABOUT YOU
When you download, install, and use the App, we may collect inter alia the following personal information about you:
- Name and surname;
- Email address;
- Cellphone number;
- Data about your physical activities (e.g. step count);
- Data imported from Health Kit and Fitbit;
- Goal set for the use of the App.
3. INFORMATION WE COLLECT AUTOMATICALLY
When you download, install, and use the App, we may automatically collect the following information:
- Information about your device including type of hardware, operating system and its version, UDI, settings, etc.
4. YOUR CONSENT
By using the App, you explicitly consent that:
WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES, EXCEPT IF IT IS REQUIRED TO PROVIDE THE SERVICE TO YOU (E.G. TECHNICAL SERVICE PROVIDERS), UNLESS WE HAVE ASKED FOR YOUR EXPLICIT CONSENT.
5. HOW WE USE YOUR INFORMATION
We use all information collected about you and your use of the App to improve the App and deliver better experience. Among others, we may use your Personal Data to:
- analyze, operate, maintain and improve the App, to add new features and services to the App;
- provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;
- customize product and service offerings and recommendations to you, including third-party products and offerings;
- send you technical notices, updates, security alerts and support and administrative messages;
- monitor and analyze trends, usage and activities in connection with our App;
We may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the App.
6. YOUR RIGHTS
Modification, correction and erasure. You are able to modify, correct, erase, and update your Personal Data by using the App settings or writing us at email@example.com.
Access. You have a right to access your Personal Data you leave in the App and ask us about what kind of Personal Data we have about you. You can do this by using the App settings or by writing us at firstname.lastname@example.org.
7. HOW WE STORE AND SHARE YOUR INFORMATION
All your Personal Data are collected on our servers for the purposes indicated in Section 5. We host and process all your Personal Data in data hosting service providers in the United States.
- Facebook Analytics. We use Facebook Analytics tools to track installs of our App as well as provide general analytics on what features of the App you prefer the most. Facebook collect only non-personally identifiable information, though some Personal Data like device identifiers (IDFA) or technical events (start of trial, subscription status, etc. ) may be transferred to Facebook for the abovementioned purposes. Read more about analytical services provided by Facebook here. You can find its data practices in ‘Privacy’ sections.
- AppsFlyer. We may share some of your Personal Data with AppsFlyer, a mobile marketing platform. By using AppsFlyer and its integrated partners we are able to reach more people like you on different platforms. Read more about AppsFlyer here and its integrated partners here. To accomplish the abovementioned goals, we may share the following Personal data with AppsFlyer and some of its integrated partners: technical identifiers like IP address (which may also provide general location information), User agent, IDFA (Identifier for advertisers), Android ID (in Android devices), Google Advertiser ID, Customer issued user ID and other similar unique technical identifiers as well as non-sensitive certain app events (like start of trial).
8. DATA RETENTION AND SECURITY
If you choose to delete the App, we may retain your Personal data for as long as your account is active and within reasonable period (but not later than 3 years) thereafter in case you decide to re-activate the App. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve the App. Where we retain information for App improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process. Among others, we utilize the following information security measures to protect your Personal Data:
- Pseudominization and tokenization of certain categories of your Personal Data;
- Encryption of your Personal Data in transit and in rest;
- Systematic vulnerability scanning and penetration testing;
- Protection of data integrity;
- Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
- Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake privacy audit in case of Company’s merger or takeover.
Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach.
9. LEGAL REQUESTS AND DISCLOSURE OF INFORMATION
We may preserve and share your Personal Data in response to a legal request from a competent authority (search warrant, subpoena, court order). We may also preserve and share your Personal Data when we have a good belief that that is necessary for a legitimate purpose: like detecting fraudulent behavior in the App, in order to protect security of the App, and in other cases.
10. CHILDREN’S PRIVACY
We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old under requirements of COPPA. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at email@example.com and we will take required steps to delete such information and (or) delete her account.
11. CONTACT US
IP SURJANSKII EVGENII ARKADEVICH
UL. KIEVSKAYA, D. 3, C. A, KV./OF. 60
ST. PETERSBURG, RUSSIA