Privacy Policy
Effective Date: June 24, 2021
These Privacy Policy (collectively, the “Agreement”) together with all the documents referred to in it constitute a legally binding agreement made between you as a natural person (“you”,“your” or “user”) and WHALE ROAD LMITED (“we,” “us” or “our”), software application for mobile devices (the “App”).
All the documents that relate to the App are hereby expressly incorporated herein by reference.
Please read this Agreement carefully before you download, install or use the App.
It is important that you read and understand this Agreement as by downloading, installing or using the App you indicate that you have read, understood, agreed and accepted the Agreement which takes effect on the date on which you download, install or use the App. By using the App you agree to abide by this Agreement.
I. INTRODUCTION
Simple Echo Limited (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of data we may process when you use our Scanner App Application.
When we refer to personal data (or personal information) we mean any information of any kind relating to an identified or identifiable natural person. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.
We do not compromise with your privacy. We design all our products and services with your privacy in mind. We involve experts from various fields, including legal, security and others to make sure that no decision is taken without respect for your privacy.
We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We sincerely want you to read our policies and understand our privacy practices!
Our Privacy policy applies to all users who access the Application “Scanner App”(“Users”).
For the purposes of the GDPR, we are the data controller.
PLEASE READ CAREFULLY THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED. WHEN YOU USE THE WEBSITE YOU AGREE TO THE COLLECTION AND USE OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
INFORMATION WE PROCESS
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems; Camera permission; Photo Library permission; Storage permission; Universally unique identifier (UUID); Crash information; email address; Data communicated while using the service; first name; last name; gender; date of birth; phone number; username; country; app information; device logs.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
THE PURPOSES OF PROCESSING YOUR PERSONAL DATA
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Access to third-party accounts, Registration and authentication, Device permissions for Personal Data access, Infrastructure monitoring, Advertising, Backup saving and management and Beta Testing.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
-Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
-provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
-processing is necessary for compliance with a legal obligation to which the Owner is subject;
-processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
-processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
-Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
-Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
INTERNATIONAL DATA TRANSFERS
We work in the cross-border area and provide our application to Users around the world.
If you are located in the European Union, please note that we may transfer information, including personal information, to a country and jurisdiction that may not have the same data protection laws as in your home jurisdiction. We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information.
By using the Application, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.
EXERCISING YOUR RIGHTS
Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:
· Data Access and Portability. You can request copies of your personal information.
· Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct change, update or rectify your data.
· Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
· Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.
To exercise any of the rights described above, you can contact us through contact form. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.
When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.
SECURITY
The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.
Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.
If you have any questions about security of our App, you can contact us at through the email or contact form displayed below.
CHILDREN’S PRIVACY
Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under age 18 may provide any personal information to the App. If you are under 18, do not use or provide any information on this App or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.
CHANGES TO THE PRIVACY POLICY
This Privacy policy is updated regularly.
Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.
HOW TO CONTACT US
If you
have any questions about this Privacy Policy, please feel free to contact us by email: ataraxiaapp336@gmail.com