THE APP OWNER (E.G., THE BUSINESS/ENTITY WHO OWN THE APPLICATION IN STAKE) AND/OR ITS SUBSIDIARIES AND/OR OPERATING PARTNERS, AGENCIES OR RESELLERS (“BUSINESS”, “WE”, “US”, “OUR”), RESPECT YOUR PRIVACY.
This Policy describes the ways your personal information and data is collected, used and shared and the rights and options available to you with respect to your information.
- Personal Information that we may Collect
- Registration Information. You may be requested to submit a registration form (or otherwise provide personal information about you in an equivalent form or manner) in order to become a registered (or logged in) member of our membership/community/“followers” club/association (or their equivalent) or other service of the App (“Registered Member” and the “Registration Form” respectively): the Registration Form may include personal details such as, but not limited to: name, phone number, email, home address and any other information that you decide to provide us.
- “Contact Us” / Communication forms Information. If you send us an online form that we make available or by sending an email to an email address that we display, you are required to provide us with certain information such as your name and email address.
- Cookies and Other Tracking Technologies. Our Services utilize “cookies”, anonymous identifiers and other tracking technologies in order for us to provide our Services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Services. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user.
- Mobile Device Data: We may collect information about the mobile device, such as mobile device identifier and/or account identifier (Android UDID, iOS UUID; Advertising ID: IDFA for iOS devices and AAID for Android devices, or their equivalent), the Internet protocol (IP) address of the device used to access the Internet, geo-location (if enabled), device type and its operating system version.
- We also collect information regarding the features, content, services or websites accessed, clicked or interacted with through the App as well as information regarding the interactions made with the App’s interface and features.
- Location. We process your geolocation information in order to provide you with offers and/or promotions which are based on your location (“Location Based Services”). These Location Based Services apply whenever your location is made available to us. By disabling your geo-location (e.g. through the mobile device operating system), certain features which require your geo-location information may not function or may be interrupted.
- Online Purchases. To the extent the App includes an online store/ordering service, which is offered by us (not by a Third Party), we will collect information regarding the purchases made online. Purchase details may include: time and date of your purchase, place where purchase was made, the amount paid and information about the items purchased.
- Children’s Privacy
Personal information about children who are under 13 years, or other minimum age which applies in your country (16 in most EU countries) is not knowingly or intentionally collected. If you are under that age, you are not permitted to use the App, register to any Members Features, or use any aspect of the App. If you have reason to suspect that children data is collected, you are kindly requested to immediately report it to us.
- Use of collected information. Legal basis (GDPR only)
The information we collect will be used for the following purposes (please note the GDPR legal basis next to each purpose):
- To provide you with the App’s functionalities, features and services (including, without limitation, personalized content and Location Based Services, if any), send you, from time to time, push notifications, SMS text messages, commercial emails and/or other communications from us. GDPR legal basis: depending on the context, consent, performance of a contract, legitimate interest (g. send you administrative communications);
- To improve and customize the experience of using the App and the offerings made through the App. GDPR legal basis: legitimate interest, performance of a contract;
- To develop new services or update or upgrade existing services. GDPR legal basis: legitimate interest, performance of a contract;
- To manage the administrative and operational aspects of the App. GDPR legal basis: legitimate interest, performance of a contract;
- To send you marketing communication. GDPR legal basis: legitimate interest or consent;
- To enforce this Policy and prevent unlawful activities and misuse of the App. GDPR legal basis: legitimate interest, compliance with laws, performance of a contract;
- To comply with any applicable law and assist law enforcement agencies when we have a good faith belief that our cooperation with them meets the applicable legal standards. GDPR legal basis: compliance with laws, legitimate interest; and
- To take any action in any case of dispute involving you with respect to the App. GDPR legal basis: Legitimate interest, compliance with laws.
- If you have questions about these uses, please contact us as detailed hereunder. Please note that the legal basis is provided for GDPR purposes only.
- Sharing and transferring collected information
The information outlined in the preceding sections, may be shared with, or transferred to our processors or vendors for the purposes of helping us provide the App and its respective services. This includes our processors, vendors and third parties which provide you with services, features or content in connection with the App such as online ordering, scheduling, ecommerce services, games, payments, communications, customer support, feedback, plugins or APIs, or companies that host the App. If you wish to receive further information, please contact us (as detailed hereunder).
In addition to the above, we may share the information as follows:
- In any case of dispute, or legal proceeding of any kind involving you with respect to the App, your information may be shared with competent authorities and with any third party, as may be required;
- With the relevant authorities, entities or persons if we reasonably believe that we are required by law to share or disclose your information;
- With our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly);
- Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business, the information that we receive, collect or obtain, as outlined in the preceding sections, may be shared with or transferred to, that respective entity, provided that it will undertake to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, that entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and we will be released from any liability to you, regarding the succeeding entity’s use and processing of the information by it.
- In any case other than the above mentioned in this Policy, your personally identifiable information will be shared with others only if you provide your consent.
- Aggregated or anonymized information
The App collects anonymized as well as aggregated information, which does not identify you personally. Such anonymized or aggregated information will be used by us in any way without restrictions or limitations.
- Transfer of Data Outside Your Territory (GDPR only)
We host your personal information in connection with the App either in the European Economic Area, in the US, in the country where we are located, or in countries deemed as providing an adequate level of data protection.
Your data will be accessible in the country where we or our service providers are located.
Please contact us if you need further information about this.
- Analytic Tools
- Analytics Tools. We may use Analytics Tools (such as “Google Analytics”). By enabling such tools, we enable the collection of data about App users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from such tools to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger.
- Your Rights with the Data
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
- You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
Please contact us as detailed hereunderif you wish to make a request.
- Data Retention
Your personal information will be stored until we delete the record and we proactively delete it or you send a valid deletion request. Please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
- Change of this Policy
This Policy may be changed from time to time and, therefore, we ask you to check back periodically for the latest version of this Policy.
- Contact Us
You may send requests, responses, questions and complaints by contacting us.
Please consult our Web/Mobile site, Social channels/pages, Mobile App, for our contact details.
(GDPR only) If your question relates to our data protection officer (DPO) or representative in the EU, we will forward the request accordingly.
Last Updated: Sep 01 2021