As an Internet company that creates a secure software we take privacy issues seriously and we highly value your personal information and always treat them with confidentiality. We understand that you may require highest standard of confidentiality and compliance with rules concerning personal data processing. Therefore, we would like to inform you how we process your Personal Data.
Table of contents:
- Who is data controller?
- What is personal data?
- How can I contact a data controller?
- How do we obtain and process your Personal Data?
- Do we share your personal information with anyone else?
- What are your rights?
- Other provisions
1. Who is data controller?
2. What is Personal Data?
3. How can I contact the data controller?
If you have any question or doubts concerning processing of your Personal Data, please do not hesitate to contact us. You may write an e-mail to us: email@example.com
4. How do we obtain and process your Personal Data?
We always process your Personal Data in accordance with the provisions of the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation; hereinafter: GDPR).
We may process your personal data in connection with various activities concerning providing services by us. We receive your Personal Data directly from you – especially when you use our Services, install the App or contact us.
We may process your Personal Data if you are using our services as a User - a person who accepted our Terms of Service or installed our App.
In connection with using the App by you, we may process your Personal Data in order to:
conclude and perform the contract for the provision of electronic services, in accordance with the provisions of Terms of Service - the legal basis for processing User's Personal Data in this regard is the necessity of processing for performance of the contract to which the data subject is a party or to take action at the request of the data subject before the conclusion of the contract, in accordance with the provisions of Article 6.1.b) of the GDPR,
comply with obligations imposed on the data controller by legal provisions, including in particular tax law or administrative law - the legal basis for Personal Data processing in this regard is the need for processing the data to fulfil the legal obligation to which data controller is subject, in accordance with the provisions of article 6.1.c) of the GDPR,
monitor the way in which our Services are being used, especially for statistical purposes, development of our services, purposes related to the prevention of errors and bugs within the App, to ensure an appropriate level of security, create updates and possible fixes as well as in order to prevent actions which are not in accordance with provisions of our Terms of Services or generally applicable law – what constitutes the legitimate interest of the data controller, and the legal basis for Personal Data processing in this regard is the provision of article 6.1.f) of the GDPR, which indicates the possibility of processing personal data when it is necessary to achieve the objectives of legitimate interests pursued by the data controller or by a third party,
respond to your queries, review potential complaints concerning provision of services by us – what also constitutes the legitimate interest of the data controller, and the legal basis for Personal Data processing in this regard is the provision of article 6.1.f) of the GDPR, which indicates the possibility of processing personal data when it is necessary to achieve the objectives of legitimate interests pursued by the data controller or by a third party.
Sometimes we also may process your Personal Data for the establishment, exercise or defence of legal claims – this also bases on our legitimate interest, as the data controller, and the legal basis for data processing in this regard is the provision of article 6.1.f) of the GDPR, which indicates the possibility of processing personal data when it is necessary to achieve the objectives of legitimate interests pursued by the data controller or by a third party.
6. Do we share your personal information with anyone else?
First of all, we inform you that we do not sell your Personal Data to any third parties. However, we may use some of the external service providers that will process your Personal Data on our behalf, such as:
- Microsoft Ireland Operations Limited with its registered office in Dublin, Ireland - this entity provides us with external cloud and IT services,
- Paddle.com Market Limited, with its registered office in Northamptonshire, United Kingdom - this entity provides us services related to processing orders, fraud prevention, payments and invoicing.
Note that not all of these data processors may automatically receive all your Personal Data, especially stored within the App, as it is end-to-end encrypted.
Also please have in mind that if you download our App via Apple App Store or Google Play, your personal data may be processed by Apple, Inc. or Google LLC, according to their own privacy policies and rules for processing personal data. Please note that in this regard these entities act as a separate data controllers of your personal data.
7. What are your rights?
As we are processing your Personal Data, you are entitled to:
- Request from the Service Provider access to your Personal Data – you may always request this access. We will then provide you with access to this data that we have access ourselves. However, we note that we will not be able to provide you with this data that are encrypted within the App.
- Request rectification of your Personal Data – if you notice that your Personal Data are incorrect or outdated, just let us know and we will rectify them.
- Request erasing your Personal Data – in specific situations, especially if you do not use our services anymore, you may request us to erase your Personal Data. However, we sometimes may refuse to do so, according to the provisions of the GDPR – especially if we still need them in order to exercise or defence of legal claims or to be compliant with a legal obligation which requires processing your Personal Data.
- Request to restrict the processing of your Personal Data – you may ask us to restrict processing your Personal Data if you believe that processing is unlawful or we do not need your Personal Data anymore, you ask us to rectify incorrect data, or you object to processing of your Personal Data.
- Request the transfer of your Personal Data to other service providers – you may always ask us to transfer your data, which comes directly from you, are processed by automated means and are processed basing on a necessity to perform a contract. However we notice that we cannot decrypt nor read nor send to you your decrypted data.
- File a complaint about the unlawful processing of your Personal Data to the competent data protection authority – you can always file a complaint about incorrect processing your Personal Data to competent authority.
To the extent that the processing of your personal data takes place basing on the basis of the legitimate interest of the data controller, you have the right to object to the processing of your Personal Data.
8. Other provisions
Providing Personal Data may be required to conclude a contract for the provision of electronic services or to create a User's account. It may also be needed to comply with legal provisions, especially concerning invoicing and tax law.
We do not process your Personal Data in a way that includes automated individual decision-making or profiling according to the GDPR.