By downloading, installing and using the App you accept the practices and policies described and consent your agreement for the collection and processing of your Personal Data by Us.
1. Personal Data We may collect about you
1.1 We may collect and process the following data about you:
a. Information that you provide when you use our App. This includes Personal Data provided at the time you register to become a user of the App (hereinafter referred to as the “User”) such as your telephone number and your country;
b. Personal Data that you provide while setting up your account such as your first and last name, e-mail address and a profile picture;
c. Personal Data collected automatically when you use the App, such as your location/GPS coordinates (you may enable or disable location services at any time from your mobile device settings – this may differ from a device to another), a device identifier (such as UDID, Serial Number), IP address, operating system and your activity on the App;
d. Personal Data collected automatically about your device contacts list (phone numbers). Such information will be collected when inviting your contacts to use the App (you may enable or disable the access to your contacts list at any time from your mobile device settings – this may differ from a device to another). For clarity purpose the access you give us shall be limited only to the contact that you want to invite in the App and we shall not access your entire contacts list. Your contact list will not be saved in our database.
e. We will keep a copy of your correspondence and/or communication if you will contact Us by e-mail and/or telephone.
1.2 We also process Personal Data and Content (“Content” is defined in the Terms & Conditions that you can read here) that you upload or share within the App such as comments, descriptions, images, photo albums as well as the metadata related to such files, for example but without limiting to size, resolution, date and time, geolocation and/or any other technical information regarding the file or the device with which you created the file (hereinafter referred to as the “EXIF”);
1.3 For clarity purpose We will not request Special Personal Data. According to the Law the Special Personal Data is Personal Data referring to, among others, racial or ethnic origin, political opinions, religious or philosophical beliefs, health-related data or sexual orientation.
1.5 We respect your private life. For this reason, we will process your Personal Data only in situations which is required for use of the App. Also, for your security We will always endeavor to collect as few Personal Data as possible.1.6 Personal Data will be stored only for the duration of processing as described herein. We take appropriate measures to ensure that any Personal Data collected from you is kept secure and kept only for as long as is necessary for the purpose for which such information is used. Please note that deleting the App does not represent the rescission of your consent regarding your Personal Data processing. To revoke your consent, you must delete your account following the procedure described in the Terms and Conditions.
1.7 Because we believe in a responsible processing of your Personal Data, the collection and processing of your Personal Data will be limited only to declared purposes herein, the Personal Data will not unreasonably intrude upon your privacy nor unreasonably interfere with your autonomy and integrity and the processing will be compliant with the legal frameworks.
2. Your rights
2.1 Under the conditions imposed by the Law you enjoy the following rights related to our processing of your Personal Data:
a. the right to access your Personal Data;
b. the right to correct your Personal Data;
c. the right of opposition, meaning that at any time you can notify that you wish us to stop processing your Personal Data, under certain conditions. For clarity purpose, this right will be exercised by deleting your account. Please note that deleting the App does not represent the rescission of your consent regarding your Personal Data processing. To revoke your consent, you must delete your account following the procedure described in the Terms and Conditions.
d. the right not to be subject to individual decisions based on Personal Data processing performed by automatic means;
e. the right to appeal to the court for the resolution of any dispute arising from your Personal Data processing;
f. the right to request that all your Personal Data that we process to be deleted;
g. the right to request the transfer of your Personal Data to another operator.
Please be aware that all the above mentioned rights will be respected to the extent that they do not affect the rights of any other individuals or third parties. Also, please be aware that any unreasonable cost related to the exercise of these rights, including the costs resulting from the abuse of such rights, will be incurred by the User.
2.2 All of the rights above mentioned, except for the right to appeal in court, may be exercised in accordance with the Law, by written application, dated and signed, transmitted to our e-mail address email@example.com . We will answer at any such complain in a period of maximum 15 days.
2.3 In the event you consider that this data processing is illegal you can address a complain to the Authority – www.dataprotection.ro.
3. Processing of your Personal Data
3.1 We use information held about you in the following ways:
a. to monitor and analyze usage and trends and to personalize and improve the App and your experience when you use the App, such as increase the functionalities and user friendliness of the App.
b. to send you confirmations, badges, notifications, in-app notifications, e-mail notifications of our Services as well as information related to new features or changes within the App – such as sign up SMS text confirmation code, security alerts and support and administrative messages and otherwise to facilitate your use, administration and operation of our Service (you may enable or disable such notifications from your mobile device settings – this may differ from a device to another - restricting of such notifications may impede the delivery of the Service).
c. to allow you to add your location to your Time Bubbles;
d. to connect with your friends – when instructed by you with an invitation code sent via a text message;
e. to let your Friends or Groups know about your Content in the App;
f. to let your Friends or Groups comment or talk about your Content in the App;
g. to ensure that the Content uploaded in the App is presented in the most effective manner for you and your device;
i. to provide you with any other information that We feel may be of use or interest to you;
j. any other reason within the purpose for which the Personal Data was collected, respectively for the delivery of the Service and the functioning of the App; and
k. to store your Content (storage space).
4.1 We may use your Personal Data for direct marketing purposes or any other related purposes. We may display, use or share your data for marketing purposes or engage in marketing activities on behalf of, or for the benefit of third parties.
5. Disclosure of your Personal Data
5.1 We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. Such disclosure will be limited for the provision of the Service such as, without however being limited to the use of the App in certain territories.
5.2 We will not share the Personal Data we have collected from you, except as described below:
a. with your Friends or Groups on the App according to the preferences set in your account;
b with service providers employed or contracted by the Company and in connection with the provisions of the Service;
c. we may share aggregated information and non-identifiable information with third parties for industry analysis, demographic profiling and other similar purposes;
d. when we believe in good faith that we are lawfully authorised or required to do so or that doing so is reasonably necessary or appropriate to comply with the Law or any other Law or legal processes or respond to lawful requests of authorities, including responding to subpoenas, warrants or court orders. Should such event occur We are in no circumstance under the obligation to perform any due diligence assessment or due process except for a formal review. Unless specifically forbidden by the context of such disclosure including the expedience of disclosure, we should inform you prior if such disclosure is taking place;
f. in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where Personal Data may be disclosed or transferred as one of our business assets; and
g. to protect the rights of our Company and users.
6. Data security
6.1 All Personal Data will be stored using the following third party data center provider:
? Microsoft Azure
Microsoft Ireland Operations, Ltd.
Attn: Data Protection
Sandyford, Dublin 18, Ireland
6.4 In order to protect your Personal Data we will take the following safety measures, all of the following being implemented in a reasonable commercial manner considering the proportionality of the interest that needs to be protected: limited access only to employees who need such information for providing the services, access to databases based on username and password, databases will be stored on computers protected by a firewall; use of an authorisation system, that can allow the user to access to specific resource; protection of electronic means and data against unlawful data processing operations, unauthorised access and specific software; implementation of procedures for safekeeping backup copies and restoring data and system availability
6.5 The collection and processing of your Personal Data will be limited to the minimum necessary for achieving the specific purpose. This include also that Personal Data will be retained only for the time necessary to achieve the specific purpose. Please note that deleting the App does not represent the rescission of your consent regarding your Personal Data processing. To revoke your consent you must delete your account following the procedure described in the Terms and Conditions.
7.1 In order to use or register to the App you must be at least 18 years old or have the consent of a parent or legal guardian. By registering to the App and the use of Service you confirm that you are either aged 18 or older or that you have your parent or legal guardian consent.
7.2 We may ask you to provide proof of consent from your parents or legal guardian at any time. Please note that parents or legal guardians who have provided their consent are fully responsible for the behaviour of their children in accordance with the law and bear liability for any misconduct as long as damages suffered.
8. Policy updates
8.1 From time to time there may be updates to this Policy. We further recommend you to access this Policy from time to time in order to keep up to date with the changes regarding the scope, the processing method, your rights or security measures.
8.2 If We have your e-mail address We will contact you in order to announce such changes, as well notify you using the in-app notifications or using the corresponding function in the App.
9. Account deactivation
9.1 You can delete your account by contacting us at [firstname.lastname@example.org]. After the account deletion please take into consideration that some of the collected information may be stored for at least 90 days.
9.2 Please be aware that when you will delete your account, including your Content, you may affect your relation with your Friends/Groups that have shared their content with you through Time Bubbles and/or to the ones you have distributed your Content.
10. Applicable Law
10.1 This Policy is governed by and construed in accordance with Law 677/2001 regarding the protection of individuals in relation to the processing of Personal Data and the free movement of such data (“Law”). Law 677/2001 is implemented according to the European Union Directives and Regulations applicable for the processing of personal data. In case of any dispute arising from this Policy or from the use of or operation of the App the courts of Romania shall have exclusive jurisdiction.
S. C. Essensys Software S.R.L. having its registered address in Romania, Bucharest, 16 Copilului Street, 2nd Floor, 1st District, Zip: 012177 , TIN 17393982, Trade Register Registration Number J40/5499/2005, registered under number [?] at the National Data Protection Authority (hereinafter referred to as the “Authority”), as a Personal Data Operator (hereinafter referred to as the „Company” and/ or „We”).
For any questions in connection with enforcing your rights you may contact National Supervisory Authority for Personal Data Processing (www.dataprotection.ro) at email@example.com .
Effective date: [26.07.2016]
Last update: [26.07.2016]