Effective Date: 01.04.2018
Current version is available at http://appsnovatech.com/privacyPolicy.aspx
3. What is the purpose of this Policy
Privacy and security of your Personal information are extremely important to us. When you use the Sites and/or Services, AppsNovaTech processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.
As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:
(a) why and how your Personal information is used (also, “processed”) by AppsNovaTech when you access the Sites or Services;
(b) AppsNovaTech’s role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed;
(c) what instruments you may use to limit the amount of Personal information collected by AppsNovaTech; and
(d) what your rights are in relation to the above processing.
4. What type of Personal information is collected by AppsNovaTech
Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your AppsNovaTech user account or without logging in. When you are logged in to your AppsNovaTech user account as you are using the Sites or Services, Personal information collected by AppsNovaTech may be collated and combined with other Personal information (such as your identity, contact details, age and gender, if you shared this information with us) collected by AppsNovaTech in your user account. AppsNovaTech does not verify Personal information provided by you and cannot posit if it is true and whether you have the legal capacity required. However, AppsNovaTech assumes that the information you provide is true, sufficiently complete and up-to-date.
Personal information collected by AppsNovaTech when you access, interact with or operate the Sites and/or Services includes:
(i) information provided by you when you register (create) a user account, such as your name, mobile phone number and age;
(ii) electronic data (http headers, IP address, information about your hardware and software);
(iii) date and time of accessing the Sites or Services;
(iv) information related to your activity when using the Sites or Services;
(v) (geo)location information;
(vi) other information about you that needs to be processed according to the terms and conditions of any specific AppsNovaTech Site or Service; and
(vii) information about you that we may receive from our Partner in accordance with an agreement you made with this Partner and an agreement between AppsNovaTech and this Partner.
We do not actively collect any sensitive personal data (such as racial origins, political opinions, health or biometric data). As we do not know in advance the potentially sensitive nature of the personal data you may provide to us, you must be aware that we may not be able to request your consent with such processing.
We do not perform any form of profiling which has the potential to significantly impact your rights and freedoms.
5. What are the legal basis for processing your Personal information and the purposes of it
AppsNovaTech is not allowed to process your Personal information if it does not have a valid legal ground. AppsNovaTech will therefore only process your Personal information if:
(i) the processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services;
(ii) the processing is necessary to comply with our legal or regulatory obligations; or
(iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of AppsNovaTech and does not unduly affect your interests or fundamental rights and freedoms. Please note that when we process your Personal information on this basis, we will always seek to maintain a balance between our legitimate interest and the protection of your privacy.
Examples of such ‘legitimate interests’ referred in (iii) immediately above are:
(a) to better understand how you interact with our Sites and/or Services;
(b) to enhance, maintaining accessibility, modify, personalize or otherwise improve the Sites and Services for the benefit of all users; and
(c) to offer you other products and services from AppsNovaTech or other companies which we think can be of interest to you (i.e. personally-targeted advertising).
(iv) for specific purposes we may ask your consent for processing of your Personal information.
AppsNovaTech always processes your Personal information for a specific purpose and only processes Personal information which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:
(i) to provide you with the Sites and/or Services;
(ii) to provide you with access to your user account, if you have an account on these Services;
(iii) to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application;
(iv) to provide advertisements and/or commercial offers based on your preferences and other Personal information available to AppsNovaTech;
(v) to improve user experience, as well as improving other AppsNovaTech products, applications and services;
(vi) to develop new products, applications and services;
(vii) to protect your rights and the rights of AppsNovaTech; and
(viii) to collect, process and present statistical data or big data, or perform other research and/or analysis of Personal information.
6. How does AppsNovaTech protect your Personal information
In most cases, Personal information is processed automatically without access to it by our staff. However, if such access is necessary, your Personal information can be accessed only by those AppsNovaTech employees whose professional tasks require using this information. To protect your Personal information and ensure its confidentiality, these employees must comply with internal rules and follow protocols for processing Personal information. They are also required to follow all technical and organisational security measures protecting your Personal information.
AppsNovaTech has also implemented adequate technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.
7. Who else has access to your Personal information and who is it shared with
AppsNovaTech may also transfer Personal information to third parties outside the AppsNovaTech Group to complete the purposes listed in Section 5 above. Such third parties may include:
i. Partners, such as media publishers, advertising networks and other partners providing AppsNovaTech with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners;
ii. Advertisers or other Partners serving targeted advertisement on the AppsNovaTech Sites or Services; and third parties who process Personal information, such as our (IT) systems providers and/or consultants.
AppsNovaTech may also transfer Personal information to the following third parties outside the AppsNovaTech Group:
i. any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
ii. any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;
iii. third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;
8. For how long do we store your Personal information
AppsNovaTech will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.
Unless otherwise legally required or agreed, the data, which are stored by you on our systems as part of the Service, will remain stored as long as you have an account with us, but you can delete them at any time.
If you wish to have any Personal information removed from our databases, you can have it removed via your AppsNovaTech account or using interface of the Sites or Services (where applicable).
9. Your rights
9.1 What are your rights
If it is provided by applicable law, you have a right of access to your Personal information as processed by AppsNovaTech under this Policy.
If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.
If it is provided by applicable law, you also have the right to:
request erasure of your Personal information;
request the restriction of the processing of your Personal information;
object to the processing of your Personal information if it is provided by applicable law.
AppsNovaTech will honour any such requests or objections as required under applicable law.
To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.
9.2 How can you exercise your rights
To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact AppsNovaTech (see Section 11 hereof).
If you are not satisfied with how AppsNovaTech processes your Personal information, please let us know and we will investigate your concern. If you are not satisfied with AppsNovaTech’s response, you have the right to make a complaint to the competent data protection authority.
10. Updates to this Policy
This Policy may be subject to amendments. AppsNovaTech shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.
AppsNovaTech undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site (e.g. via a pop-up or web banner) prior to such changes taking effect, and you may also be notified via other channels (e.g. by email) if you have provided us with your contact details.
11. Questions and Suggestions
We welcome your questions or suggestions concerning implementation of or amendments to this Policy. To contact us please use this e-mail adress: firstname.lastname@example.org. You can also use this form to exercisese your rights or report any inaccuracies in your Personal information or protest its processing.
Date of publication: 01.04.2018