Privacy Policy

This Privacy Policy outlines how we collect, store, utilize, and handle the information you provide or we gather through our Services and mobile application. By using our mobile application or signing up for it, you acknowledge and consent to this Privacy Policy and the processing of your data, including your Personal Information, as described in this Policy. If you do not agree to the terms outlined in this document, we kindly request that you refrain from using our mobile application and its services.

 

1 Definitions

"Policy" refers to this Privacy Policy.

"We," "our," or "us" refers to SIA "VAlet", a company located at Ventspils šoseja 43B, Jūrmala, Latvia, and any of our affiliates.

"You" or "your" refers to you as an individual user of our mobile application and/or services.

"Mobile Application" or "App" refers to our mobile application through which this Policy is accessible.

"Services" refers to the services we provide to you as described in the Terms.

"Terms" refers to our Terms of Service.

"Personal Information" means, unless otherwise defined by applicable law, information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular user or household. This Policy does not apply if you cannot be identified (e.g., when Personal Information has been aggregated and anonymized).

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2 What Data We Collect and How We Do That

First and foremost, we want to assure you that we have never sold and will not sell your Personal Information.

When you interact with our mobile application, use our Services, or contact us directly, we collect and process your Personal Information. The methods we employ to collect this information can be broadly categorized as follows:

Information You Provide to Us Directly

1. When you utilize certain features of our mobile application, we may request that you provide Personal Information directly to us. For instance, when creating an account, you will be asked to provide your email address, home address, and name. Additionally, if you contact us or provide feedback, we may collect information from those interactions. In order to access our removal Services, we will require your name, alias, email address, phone number, and date of birth.

Information We Collect Automatically

 

Similar to most online services, we may automatically gather certain information about the devices you use to access our mobile application and Services. As described below, we may collect and analyze the following:

(i) Device information, such as IP addresses, unique device identifiers, screen resolution, time zone, operating system, device make and model.

1. (ii) Information pertaining to your interactions with our mobile application and Services, including referring and exit web pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed (along with the order of those pages), statistical data about the usage of our mobile application and Services, duration of time spent on specific pages, date and time of usage, frequency of use, error logs, and similar information. We may employ third-party analytics, advertising, and marketing services and technologies (such as Google Analytics, Facebook Ads, Google Ads, Microsoft Ads, etc.) to aid in the collection of this data. The service providers collect this information directly and use it to evaluate your usage patterns and trends.

 

3 How We Use Personal Information

We utilize your Personal Information for various purposes, as it is essential for us to provide you with the mobile application and its Services. Failure to process your Personal Information may result in the inability to access certain features or aspects of the Services.

The following outlines the purposes for which we use your Personal Information:

1. Operation and Delivery of Services:

   • Ensuring the proper functioning of our mobile application and delivering the requested Services.

   • Providing support and assistance, including resolving technical or other issues related to the mobile application and Services.

2. Service Enhancement and Optimization:

   • Improving our services and mobile application, testing and developing new features, and conducting analysis to enhance your user experience and provide more efficient tools and features.

   • Analyzing and aggregating data to generate statistics, including aggregated analytics and reports used for internal purposes.

3. Advertising:

   • Displaying advertisements tailored to your interests.

4. Relationship Management and Communication:

   • Managing our relationship with you and communicating important information.

   • Sending operational and transactional communications, such as notifications about changes to the Services, security updates, or assistance with using the Services.

   • Requesting surveys and collecting feedback.

   • Providing information you have requested or that is required to be sent to you.

   • Promoting engagement with the Services and mobile application.

5. Marketing Communications:

   • Sending marketing communications that may be of interest to you, including information about new services, newsletters, product offers, and promotions. You can opt out of receiving such communications by using the "unsubscribe" link provided in the email or by contacting our support team.

6. Security and Fraud Prevention:

   • Preventing, detecting, and reporting crime, ensuring network and information security, mitigating security risks, and detecting and preventing fraudulent or malicious activities.

7. Legal Obligations and Rights:

   • Fulfilling our legal duties, responsibilities, and obligations, and complying with applicable laws and regulations.

   • Exercising our rights as outlined in the Terms or other agreements with you.

8. Contractor and Successor Disclosure:

   • Disclosing information to contractors on a need-to-know basis or to successors following a restructure.

We may aggregate and/or de-identify the information collected through the mobile application and Services. De-identified and/or aggregated data may be used for various purposes, including research and marketing, without limitation.

 

4 Disclosure of Your Personal Information

There may be circumstances where it becomes necessary to disclose your Personal Information to third parties. We may disclose your Personal Information to the following:

1. Data Broker and People-Search Sites:

   • In order to provide you with our Services, we may need to disclose your information to data brokers and people-search sites. This allows us to locate your records on these platforms and request their removal on your behalf.

2. Third-Party Service Providers and Partners:

   • We may disclose your Personal Information to third-party service providers and partners who assist us in delivering the Services and maintaining the mobile application.

   • This includes providers who support the delivery of specific features related to the Services and mobile application.

   • We may also engage providers of analytics and measurement services (e.g., Google Analytics), technical infrastructure services (e.g., Microsoft Azure, Google Cloud, Amazon AWS).

   • Additionally, we may collaborate with advertising, marketing, or promotional partners (e.g. Facebook Ads, Google Ads, LinkedIn Ads, Reddit Ads, Microsoft Ads) to promote our Services and mobile application.

3. Legal and Regulatory Requirements:

   • We may disclose your Personal Information to law enforcement agencies, government bodies, courts, or other third parties when required by applicable laws.

4. Professional Advisors:

   • In certain circumstances, we may disclose your Personal Information to professional advisors, such as lawyers or auditors, as necessary for the professional services they provide to us.

5. Contractors:

   • We may disclose your Personal Information to contractors who have entered into binding privacy and confidentiality obligations that are at least as protective as those outlined in this Privacy Policy, as required by applicable laws.

6. Other Parties with Your Consent:

   • We may disclose your Personal Information to other individuals or entities when we have obtained your explicit consent to do so.

Please note that we take measures to ensure that any third parties with whom we share your Personal Information will handle it in accordance with applicable privacy laws and regulations.

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5 Data Retention

We follow different data retention practices based on the type of information involved. Certain information can be deleted at your discretion, while other data is automatically removed. There are situations where business and legal requirements necessitate the extended retention of specific data for distinct purposes. The reasons for retaining data for longer periods may include:

1. Service Availability:

   • To ensure the continuous availability of the Services and Website to you and other users.

2. Fraud Prevention and Security:

   • To protect you, other individuals, and ourselves from fraudulent activities, abuse, illegal actions, and unauthorized access. This includes situations where fraud is suspected.

3. Compliance and Financial Regulations:

   • To comply with tax regulations, anti-money laundering laws, financial regulations, or for accounting purposes.

4. Dispute Resolution:

   • To facilitate the resolution of disputes should they arise.

5. Legal Obligations and Enforcement:

   • To meet and fulfill our legal obligations under applicable laws, regulations, legal processes, enforceable governmental requests, or when required to enforce the Terms of Service. This may include investigations into potential violations.

6. Customer Support and Feedback:

   • If you have engaged in direct communication with us, such as through a customer support channel or by providing feedback or bug reports.

Please be assured that we handle retained data in accordance with relevant laws and regulations, ensuring the protection of your privacy and rights.

 

6. Information Regarding Children

Our mobile application and Services are not intended for children who are 18  years old or younger. We do not knowingly collect Personal Information from children who are 18 years old or younger. If you have any concerns about the privacy of your child while using our Services or if you believe that your child who is under the age of 18 has provided Personal Information on our mobile application, please contact us at  support@getprivacyapp.com . We will promptly delete any such Personal Information from our records or, if necessary, seek verifiable consent from a parent or legal guardian to retain such information within a reasonable timeframe.

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7. Security Measures

We prioritize the security of user data with measures such as secure storage, access controls, employee training, and regular updates to address vulnerabilities.

 

8 Third-Party Links and Services

Our mobile application and Services may include links to third-party websites, apps, and other services. If you choose to utilize these external sites or features, please be aware that you may be disclosing your information not only to those third parties but also to their users and the general public, depending on how their services operate. We do not assume responsibility for the content or privacy practices of such third-party websites or services. The collection, use, and disclosure of your information on these sites will be governed by their respective privacy policies, not by this Privacy Policy. We encourage you to review the privacy statements of each service  you use.

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9 Modifications

We reserve the right, at our sole discretion, to modify or revise this Privacy Policy at any time by posting the updated Policy on our mobile application. It is advisable to regularly check the most current version.

By continuing to use our mobile application and Services after any modifications or updates have been made, you indicate your acceptance of the revised Privacy Policy. If you do not agree with the changes, please refrain from using our mobile application and Services.

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10 Privacy-Related Inquiries

If you have any concerns regarding the use of your Personal Information or if you have inquiries about the privacy aspects of our Services or mobile application, please feel free to contact us at support@getprivacyapp.com. We are here to assist you with any privacy-related matters you may have.

 

11. California Privacy Notice

Although SIA "VAlet" does not fall under the category of a business to which the California Consumer Privacy Act (CCPA) applies, we strive to voluntarily comply with the key principles of the CCPA. This California Privacy Notice for residents of California supplements the information provided in this Privacy Policy. This section applies exclusively to individuals who reside in the State of California.

Categories of Personal Information Collected:

Under the CCPA, the Personal Information we may collect or have collected from you in the past twelve months falls into the following categories:

- Identifiers, such as name, alias, address, phone numbers, email address, or IP address.

- Characteristics of protected classifications under California or US federal law, such as age.

- Commercial information, such as subscription purchase history.

- Geolocation data, such as the location of your device.

- Audio, visual, electronic, or similar information, including communication with us via phone or other means.

- Inference data, such as information about your preferences.

- Sensitive Personal Information, such as driver's license or state identification card number, and account credentials.

We use and disclose sensitive Personal Information solely for the limited purposes permitted by the CCPA and not for inferring consumer characteristics.

Categories of Sources of Personal Information:

In the past twelve months, we have collected Personal Information from California residents from the sources described in the section titled "What Data We Collect and How We Do That."

Categories of Third Parties to Whom We Disclose Personal Information:

We disclose Personal Information to the categories of third parties described in the section titled "To Whom We May Disclose Your Personal Information."

Categories of Personal Information Disclosed for a Business Purpose:

Personal Information that may have been disclosed about consumers for a business purpose in the past twelve months falls into the categories established by the CCPA, including identifiers, commercial information, geolocation data, internet or other electronic network activity information, and audio, visual, electronic, or similar information. For more information, please refer to the section titled "How We Share Your Personal Information."

Business and Commercial Purposes for Collecting Personal Information:

We use the Personal Information we collect for the business and commercial purposes described in the section titled "How We Use Personal Information." We may also use Personal Information relating to California residents for specific business purposes listed in the CCPA.

Categories of Personal Information Shared:

As stated in this Policy, we use online advertising services from third parties on the mobile application. When interacting with the Services or mobile application, the following categories of Personal Data may be shared with certain third-party providers for online or "cross-context" behavioral advertising, as defined by the CCPA: identifiers, commercial information, and internet network activity information.

Your Rights:

Under the CCPA, you have the following rights:

- The right to request disclosure of the Personal Information we have collected about you.

- The right to request further information about our collection, use, disclosure, or sale of your Personal Information, including categories of Personal Information collected, sources of information, categories of information shared or sold, and the purpose of such sharing.

- The right to request correction of inaccurate Personal Information.

- The right to request deletion of your Personal Information, subject to certain circumstances.

- The right to opt out of the sale or sharing of certain Personal Information for cross-context behavioral advertising.

- The right to request limitations on the use of your Sensitive Personal Information.

- The right to designate an authorized agent to exercise these rights on your behalf.

To exercise any of these rights, please contact us at support@getprivacyapp.com .

 

12. Virginia Privacy Notice

Although the Virginia Consumer Data Protection Act (VCDPA) currently does not apply to SIA "VAlet" due to its scope limitation, we aim to voluntarily adhere to the key principles of the VCDPA. This Privacy Notice for residents of Virginia supplements the information provided in this Privacy Policy. This section applies exclusively to individuals who reside in the Commonwealth of Virginia.

The VCDPA requires us to provide the following information:

Categories of Personal Data Processed:

Please refer to the section titled "California Privacy Notice" under the subsection "Categories of Personal Information Collected" for the categories of Personal Information processed by us. However, please note that Sensitive Personal Information, such as driver's license numbers or account credentials, is not considered within the scope of the VCDPA.

Purpose of Processing Personal Information:

The purposes for processing Personal Information are described in the section titled "How We Use Personal Information". Additionally, we process Personal Information for targeted advertising.

Sale of Personal Information: We do not sell Personal Information.

Profiling and Significant Effects:

We do not process Personal Information for the purpose of profiling that leads to decisions with significant legal or similar effects concerning consumers.

Sharing of Personal Information:

While we do not share Personal Information with third parties as defined in the VCDPA, we do disclose Personal Information to our service providers, contractors, and other processors as described in the section titled "To Whom We May Disclose Your Personal Information".

Rights of Virginia Residents:

Subject to the exclusions and limitations outlined in the VCDPA, as a Virginia resident, you have the following rights related to your Personal Information:

- The right to request the deletion of your Personal Information, unless its retention is reasonably necessary for compliance with the VCDPA.

- The right to request the correction of inaccurate Personal Information, considering the nature and purpose of its processing.

- The right to confirm whether we are processing your Personal Information and to access it.

- The right to obtain a copy of the Personal Information you previously provided to us in a portable format.

- The right to opt out of the processing of your Personal Information for targeted advertising purposes. Please note that this choice does not affect non-personalized marketing or contextual advertising based on the content and predicted audience of the website you are browsing.

To exercise your consumer rights under the VCDPA or to appeal our decision regarding your request, you can contact us at support@getprivacyapp.com.

Non-Discrimination:

We will not discriminate against you for exercising any of your consumer rights under the VCDPA.

 

13. Nevada Privacy Notice

We do not sell "covered information" as defined under Chapter 603A of the Nevada Revised Statutes.