Last Updated: 11/11/2022
SPNA s. r. o., ID no. 53702727, with its registered seat at Tallerova 4, 811 02 Bratislava, Slovakia (“we”).
We are creators of Best Nine application (“App”) and by this Privacy policy, we would like to inform you about how we process your personal data through this App.
We recommend that you read this information carefully. If you have any questions, you can contact us at any time using the contact details below. As we are company located in European union, the processing of personal data is governed by Regulation (EU) 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 (“GDPR”).
A. TABLE OF CONTENTS
Our goal is to ensure maximum transparency in the processing of your personal data. We have divided this document into the following sections:
- the personal data processed, including examples of the data processed (part B);
- the purposes of the processing of personal data, as well as the legal bases and periods of processing (part C);
- sharing of personal data (part D);
- Your rights in data processing and how to exercise them (part E);
- the possibility to lodge a complaint (part F); and
- amendments to this document (part G).
B. PERSONAL DATA PROCESSED
When you use our App, personal data may be processed. As we want to be as transparent as possible, we divided personal data that we process about you as personal data controller into these categories:
- Identifiers, such as uid, device's advertising identifier, ip address.
- Contact info, such as e-mail address only if a user contacts customer support.
- Purchases information, such as payments related solely to the App.
- User content, such as instagram username and publicly available content associated with the account, customer support requests.
- Usage data, such as app launches, taps, scrolling information, or other information about how the user interacts with the app.
- Diagnostics data, such as crash logs, timezone id, language, ios version or other technical information about your device.
- Customer support data, such as identification of issue, messages between you and us, attached files and additional information, information about solution of your issues.
- Marketing data, such as marketing ID, device information, information about viewed ads. Marketing data is collected only if ads are displayed in the app.
Please, do not use our App to upload any sensitive information about you, such as health data, genetic data, biometric data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning sexual orientation.
The App is not designated for children. By downloading or installing the App, you declare that you are older than 13 years old and are solely responsible for any damage or loss that we may suffer because of his untruthful declaration.
C. PURPOSES OF THE PROCESSING OF PERSONAL DATA
We process your personal data as a data controller for the processing purposes, legal bases and periods set out below.
In this section, we describe the processing of your data related to the provision of our App.
Processing of personal data in our App
C.1 Provision of App functionalities
We primarily process personal data to provide you with our App and to treat you as a customer, when you download the App and agree with our Terms & Conditions, or when you order our paid services connected with App. Personal data is processed to authenticate you as the user, enable our features, customize what you see and use, perform customer support, ensure functionality of our App. We also use your personal data to customize the App to your preferences and save them. This enables us to make it easier for you to browse the App and to customize the App for you in terms of location, language options, device of choice, etc. As part of this, we may also send you messages about the conclusion and performance of a contract, new product and service releases, payment reminders or approvals, etc.
For this purpose, we process these categories of personal data:
- Identifiers, Contact info, Purchases information, User content, Usage data, Diagnostics data, Customer support data.
The legal basis for this processing is the performance of the contract between you and us and the need to take steps at your request before entering the contract.
The data are processed for the duration of the mutual relationship and for the period necessary for the performance of the obligations under such contract and for a maximum of three years from the last activity in the App.
C.2 Improving our App
We may process data about how you use our App, what features you use most, other analytics, effectiveness of features etc., so that we can better understand how you use them and trends in their use and then improve and further develop them to your satisfaction. We also use personal data for training and improving our App via AI tools.
For this purpose, we process these categories of personal data:
- Identifiers, Purchases information, User content, Usage data, Diagnostics data, Customer support data.
The legal basis for this processing is our legitimate interest in improving our App, and the data is processed for a maximum of 3 years from the date of collection.
C.3 Internal records, statistics, and protection of our rights
We may process your data for the purposes of keeping internal records within our company, recording subscriptions made, producing statistical reports, protecting our rights and legal claims, and to ensure that only you use our App in accordance with their terms.
For this purpose, we process these categories of personal data:
- Identifiers, Contact info, Purchases information, Usage data, Diagnostics data, Customer support data.
The legal basis for this processing is our legitimate interest in keeping internal records, statistics, and the protection of our rights. The data is processed until a maximum of 10 years after the last activity in the App (or longer in the event of a dispute), or for a maximum of 5 years after the collection of personal data if no contract has been concluded.
C.4 Support and promotion of our products and services
We may process the data you provide when you review, register, or purchase our products and services to inform you about our other products, services or promotions, news, announcements, new releases, etc.
For this purpose, we process these categories of personal data:
- Identifiers, Purchases information, User content, Usage data, Diagnostics data, Customer support data.
The legal basis for this processing is our legitimate interest in supporting and promoting our products and services. The data is processed until a maximum of 2 years after the termination of the contract concluded with you.
C.5 Fulfilling legal obligations
We may also process your personal data in order to comply with our legal obligations, particularly in the area of tax and accounting. At the same time, we need to be prepared to provide cooperation to state authorities if we are required to do so by law.
For this purpose, we process these categories of personal data:
- Identifiers, Contact info, Purchases information, User content, Usage data, Diagnostics data, Customer support data.
The legal basis for this processing is the fulfillment of our legal obligations. The data is processed for the period required by law.
C.6 Third-Party advertising
If you give us your consent via pop-up screen, we will share your personal data with third-party advertisers which will be named when giving consent. We will only process personal data and share it with third-parties, when the pop-up screen is in the App. If there is no pop-up screen, no third-party advertising is done. Those third-parties will display you ads according to data shared about you.
For this purpose, we process these categories of personal data:
- Identifiers, Usage data, Diagnostics data, Marketing data.
The legal basis for this processing is your freely given consent (via pop-up). You may withdraw this consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. The data is processed for the period of mutual relationship, maximum up to 1 year from giving consent.
D. SHARING OF PERSONAL DATA
We may share your personal data with other companies in our group who also process data in accordance with this document and help us with better analytics.
At the same time, we may share personal information with third parties who help us provide our App to you. These parties act as our data processors and process personal data for us, within the scope of our processing purposes set out above. Those data processors may be:
- A company helping us with marketing activities located in the Czech republic;
- App Toro s.r.o. providing App support, development and cloud storage;
- A company providing web scraping technology;
In addition to this, if we process your personal data for fulfilling legal obligations, we may share your personal data with certain third parties as data controllers for this purpose where we are obliged to do so under applicable legislation (in particular, administrative authorities, police authorities and judicial authorities). Similarly, we may be obliged to share your data with persons who claim to have been harmed by your conduct.
We hereby confirm that any third party with whom our App shares personal data, such as analytics tools, advertising networks and third-party SDKs, as well as any parent, subsidiary or other related entities that will have access to personal data, will provide equal protection of personal data as stated in this Privacy policy.
Where we share your personal data with controllers and processors in third countries (outside the EEA), we only do so where there is a decision by the European Commission that a particular country outside the EEA provides an adequate level of data protection, including where controllers or processors have adopted additional data protection measures such as Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SCCs).
E. YOUR RIGHTS IN PROCESSING AND THE POSSIBILITY OF EXERCISING THEM
Just as we have rights and obligations when processing your personal data, you have certain rights when processing your personal data as set out in the following paragraphs. You have the right to (i) request access to your personal data; (ii) withdraw your consent; (iii) request rectification of your personal data; (iv) request erasure of your personal data; (v) request restriction of the processing of your personal data; (vi) request portability of your personal data; (vii) object to the processing of your personal data; or (viii) lodge a complaint with the relevant supervisory authority.
In all matters related to the processing of your personal data, whether it is a question, the exercise of rights, sending a complaint to our hands, etc., you can contact us at bestnine@apptoro.agency.
Your request will be processed without undue delay, at most within 1 month. In exceptional cases, in particular due to the complexity of your request, we are entitled to extend this period by a further 2 months. We will, of course, always inform you of any such extension and the reason for it.
You also have the right to lodge a complaint with the supervisory authority as described below.
E.1 Right of access
You have the right to obtain confirmation from us as to whether or not we are processing your personal data.
If we process your personal data, you also have the right to request access to information about the purpose and scope of the processing, the recipients of the data, the duration of the processing, the right to rectification, erasure, restriction of processing and to object to the processing, the right to lodge a complaint with a supervisory authority and the sources of the personal data (this information is already provided in this document).
You can also ask us for a copy of the personal data we process. We provide the first copy free of charge; further copies may be subject to a fee. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.
E.2 Right to withdraw consent
You have the right to withdraw your consent to the processing of personal data at any time. However, the withdrawal of consent does not affect the lawfulness of the processing prior to such consent, nor does it lead to the termination of the processing of personal data that has already been anonymized.
E.3 Right to repair
You have the right to request us to correct inaccurate personal data concerning you. Depending on the purpose of the processing, you may also have the right to have incomplete personal data completed, including by providing an additional declaration.
E.4 Right to erasure (right to be forgotten)
You have the right to request the deletion of your personal data in cases where:
- we no longer need your personal data for the purposes for which it was collected or processed;
- you withdraw the consent on the basis of which the personal data was processed and there is no further reason for processing it:
- you object to processing and there are no other overriding reasons for processing, or you object to processing for direct marketing purposes;
- personal data is processed in violation of the law.
However, you cannot exercise this right where the processing is necessary for compliance with our legal obligations or tasks entrusted to us in the public interest or for the establishment, exercise, or defense of legal claims.
E.5 Right to restriction of processing
You have the right to request restriction of the processing of your personal data in cases where:
- you contest the accuracy of your personal data; in this case, you may request a restriction of processing until the accuracy of the personal data has been verified;
- the processing is contrary to the law and instead of erasure, you request a restriction of the processing of personal data;
- we no longer need your personal data for the purposes for which it was collected or processed, but you require it for the establishment, exercise, or defense of legal claims;
- you have objected to the processing of your personal data; in this case, you may request a restriction of processing until it is verified that our legitimate interests prevail.
E.6 Right to portability
You have the right to obtain a copy of your personal data that we process by automated means on the basis of your consent or for the performance of a contract. We will transmit this data in a commonly used and machine-readable format to you or to a controller designated by you, if technically feasible. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.
E.7 Right to object
You have the right to object to the processing of your personal data that we process on the basis of our legitimate interest. We will stop processing your data if there are no other overriding reasons for processing or if the processing is not necessary for the establishment, exercise, or defense of legal claims or if you object to processing for direct marketing purposes.
F. RIGHT TO FILE A COMPLAINT
In addition to the possibility of exercising your rights with our company, you can also file a complaint with the relevant supervisory authority, which is the Office for Personal Data Protection located at Hraničná 12, 820 07 Bratislava, Slovakia.
G. CHANGES TO THIS INFORMATION
This processing information is effective as of 11/11/2021. We are entitled to change this processing information from time to time, so please check it regularly. We will post any changes to this document on our website.