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APPGYVER PRIVACY POLICY

Last updated November 2019.

AppGyver (“we”, “us”, “our”) is committed to protecting your privacy and to comply with applicable data protection and privacy laws. This Privacy Policy explains what kind of information AppGyver collects in connection with its services, including the AppGyver website, and how such information is processed.

This Policy applies to processing of personal data collected when using the AppGyver website or other AppGyver services. Please acknowledge that this Privacy Policy applies to personal data that is processed by or for AppGyver in cases where AppGyver acts as a controller to the personal data. To the extent AppGyver processes personal data as a data processor on behalf of AppGyver’s company customer (the company with whom you have an employment, a commission or other contractual relation), the processing of your personal data is not controlled by us but the relevant company customer. In such cases, our processing of personal data is subject to the agreement entered into between us and the relevant company customer, and you should turn to such entity for any details of the processing of your personal data.

Moreover, this Privacy Policy does not apply to any links to any third parties’ websites and/or services which you may encounter when you use the AppGyver services. The collection and use of any personal data by any third parties will be subject to such third parties’ applicable privacy policies. We encourage you to carefully familiarize yourself with the privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any such third parties.

By using AppGyver website and/or other AppGyver services and/or by submitting personal data to AppGyver, you express your agreement to the processing of your personal data in the manner provided for in this Policy. If you do not agree with this Policy, please do not use AppGyver website, AppGyver services or provide AppGyver with your personal data.

The Data We Collect

We collect your personal data typicallywhen you register into our services. Below are examples of the categories ofdata collected.

  • Technical Information
    Certain technical information is normally collected as a standard part of your use of our website or services. Such information includes, for example, your IP-address, access times, the website you linked from, pages you visit, the links you use, the banners and other content you viewed, information about your computer (or other terminal device) and other such technical information your browser provides us with or as may be otherwise collected in connection with certain services. When you use our services or otherwise interact with us, certain additional information may also be transmitted to AppGyver. Please also see the section "Use of Cookies and Web Beacons" below.
  • Information you provide to AppGyver
    When you register for our services, we may ask you to provide us with information such as your name, (email) addresses, as well as user names, passwords and other such credentials that are used to authenticate users and to validate their actions or that may be needed to provide you with the products and services you have requested or to communicate with you. We may also collect other information you provide, such as language preferences, your consents, preferences and feedback, and other such information you provide us with. Please note that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data.
  • Your transactions with us
    We collect or ask for information relating to your use of our services and your other interactions with us. Such information may include, for example, details of the queries or requests you have made, the products and services provided (including delivery details), financial details (including payments made, credit card details, billing address, credit checks and other such financial information), details of agreements between you and AppGyver, records of contacts and communications, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points. Certain services may involve the processing of your location data.
  • Other data sources
    We may use certain publicly available sources, in accordance with applicable law, to collect or update personal data.

The Purposes and Legal Grounds for Processing

AppGyver processes your personal data for the purposes described in this Policy and/or any additional service specific privacy information. Please note that one or more purposes may apply simultaneously.

  • Provision of products and services
    We may use your personal data to fulfill your requests or as otherwise may be necessary to perform or enforce the contract between you and AppGyver, to ensure the functionality and security of our services, to identify you and to prevent and investigate fraud and other misuses.
  • Development of services
    We may use your personal data to develop our products and/ or services. However, for the most part we only use aggregate and statistical information in the development of our products and services. We may also use your personal data to personalize our offering and to provide you with service more relevant to you, for example, to make recommendations and to display customized content and advertising in our websites. We may combine personal data collected in connection with your use of AppGyver service with other personal data we may hold about you, except where such personal data was collected for a different purpose. We may create aggregate and statistical information based on your personal data.
  • Communicating with you and marketing
    We may use your personal data to communicate with you, for example, to provide information relating to our services you are using or to contact you for customer satisfaction queries. We may use your personal data for marketing or research purposes, for example, to conduct market research and we may, in accordance with applicable law, contact you to inform you of new products, services or promotions we may offer. AppGyver does not disclose your personal data to any other company for marketing purposes without your prior consent.
  • Legal Grounds for processing
    The legal grounds for processing your personal data are either compliance with the agreement entered into between us and you, our legitimate interest, compliance with legal obligations to which we are subject or your consent as further described in the examples below.

    - Contractual obligations: Processing of your personal data to certain extent is necessary to enable us to fulfil the agreement we have concluded with you. For example, when you subscribe to our services, it is necessary for us to process your personal data so that we can carry our contractual obligations so that you can use the relevant service.
    - Our legitimate interest: We process your personal data based on our legitimate interest in particular to develop our services and to analyse the use of our services, as well as for administrative purposes and to preventing and resolving possible misconduct.
    - Consent: Based on your consent, we can process your personal data to sending you direct electronic marketing.

    The provision of your personal data as described in this Privacy Policy is partially a contractual requirement. For example, when you subscribe to our services, you are required to provide us with certain personal data for processing purposes specified in this Privacy Policy. Failure to provide us personal data may prevent us from performing our contractual obligations, which may lead to you being unable to use our services.

Sharing Your Personal Data

Generally, we do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.

  • Consent
    We may share your personal data if we have your consent to do so. Some services may include sharing your personal data with other users of the service, for example services where users publish their own content.
  • Authorized third parties
    We may share your personal data with authorized third parties who process personal data for and on behalf AppGyver for the purposes described in this Policy. Such parties process your personal data as processors, and are not permitted to use your personal data for other purposes, and we require them to act consistently with this Policy and to use appropriate security measures to protect your personal data.

    In addition, we may disclose your personal data to a debt collection agency for purposes of debt collection, or to other service providers providing certain services to AppGyver, but only to the extent that the fulfilment of their tasks require the disclosure of personal data.
  • International transfers
    Our services may be provided using resources and servers located in various countries around the world. Therefore your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we take steps to ensure that there is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures. To learn more about the international transfers of personal data and the applied legal bases for such transfers, please contact us using the contact details specified below.
  • Mandatory disclosures
    We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies. We may also disclose and otherwise process your personal data in accordance with applicable law to defend AppGyver's legitimate interests, for example, in civil or criminal legal proceedings or to prevent and investigate fraud and other misuses.
  • Mergers and Acquisitions
    If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.

Data of Minors

AppGyver does not seek to collect any information from or engage in any transactions with persons under the age of 18. Our databases may nevertheless contain personal data of persons under the age of 18 due to the fact that it is not always possible to determine precisely the age of the user. Insofar as we ask you to ensure you are over 18, and we block the service from any person who is under 18 years of age. We will also make reasonable efforts to clear our databases of personal data relating to under age users.

AppGyver's policy is to request that minors (the legal age of majority and therefore the age of minors is determined by local law where you reside) do not make purchases or engage in other legal acts on our services without the consent of a parent or legal guardian, unless otherwise permitted by applicable law.

Data Quality

We take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out of date or otherwise incorrect or unnecessary personal data.

As certain services may allow you to manage your profile, we encourage you to access your personal data from time to time to ensure that it is correct and up-to-date. Please remember that it is your responsibility to provide us with correct details as well as to update the personal data you have provided us with in case of any changes.

Security

While there are always risks associated with providing personal data, whether in person, by phone, via the internet or otherwise, and no technology is completely safe or "tamper" or "hacker" proof, AppGyver takes appropriate technical and organizational information security measures to prevent and minimize such risks.

Such measures include the use of firewalls, secure servers, encryption, proper access rights management systems and processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your personal data against unauthorized use or disclosure. Where appropriate, we may also take backup copies and use other such means to prevent accidental damage or destruction to your personal data. If a particular part of AppGyver website supports online transactions, we will use an industry standard security measure, such as the one available through "Secure Sockets Layer" ("SSL"), to protect the confidentiality and security of online transactions.

Retention Time

The retention period of personal data depends on the data concerned and its purpose of use. We will retain personal data at least as long as they are needed for the execution of the purposes of processing specified in this Privacy Policy, such as for the performance of our contractual obligations. The retention periods are determined in accordance with the following criteria:

- Related personal data will be retained for as long as you are using our services and for a period of maximum of two years after that;
- Related personal data will be deleted when you withdraw your consent to certain processing or request the deletion of your personal data, unless we have another legal ground for processing for some or all data;
- Related personal data will be deleted when you object to the processing of your personal data for direct marketing purposes. In this case, however, we may keep the information regarding your objection to receiving direct marketing to ensure that your contact details will not be added to our posting list again;
- Statutory retention periods may also apply. For instance, the accounting regulation requires that any information included in the accounting materials are retained for six years.

Notwithstanding the foregoing retention periods, if a justified ground for retaining certain personal data for longer periods arise during the processing of your personal data (such as suspected malpractice), we may retain the related personal data for as long as they are necessary for the purposes of investigation and possible court proceedings.

In addition, certain pieces of your personal data may be retained by us in certain cases for an indefinite period. For example, if you have chosen to share a component that you have created on the AppGyver community marketplace, the component may include certain information on you that cannot be deleted even in cases where you have requested AppGyver to delete your personal data.

When personal data are no longer needed, the data is destroyed in a secure way or irrevocably anonymized.

Use of Cookies and Web Beacons

From time to time when you visit AppGyver website or AppGyver services, information may be placed on your computer to allow us to recognize your computer. This information is commonly in the form of a text file known as a "cookie". Cookies are small pieces of data stored on your computer's hard drive, rather than on the website. Typically, they enable collection of certain information about your computer, including your internet protocol (IP) address, your computer's operating system, your browser type and the address of any referring sites. Our use of cookies is intended to provide benefits to you, such as eliminating the need for you to enter your password frequently during a session. Cookies are also used for website traffic analysis and anonymous demographic profiling so that we may improve our services.

AppGyver may use so called web beacons (or "pixel tags") in connection with its website. However, we do not use them to identify individual users personally. Web beacons are typically graphic images that are placed on a website and they are used to count visitors to a website and/ or to access certain cookies. This information is used to improve our services. Web beacons do not typically collect any other information than what your browser provides us with as a standard part of any internet communication. If you turn off cookies, the web beacon will no longer be able to track your specific activity. The web beacon may, however, continue to collect information of visits from your IP-address, but such information will no longer be unique.

If you do not wish to receive cookies, or want to be notified before they are placed, you may set your web browser to do so, if your browser so permits. Please understand that if cookies are turned off, you may not be able to view certain parts of this site that may enhance your visit. Some of our business partners whose content is linked to or from this site may also use cookies or web beacons. However, we have no access to or control over these cookies.

Your Rights

In case you wish to know what personal data we hold about you or you wish to replenish, rectify, anonymize or delete any incomplete, incorrect or outdated personal data, or you wish us to cease processing your personal data for the purpose of sending promotional materials or direct marketing or for the performance of market research or on other compelling legal grounds, you may, as appropriate and in accordance with applicable law, exercise such rights by contacting us. In addition to the foregoing rights, you can contact us with your requests related to your right to data portability, and your other objections related to the processing of your personal data. We also respect your right to obtain the restriction of processing in accordance with the applicable data protection laws.

In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you. Please note especially that in case your subscription is connected to your employer's subscription, we may not be able to delete all personal data related to you due to obligations and commitments made towards your employer. We encourage you to use available profile management tools for the above purposes as such tools often provide you with direct access to your personal data and allow you to effectively manage it. To the extent the use of your rights is not possible though the profile management tools, please contact us by using the contact details below.

Please note that AppGyver may need to identify you and to ask for additional information in order to be able to fulfill your above request. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.

The Controller of Your Personal Data and Contact Details

AppGyver Oy, Merimiehenkatu 36 D 212, 00150 Helsinki, Finland shall be the controller of your personal data.You can contact us by sending paper post to the address specified above, or by email at privacy[at]appgyver.com.

Changes to This Privacy Policy

AppGyver may from time to time change this Privacy Policy or change, modify or withdraw access to this site at any time with or without notice. If this Privacy Policy is changed in a material, adverse way, AppGyver will post a notice advising of such change at the beginning of this Policy and on this site's home page for 14 days. We recommend that you re-visit this Privacy Policy from time to time to learn of any such changes to this Privacy Policy.