Last modified: November 2023
Opt-out options: DO NOT USE MY DATA
I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)
When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.
It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.
For the purposes of the GDPR, we are the data controller, unless otherwise stated.
IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE
Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request:
- - the categories of personal information that is processed;
- - the categories of sources from which personal information is obtained;
- - the purpose for processing of user personal data;
- - the list and categories of third parties with whom we may share your personal information;
- - the specific pieces of personal information that we might have obtained about a particular user provided that the data provided in the request is reliable enough and allows us to identify the user.
All about the categories of information, its sources and purposes of processing >>
Please mind that according to CCPA personal information does not include de-identified or aggregated consumer information.
How your information can be shared >>
Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.
If you do not want us to process your personal information any more please contact us via our “Contact Us” form available on the Website.
To submit a verifiable consumer request for access, portability or deletion of personal data please contact us via our “Contact Us” form available on the Website. Please include in the text of your request the wording "Your rights to maintain confidentiality in the state of California”.
When submitting a verifiable request, you should be ready to:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.
Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or different level or quality of services for you, if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.
SALE OF DATA
We do not sell any of your personal data to third parties.
II. INFORMATION WE PROCESS
There are several categories of information that may be processed when you access and/or use the Website.
We ask for and process the following information when you access and/or use the Website. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the Website and perform the requested services.
- – Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via our “Contact Us” form available on the Website. We collect, store and process it by our cloud storage provider (Amazon.com, Inc.). We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request and perform the requested services.
Information That Is Processed Automatically
When you access and/or use the Website, some information about your device and your user behavior may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest for improving the Website and giving our users the best experience.
We may use third-party automatic data processing technologies to analyze certain information sent by your device via the Website (advertising or analytics tools). Some of them may launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first time access the Website.
- Device Details. When you use a device (computer, mobile phone or tablet) to access the Website, some of the details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your device, which uniquely identify your device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.
What data may be processed:
- (a) Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, battery life, loading time, latency, framerate, device memory usage.
- (b) Information about the Internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser.
- (c) Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. “coffee shop”).
- (d) Device identifiers: Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices, user identifiers.
- Log file information. Log file information is automatically reported each time you make a request to access the Website. When you use the Website, analytics tools automatically record certain log file information, including time and date when you start and stop using the Website, and how you interact with the Website.
- Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.
Information provided automatically to advertising or analytics tools does not generally come to our control, therefore, we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility.
III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA
Our mission is to constantly improve the Website and provide you with new experiences. As part of this mission, we use your information for the following purposes:
- (a) To make our service available and ensure the efficient operation of the Website. We use functional information to provide you with all requested services and to ensure the efficient operation of the Website according to its intended purpose.
- (b) To improve, test and monitor the effectiveness of our Website. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our Website.
- (c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.
- (d) To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about your Website experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
IV. SHARING OF YOUR INFORMATION
Please note that while integrating external services we choose third parties that can assure they apply all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.
We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.
We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.
We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our services:
In case you want to learn more about the services and privacy options (including opt-out) please consult the correspondent websites and privacy policies.
The Website may contain links to third-party websites/services or you may access the Website from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from the Website, including the information or content contained within them.
We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:
- - as required by law;
- - when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- - in some cases, we may share your information with our affiliates, subsidiaries, contractors, business partners or other third parties who perform services on our behalf.
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or prominent notice on our Website of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
V. INTERNATIONAL DATA TRANSFERS
We work in the cross-border area and provide the Website to users around the world.
We and third-party organizations that provide automatic data processing technologies for the Website or our third-party partners may transfer processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.
By using the Website you agree that we may transfer your personal information to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.
We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information.
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.
VI. HOW LONG WE USE YOUR PERSONAL DATA
We generally retain your personal information for as long as is necessary for performing the functional service of the Website and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information.
However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.
VII. EXERCISING YOUR RIGHTS
Applicable data protection laws give you certain rights regarding your personal information. You have the following rights in relation to your personal information that was collected:
- Data Access and Portability. You can request copies of your personal information.
- Change or Correct Data. Where you cannot update data by yourself, you have the right to ask to correct, change, update or rectify your data.
- Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
- Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.
- Lodge a complaint. You can lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you infringes the GDPR.
To exercise any of the rights described above, you can contact us via our “Contact Us” form available on the Website. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.
If you are located in the European Union, you may address our representative when you have questions on privacy issues: Konrad Gutowski, privacy @ aiby.com.
VIII. HOW TO OPT OUT
You may prevent and/or manage the collection and processing of some Information related to your use of the Website following the instructions provided below. Note that it is applicable only with respect to the Information that is processed automatically.
Google Analytics. If you want to opt-out of being tracked by Google Analytics you can install and enable Google Analytics Opt-out Browser Add-on. Additionally, you can manage cookies and/or delete cookies already set by Google Analytics through your browser settings. Further information on Google Analytics’ data practices and relevant instructions can be found at https://support.google.com/analytics/answer/6004245 (see section ‘Information for Visitors of Sites and Apps Using Google Analytics’).
Bear in mind that if you choose to disable all cookies, this can affect the Website functions, some of the features that make the Website more efficient may not function.
The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.
Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.
If you have any questions about the security of the Website, you can contact us via our “Contact Us” form available on the Website.
X. CHILDREN’S PRIVACY
Our Website is not intended for children under the age of eighteen (18). Therefore, we do not knowingly collect or solicit any personal information from children under eighteen (18). No one under the age of eighteen (18) may provide any personal information to the Website. If you are under the age of eighteen (18), do not provide any information on the Website or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under the age of eighteen (18) without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under eighteen (18), please contact us.
XII. HOW TO CONTACT US
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