01 August 2018
2. Information we collect
2.1 We do not collect any information which can identify Your or users of Your Devices, unless You voluntarily provide Us with such data (in particular, when communicating with Our support team, leaving feedback re Your experience with Nicola App). In particular, We do not collect Your name, e-mail, telephone number, any persistent online identifiers (like, advertising ID).
2.2 Please note that to enable the monitoring functionalities of Nicola App We shall need Your camera to be turned on (We shall ask for Your separate permission to turn on the camera). However, all the images or other data caught by the camera shall be processed solely on the Devices and shall not be sent to Our servers, i.e. We shall not, and are not able to, get access to such images and data. We shall get only the statistics data about usage of the Devices, i.e. We shall know that someone using Your Device was reading or playing games within a particular period of time, was visiting certain websites, was opening certain applications and etc. For the avoidance of doubt, We shall not have access to the screen of Your Device.
2.3 Except for statistics data about usage of the Devices, We shall collect the data on how You are using Nicola App. These data are needed to enable proper operation of Nicola App, in particular to identify and fix the problems You are facing when using Nicola App.
2.4 To enable operation of Nicola App We generate and assign a specific identifier to the statistics and usage data We collect, as defined in Clauses 2.2 and 2.3 above. This identifier is randomly generated by Our system, is specific for Nicola App (i.e. it is not the same across multiple applications, like advertising ID) and is not linked to a particular device. This identifier permits Us solely to identify that two events of using Nicola App belong to the same user, however does not let it possible to identify that user.
2.5 We may also collect other data about Your Devices that do not permit direct association with You or other individuals, such as the operating system, settings, language, wireless network, mobile network information, software and hardware attributes.
2.6 In case We start collecting data enabling identification of You or users of Your Devices, We shall first ask for Your express consent for such collection and further processing.
2.7 We do not collect personally identifiable information about Your online activities over time and across third-party websites or online services and therefore do not respond to Do Not Track (DNT) signals or other mechanisms that provide You the ability to exercise choice regarding the collection of such information.
3. Purposes of processing
- delivering the Services to You (including, maintaining and monitoring the proper operation of Nicola App, fixing any problems in its operation, dealing with Your enquiries, complaints and requests);
- ensuring and protecting the safety and security of Nicola App, protecting Our Intellectual Property Rights and other rights;
- conducting statistical and analytical surveys and researches, in particular for improving the Services and Your user experience.
3.2 In case You voluntarily provide Us with any personal data, We shall process these data solely for the purposes for which they were provided to Us and for no longer they are needed to fulfill such purposes.
4. Sharing of data
4.1 You agree that We may share Your data when this is needed for the purposes of processing with the following categories of recipients:
- the companies being in the same corporate group with Us;
- data storage providers;
- providers assisting Us with client support;
- any other providers assisting Us with delivering and improving the Services for You.
4.2 We may also share Your data when it is required by law and/or any regulatory authority. In such circumstances, We will expressly inform the third party of the confidential nature of the data shared.
4.4 All the third parties with which We share Your data only get the minimum amount of data that are reasonably required in order for them to provide their service to Us and therefore to You. The use of the shared information by such third parties is strictly limited to the purposes of processing outlined in Section 3 and is not permitted for any other purpose. All third parties with which We share Your data are required to protect such data in accordance with all relevant laws and regulations and in a manner similar to the way We protect the same.
4.5 We will not share Your data with third parties which are considered as not being able to provide its clients and potential client with the required level of protection.
5. Your rights
5.1 With respect to Your personal data We process (if any) You have the right:
- to obtain from Us the information regarding Our processing of Your personal data;
- to obtain from Us without undue delay the rectification of inaccurate personal data concerning You;
- to obtain from Us the erasure of Your personal data your ‘right to be forgotten’;
- to restrict Our processing of Your personal data, when it is permitted under applicable law;
- to obtain from Us Your personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller without any obstacle on Our side;
- to withdraw Your consent to Our processing of Your personal data (where We are relying on consent to process Your personal data) by sending Us an e-mail request;
- to lodge a complaint against Us with a supervisory authority for GDPR purposes – Cyprus Data Protection Commissioner’s Office.
6. Period of processing
6.1 We shall store Your personal data for no longer they are needed for the purposes for which You provided them to Us, unless You give Us Your explicit consent to process them for a longer period of time.
6.2 With respect to non-personal data We are not limited by any particular retention period.
8. Questions and complaints
8.2 If You consider that Our collection, usage, disclosure and/or storage of Your personal information violate any applicable data protection laws We are bound by, please refer Your complaints to firstname.lastname@example.org. We will consider them within reasonable time and provide You with an answer.