Privacy Policy

1. 1. Consent: means any freely given, specific, informed, and unambiguous indication of the Data Subject's wishes by which the person, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. 2. Cookies: means are small pieces of data stored on the user's device.
3. 3. Data Controller: means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the way any personal data are, or are to be, processed.
4. 4. Data Processor or Service Providers: means a natural or legal person, public authority, agency, or other body (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
5. 5. Personal Data: means any information relating to an identified or identifiable natural person (the "Data Subject") via an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
6. 6. Processing: means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
7. 7. Recipient: means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not.
8. 8. Usage Data: means the data collected automatically either generated using the Service or from the Service infrastructure itself.
9. 9. User: means the individual visiting and using our Service. The User corresponds to the Data Subject.

2.1 The main principles on which the Data Controller bases the processing of personal data are: (i) legality; (ii) good faith and transparency; (iii) minimizing data and limiting the purposes and retention period; (iv) accuracy; (v) integrity and confidentiality; (vi) accountability.

2.1.1 In order for the Processing to be lawful, the Data Controller processes your Personal Data based on your Consent or on other legitimate grounds, when necessary, in the context of a contract or with an expressed intention to conclude such.

2.1.2 The principle of good faith and transparency requires the Data Controller to ensure that all information and communication related to the Processing of your Personal Data is easily accessible and understandable, using clear and unambiguous wording.

2.1.3 Compliance with the third principle, namely to minimize data and limit the purposes and period of storage by the Data Controller, is ensured by collecting only those data that are absolutely necessary for the purposes and activities of the Data Controller and its compliance with the legal requirements.

2.1.4 The principle of accuracy requires that all Personal Data processed by the Data Controller be accurate and kept up to date.

2.1.5 In accordance with the principle of integrity and confidentiality, the Data Controller processes your Personal Data in a way that ensures an appropriate level of security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

2.1.6 The principle of accountability comes to ensure before you that everything the Data Controller does regarding your Personal Data is subject to control and the Data Controller is responsible for it.

2.2 The Data Controller ensures that all persons involved in the Personal Data processed by it are familiar with the basic principles set out here, this Policy, as well as the applicable legal requirements regarding the protection of your Personal Data.

3.1 While using our Service, we may ask you to provide us with certain Personal Data. The categories of Personal Data may include, but are not limited to:

• First name and last name
• Country and/or country code
• Email address
• Phone number (if applicable)
• Habitual residence (if applicable)
• Payment data and information about payments
• Cookies and Usage Data – device type, device ID and/or IP address
• Communications with us and their content

3.2 The Data Controller receives your Personal Data in the following ways: (i) personally from you, when you visit and start using the Service; (ii) from other sources like PayPro, Google, Apple, Huawei, etc. but only as supplementary information; and (iii) through so-called Cookies and other unique identifiers.

3.3 We will not sell your data to third parties, but we may share it with our partners (Google, Apple, Huawei, PayPro and more) who help us provide our services and/or improve user-facing features.

3.4 Please note that when you provide your credit or debit card number on the Service, this Personal Data is automatically redirected to our Service Providers. We do not process this Personal Data ourselves.

3.5 Where required by law, we store the data and information we collect from you when you are unauthenticated separately from any Personal Data that directly identifies you.

3.6 In addition, some of our Service have optional features which, if used by you, require us to collect additional information to provide such features.

4.1 Once provided, your Personal Data will be processed on the following grounds: (i) Consent; (ii) performance of a contract; (iii) compliance with a legal obligation; and (iv) legitimate interests pursued by us as Data Controller.

4.2 By pressing the "Subscribe", "Grant", or "Next" buttons, you give us your prior, explicit, written, informed, freely given and unambiguous Consent for the Processing of your Personal Data for the purposes stated below.

4.3 You have the right to withdraw your Consent (to opt out) at any time. The withdrawal of the Consent shall not affect the lawfulness of the Processing carried out on any of the other grounds.

4.4 When you have consented to your Personal Data being processed for direct marketing and remarketing purposes, you have the right to object/opt out to this at any time.

5.1 The Data Controller processes your Personal Data and Usage Data for the following purposes:

• Provision and maintenance of the Service, including technical and security issue detection
• Tracking preferences and interests, sending information about Services and special offers
• Customer support, assistance, and solving problems
• Observance of legal obligations
• Protection of legitimate rights and interests of the Data Controller and third parties
• Transfer of Personal Data to competent authorities when required

5.2 The Processing of Personal Data for purposes other than those for which they were originally collected is also permitted when compatible with the original purposes.

6.1 The Data Controller will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

6.2 The Processing of your Personal Data will continue as follows: (i) incorrect or inaccurate data will be deleted within one (1) month; (ii) where processing is only based on Consent — until its withdrawal; (iii) for direct marketing — until your opt-out; (iv) for contract-based processing — until the final settlement and five (5) years thereafter.

6.3 The Data Controller makes regular checks on the Personal Data processed and stored, and proceeds with their deletion, destruction, or anonymization for statistical or research purposes.

7.1 Your Personal Data may be transferred to and processed on computers located outside of your jurisdiction. If you are located outside the United States and choose to use the Service, your Personal Data are received and processed in the United States, for which you have explicitly consented.

7.2 Depending on the case, we transfer or may give access to some of your Personal Data to the following categories of Recipients: (i) companies from the group; (ii) Service Providers — payment providers, marketing partners, IT and hosting providers; (iii) public government bodies where required by law.

7.3 The Data Controller may entrust the processing of your Personal Data only to Data Processors who provide sufficient guarantees of appropriate technical and organizational measures.

7.4 If the Data Controller merges with or is acquired by another company, your Personal Data will likely be disclosed to advisers and prospective purchasers.

Under certain circumstances, we may be required to disclose your Personal Data by law or in response to valid requests by public authorities. We may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation, subpoena, or court order
• Protect and defend the rights or property of the Data Controller
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of our employees, Users, Children, or the public
• Respond to an emergency involving the danger of death or serious bodily harm
• Protect ourselves against legal liability

9.1 Cookies. We use cookies and similar tracking technologies to track the activity on our Service. Types of cookies we use: Necessary, Preference, Statistic, Security, and Advertising Cookies. You can control cookies through your browser settings.

9.2 Usage Data. We may also collect Usage Data that your browser sends whenever you visit our Service, including IP address, browser type, pages visited, time and date of visit, and other diagnostic data.

9.3 Analytics Service Providers: Google Analytics, Firebase, Adjust, and AdMost help us understand how users use our Service. Advertising Service Providers: AdMob by Google, Meta Audience Network, Google Ads, A4G, ReklamUp, Mailchimp, and AppLovin.

9.4 Payment Service Providers: Our Service uses payment providers adhering to PCI-DSS standards, including Huawei AppGallery, Apple Store, Google Play, and PayPro Global.

9.5 Others: We use behavioral remarketing, conversion tracking (Facebook Pixel), and Freshdesk for customer support. For iOS users utilizing push notifications or the AquAI feature, relevant encrypted credentials are processed temporarily and deleted upon disabling.

Our Service may contain integrations or links to other websites that are not operated by us. We strongly advise you to review the Privacy Policy of every website or service you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

11.1 The Data Controller undertakes to apply appropriate technical and organizational measures to ensure an appropriate level of security of your Personal Data.

11.2 We apply security controls including: access control to equipment, data carrier control, storage control, consumer control, access control to data, communication control, data entry control, transfer control, recovery, reliability, and integrity measures.

11.4 We follow generally accepted standards to protect Personal Data. However, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we do not guarantee absolute security.

The Data Controller respects your privacy no matter where your habitual residence is. We provide you with the right to request access, correction, completion, update, and/or erasure of your Personal Data. We will aim to address all requests within a reasonable time while being compliant with our high standards for Personal Data protection and applicable legislation.

13.1 Although the main establishment of the Data Controller is in California (USA), this Privacy Policy is made to comply with the GDPR. Rights available to EU residents include:

• Right of access — obtain confirmation and access to your Personal Data
• Right to rectification — correct inaccurate or incomplete Personal Data
• Right to erasure ("to be forgotten") — request deletion of your Personal Data
• Right to restriction of Processing — restrict processing without deletion
• Right to data portability — receive your data in a structured, machine-readable format
• Right of objection — object to processing for direct marketing at any time

13.2 You may exercise the above rights by submitting a written application to the Data Controller by mail or e-mail. Requests are addressed within one (1) month of receipt, free of charge.

13.5 In case of a violation of your rights under GDPR you have the right to refer to the competent supervisory authority at your habitual place of residence within six (6) months of the violation discovery.

We may update this Privacy Policy from time to time. The updated version will be posted on the Service. Please review it periodically because any and all amendments and/or supplements will become effective when posted. Under certain circumstances we will provide notice to you of material changes and, where required by applicable law, we will obtain your consent.