ACT ON CRISIS APPLICATION
Last updated: March 30, 2020
We are committed to protecting your privacy. It is important that You understand how We look after Your Personal Data and how We make sure that We meet our legal obligations to You under Data Protection Law.
If You have any questions in relation to this policy or generally how Your Personal Data is processed by Us please contact Us by email email@example.com.
Interpretation and Definitions
5. The words of which the initial letter is capitalized have meanings defined under the following conditions.
6. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
You means the natural person accessing or using the Application.
Under GDPR, You can be referred to as the Data Subject.
For the purpose of the GDPR, the Company is the Data Controller which means that we are responsible for looking after it. We will use Your Personal Data fairly, lawfully and in a transparent manner, and in accordance with the applicable Data Protection Law.
Application means the software program provided by the Company downloaded by You on any electronic device, named Act On Crisis/AOC.
Personal Data is any information that relates to an identified or identifiable natural person. For the purposes for GDPR, Personal Data means any information relating to natural person such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
Device means any device that can access the Application such as a computer, a mobile phone or a digital tablet.
GDPR means General Data Protection Regulation 2016/679.
Data Protection Law refers to applicable data protection legislation including, but not limited to, the GDPR.
Collecting and Using Your Personal Data
Types of Data Collected
8.We collect and process Personal Data when you interact with our Application, and in the following ways described below.
9.When You choose an option to have 1on1 talk with a professional, We ask You to provide Us with certain personally identifiable information that can be used to book a meeting, contact or identify You. This information may include, but is not limited to:
Message You wish to leave to the professional prior to the meeting
Confirmation that You are above 18 years old
country of residence
selected language in which You wish to talk with professional
selected time slot for meeting
10. When You make a complaint or submit a query to Us in relation to the Application, You will provide Us with relevant data including data about Your experience and difficulties with the Application.
11. Usage Data, i.e. data about how you use the Application, is collected automatically when using the Application so that we can analyse how the Application is used by users. This helps Us to improve the Application and We do not use it for any other purpose. Although Usage Data does not identify You by name, and we will not attempt to identify You by name or to use the information to make decisions about You, the information is associated with a unique identifier, namely Your device ID, therefore You are identifiable and the information constitutes Personal Data for the purposes of Data Protection Law. It is important for Us to be able to distinguish different users by using this unique identifier so that We can analyse how individual users use the Application. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), Your Device ID, the type of mobile device You use, Your mobile operating system, information about the Application being opened, Information about the region in which the Application is opened and other diagnostic data.
Purposes and Legal Basis for processing Personal Data
12. Data Protection Law requires Us only to process Your personal data if We satisfy one of the legal bases of processing set out in the GDPR, for each purpose of processing.
13. The Company may use Personal Data for the following purposes:
To arrange Your meeting with Your selected professional and contact or identify You. Processing is necessary for the performance of a contract between You and Us.
To maintain and improve the Application by collecting and processing Usage Data. The processing is necessary for Our legitimate interest to maintain and improve the Application.
To reply to and deal with complaints and queries relating to the Application. The processing is necessary for Our legitimate interest to provide users of the Application with good customer service.
Who do we share Your Personal Data with?
14. We may share Your Personal Data with Our trusted services providers when they provide services to Us, or to You on behalf of Us and under Our instructions. We will control and shall remain responsible for the use of Your Personal Data at all times.
Developers and administrators of the Application;
Providers of data security, data management, website hosting, cloud hosting, storage solutions, software as a service (SaaS) and other IT services;
Providers of Application analytics services;
Our staff who need to access Your data to perform their functions and who are bound by confidentiality obligations;
Professionals: when You share personal information in order to book a professional, only your name, submitted message dedicated to chosen professional, language you wish to talk in and country you will be talking from will be shared with them via email.
Other users of Application: when you participate in community chats, only your submitted messages will be shared with others.
We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
We may also disclose Your Personal Data as required by law, including laws outside Your country of residence, to comply with a court order or to comply with other legal or regulatory requirements, for example, to courts, law enforcement authorities, and regulatory agencies such as data protection supervisory authorities.
Retention of Your Personal Data
17. The Company will also retain Usage Data for internal analysis purposes. We will only retain Usage Data for a period of 3 years after We collect it. This is so that We can understand how You use the Application over time. After 3 years, We will aggregate the data with data of other users so that it no longer relates specifically to You or any other individual.
Transfers outside of the European Economic Area
19. Google LLC, which provides Us with Google services such as Google Analytics, is based in the US and certain data may be transferred outside EEA. Google LLC participates in the Privacy Shield. You can learn more about Privacy Shield here - https://www.privacyshield.gov/.
Security of Your Personal Data
20. When handling Your personal data, We take appropriate measures reasonably designed to protect Your information from unauthorised access, loss, misuse, disclosure, alteration or destruction. Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect Your Personal Data, We cannot guarantee the security of Your data transmitted to the Application; any transmission is at Your own risk. Once we have received Your information, We will use strict procedures and security features to try to prevent unauthorised access.
Your Rights in relation to Your Personal Data
21.The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
Request access to Your Personal Data. You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing, unless we are able to demonstrate that our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.
You have the right to ask Us to restrict or block the processing of your Personal Data that We hold about You in some cases.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
What if You have a complaint?
24. If You have any concerns regarding Our processing of Your Personal Data, or are not satisfied with Our handling of any request made by You, or would otherwise like to make a complaint, You have the right to lodge a complaint with the competent data protection authority of Your country of residence (in Lithuania, that is the State Data Protection Inspectorate. You can find contact details of the State Data Protection Inspection here: https://vdai.lrv.lt/en/).
Links to Other Websites
26. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.