Privacy Policy  

==============

 

Last updated: May 06, 2020

 

This Privacy Policy describes Our policies and procedures on the collection,

use and disclosure of Your information when You use the Service and tells You

about Your privacy rights and how the law protects You.

 

We use Your Personal data to provide and improve the Service. By using the

Service, You agree to the collection and use of information in accordance with

this Privacy Policy.

 

Interpretation and Definitions  

==============================

 

Interpretation  

--------------

 

The words of which the initial letter is capitalized have meanings defined

under the following conditions. The following definitions shall have the same

meaning regardless of whether they appear in singular or in plural.

 

Definitions  

-----------

 

For the purposes of this Privacy Policy:

 

  * You means the individual accessing or using the Service, or the company,

    or other legal entity on behalf of which such individual is accessing or

    using the Service, as applicable.

 

    Under GDPR (General Data Protection Regulation), You can be referred to as

    the Data Subject or as the User as you are the individual using the

    Service.

 

  * Company (referred to as either "the Company", "We", "Us" or "Our" in this

    Agreement) refers to 4Tuna OÜ, Rävala pst 5 Tallinn Harjumaa 10143.

 

    For the purpose of the GDPR, the Company is the Data Controller.

 

  * Affiliate means an entity that controls, is controlled by or is under

    common control with a party, where "control" means ownership of 50% or

    more of the shares, equity interest or other securities entitled to vote

    for election of directors or other managing authority.

 

  * Account means a unique account created for You to access our Service or

    parts of our Service.

 

  * Website refers to https://www.2meters.app, accessible from

    [www.2meters.app](www.2meters.app)

 

  * Service refers to the Website.

 

  * Country refers to: Estonia

 

  * Service Provider means any natural or legal person who processes the data

    on behalf of the Company. It refers to third-party companies or

    individuals employed by the Company to facilitate the Service, to provide

    the Service on behalf of the Company, to perform services related to the

    Service or to assist the Company in analyzing how the Service is used. For

    the purpose of the GDPR, Service Providers are considered Data Processors.

 

  * Third-party Social Media Service refers to any website or any social

    network website through which a User can log in or create an account to

    use the Service.

 

  * Facebook Fan Page is a public profile named 2meters specifically created

    by the Company on the Facebook social network, accessible from

    <https://www.facebook.com/2metersapp/>

 

  * Personal Data is any information that relates to an identified or

    identifiable individual.

 

    For the purposes for GDPR, Personal Data means any information relating to

    You 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.

 

  * Cookies are small files that are placed on Your computer, mobile device or

    any other device by a website, containing the details of Your browsing

    history on that website among its many uses.

 

  * Device means any device that can access the Service such as a computer, a

    cellphone or a digital tablet.

 

  * Usage Data refers to data collected automatically, either generated by the

    use of the Service or from the Service infrastructure itself (for example,

    the duration of a page visit).

 

  * Data Controller , for the purposes of the GDPR (General Data Protection

    Regulation), refers to the Company as the legal person which alone or

    jointly with others determines the purposes and means of the processing of

    Personal Data.

 

 

Collecting and Using Your Personal Data  

=======================================

 

Types of Data Collected  

-----------------------

 

Personal Data  

~~~~~~~~~~~~~

 

While using Our Service, We may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to:

 

  * Email address

 

  * First name and last name

 

  * Usage Data

 

 

Usage Data  

~~~~~~~~~~

 

Usage Data is collected automatically when using the Service.

 

Usage Data may include information such as Your Device's Internet Protocol

address (e.g. IP address), browser type, browser version, the pages of our

Service that You visit, the time and date of Your visit, the time spent on

those pages, unique device identifiers and other diagnostic data.

 

When You access the Service by or through a mobile device, We may collect

certain information automatically, including, but not limited to, the type of

mobile device You use, Your mobile device unique ID, the IP address of Your

mobile device, Your mobile operating system, the type of mobile Internet

browser You use, unique device identifiers and other diagnostic data.

 

We may also collect information that Your browser sends whenever You visit our

Service or when You access the Service by or through a mobile device.

 

Tracking Technologies and Cookies  

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

 

We use Cookies and similar tracking technologies to track the activity on Our

Service and store certain information. Tracking technologies used are beacons,

tags, and scripts to collect and track information and to improve and analyze

Our Service.

 

You can instruct Your browser to refuse all Cookies or to indicate when a

Cookie is being sent. However, if You do not accept Cookies, You may not be

able to use some parts of our Service.

 

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on

your personal computer or mobile device when You go offline, while Session

Cookies are deleted as soon as You close your web browser. Learn more about

cookies: [All About Cookies](https://www.termsfeed.com/blog/cookies/).

 

We use both session and persistent Cookies for the purposes set out below:

 

  * Necessary / Essential Cookies

 

    Type: Session Cookies

 

    Administered by: Us

 

    Purpose: These Cookies are essential to provide You with services

    available through the Website and to enable You to use some of its

    features. They help to authenticate users and prevent fraudulent use of

    user accounts. Without these Cookies, the services that You have asked for

    cannot be provided, and We only use these Cookies to provide You with

    those services.

 

  * Cookies Policy / Notice Acceptance Cookies

 

    Type: Persistent Cookies

 

    Administered by: Us

 

    Purpose: These Cookies identify if users have accepted the use of cookies

    on the Website.

 

  * Functionality Cookies

 

    Type: Persistent Cookies

 

    Administered by: Us

 

    Purpose: These Cookies allow us to remember choices You make when You use

    the Website, such as remembering your login details or language

    preference. The purpose of these Cookies is to provide You with a more

    personal experience and to avoid You having to re-enter your preferences

    every time You use the Website.

 

  * Tracking and Performance Cookies

 

    Type: Persistent Cookies

 

    Administered by: Third-Parties

 

    Purpose: These Cookies are used to track information about traffic to the

    Website and how users use the Website. The information gathered via these

    Cookies may directly or indirectly identify you as an individual visitor.

    This is because the information collected is typically linked to a

    pseudonymous identifier associated with the device you use to access the

    Website. We may also use these Cookies to test new advertisements, pages,

    features or new functionality of the Website to see how our users react to

    them.

 

For more information about the cookies we use and your choices regarding

cookies, please visit our Cookies Policy or the Cookies section of our Privacy

Policy.

 

Use of Your Personal Data  

-------------------------

 

The Company may use Personal Data for the following purposes:

 

  * To provide and maintain our Service , including to monitor the usage of

    our Service.

  * To manage Your Account: to manage Your registration as a user of the

    Service. The Personal Data You provide can give You access to different

    functionalities of the Service that are available to You as a registered

    user.

  * For the performance of a contract: the development, compliance and

    undertaking of the purchase contract for the products, items or services

    You have purchased or of any other contract with Us through the Service.

  * To contact You: To contact You by email, telephone calls, SMS, or other

    equivalent forms of electronic communication, such as a mobile

    application's push notifications regarding updates or informative

    communications related to the functionalities, products or contracted

    services, including the security updates, when necessary or reasonable for

    their implementation.

  * To provide You with news, special offers and general information about

    other goods, services and events which we offer that are similar to those

    that you have already purchased or enquired about unless You have opted

    not to receive such information.

  * To manage Your requests: To attend and manage Your requests to Us.

 

We may share your personal information in the following situations:

 

  * With Service Providers: We may share Your personal information with

    Service Providers to monitor and analyze the use of our Service, to

    contact You.

  * For Business transfers: 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.

  * With Affiliates: We may share Your information with Our affiliates, in

    which case we will require those affiliates to honor this Privacy Policy.

    Affiliates include Our parent company and any other subsidiaries, joint

    venture partners or other companies that We control or that are under

    common control with Us.

  * With Business partners: We may share Your information with Our business

    partners to offer You certain products, services or promotions.

  * With other users: when You share personal information or otherwise

    interact in the public areas with other users, such information may be

    viewed by all users and may be publicly distributed outside. If You

    interact with other users or register through a Third-Party Social Media

    Service, Your contacts on the Third-Party Social Media Service may see

    Your name, profile, pictures and description of Your activity. Similarly,

    other users will be able to view descriptions of Your activity,

    communicate with You and view Your profile.

 

Retention of Your Personal Data  

-------------------------------

 

The Company will retain Your Personal Data only for as long as is necessary

for the purposes set out in this Privacy Policy. We will retain and use Your

Personal Data to the extent necessary to comply with our legal obligations

(for example, if we are required to retain your data to comply with applicable

laws), resolve disputes, and enforce our legal agreements and policies.

 

The Company will also retain Usage Data for internal analysis purposes. Usage

Data is generally retained for a shorter period of time, except when this data

is used to strengthen the security or to improve the functionality of Our

Service, or We are legally obligated to retain this data for longer time

periods.

 

Transfer of Your Personal Data  

------------------------------

 

Your information, including Personal Data, is processed at the Company's

operating offices and in any other places where the parties involved in the

processing are located. It means that this information may be transferred to —

and maintained on — computers located outside of Your state, province, country

or other governmental jurisdiction where the data protection laws may differ

than those from Your jurisdiction.

 

Your consent to this Privacy Policy followed by Your submission of such

information represents Your agreement to that transfer.

 

The Company will take all steps reasonably necessary to ensure that Your data

is treated securely and in accordance with this Privacy Policy and no transfer

of Your Personal Data will take place to an organization or a country unless

there are adequate controls in place including the security of Your data and

other personal information.

 

Disclosure of Your Personal Data  

--------------------------------

 

Business Transactions  

~~~~~~~~~~~~~~~~~~~~~

 

If the Company is involved in a merger, acquisition or asset sale, Your

Personal Data may be transferred. We will provide notice before Your Personal

Data is transferred and becomes subject to a different Privacy Policy.

 

Law enforcement  

~~~~~~~~~~~~~~~

 

Under certain circumstances, the Company may be required to disclose Your

Personal Data if required to do so by law or in response to valid requests by

public authorities (e.g. a court or a government agency).

 

Other legal requirements  

~~~~~~~~~~~~~~~~~~~~~~~~

 

The Company may disclose Your Personal Data in the good faith belief that such

action is necessary to:

 

  * Comply with a legal obligation

  * Protect and defend the rights or property of the Company

  * Prevent or investigate possible wrongdoing in connection with the Service

  * Protect the personal safety of Users of the Service or the public

  * Protect against legal liability

 

Security of Your Personal Data  

------------------------------

 

The security of Your Personal Data is important to Us, but remember that no

method of transmission over the Internet, or method of electronic storage is

100% secure. While We strive to use commercially acceptable means to protect

Your Personal Data, We cannot guarantee its absolute security.

 

Detailed Information on the Processing of Your Personal Data  

============================================================

 

Service Providers have access to Your Personal Data only to perform their

tasks on Our behalf and are obligated not to disclose or use it for any other

purpose.

 

Analytics  

---------

 

We may use third-party Service providers to monitor and analyze the use of our

Service.

 

  * Google Analytics

 

    Google Analytics is a web analytics service offered by Google that tracks

    and reports website traffic. Google uses the data collected to track and

    monitor the use of our Service. This data is shared with other Google

    services. Google may use the collected data to contextualise and

    personalise the ads of its own advertising network.

 

    You can opt-out of having made your activity on the Service available to

    Google Analytics by installing the Google Analytics opt-out browser add-

    on. The add-on prevents the Google Analytics JavaScript (ga.js,

    analytics.js and dc.js) from sharing information with Google Analytics

    about visits activity.

 

    For more information on the privacy practices of Google, please visit the

    Google Privacy & Terms web page: <https://policies.google.com/privacy>

 

Email Marketing  

---------------

 

We may use Your Personal Data to contact You with newsletters, marketing or

promotional materials and other information that may be of interest to You.

You may opt-out of receiving any, or all, of these communications from Us by

following the unsubscribe link or instructions provided in any email We send

or by contacting Us.

 

We may use Email Marketing Service Providers to manage and send emails to You.

 

  * Mailchimp

 

    Mailchimp is an email marketing sending service provided by The Rocket

    Science Group LLC.

 

    For more information on the privacy practices of Mailchimp, please visit

    their Privacy policy: <https://mailchimp.com/legal/privacy/>

 

GDPR Privacy  

============

 

Legal Basis for Processing Personal Data under GDPR  

---------------------------------------------------

 

We may process Personal Data under the following conditions:

 

  * Consent: You have given Your consent for processing Personal Data for one

    or more specific purposes.

  * Performance of a contract: Provision of Personal Data is necessary for the

    performance of an agreement with You and/or for any pre-contractual

    obligations thereof.

  * Legal obligations: Processing Personal Data is necessary for compliance

    with a legal obligation to which the Company is subject.

  * Vital interests: Processing Personal Data is necessary in order to protect

    Your vital interests or of another natural person.

  * Public interests: Processing Personal Data is related to a task that is

    carried out in the public interest or in the exercise of official

    authority vested in the Company.

  * Legitimate interests: Processing Personal Data is necessary for the

    purposes of the legitimate interests pursued by the Company.

 

In any case, the Company will gladly help to clarify the specific legal basis

that applies to the processing, and in particular whether the provision of

Personal Data is a statutory or contractual requirement, or a requirement

necessary to enter into a contract.

 

Your Rights under the GDPR  

--------------------------

 

The Company undertakes to respect the confidentiality of Your Personal Data

and to guarantee You can exercise Your rights.

 

You have the right under this Privacy Policy, and by law if You are within the

EU, to:

 

  * Request access to Your Personal Data. The right to access, update or

    delete the information We have on You. Whenever made possible, you can

    access, update or request deletion of Your Personal Data directly within

    Your account settings section. If you are unable to perform these actions

    yourself, please contact Us to assist You. This also enables You to

    receive a copy of the Personal Data We hold about You.

  * Request correction of the Personal Data that We hold about You. You have

    the right to 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 and

    there is something about Your particular situation, which makes You want

    to object to our processing of Your Personal Data on this ground. You also

    have the right to object where We are processing Your Personal Data for

    direct marketing purposes.

  * 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.

  * Withdraw Your consent. You have the right to withdraw Your consent on

    using your Personal Data. If You withdraw Your consent, We may not be able

    to provide You with access to certain specific functionalities of the

    Service.

 

Exercising of Your GDPR Data Protection Rights  

----------------------------------------------

 

You may exercise Your rights of access, rectification, cancellation and

opposition by contacting Us. Please note that we may ask You to verify Your

identity before responding to such requests. If You make a request, We will

try our best to respond to You as soon as possible.

 

You have the right to complain to a Data Protection Authority about Our

collection and use of Your Personal Data. For more information, if You are in

the European Economic Area (EEA), please contact Your local data protection

authority in the EEA.

 

Facebook Fan Page  

=================

 

Data Controller for the Facebook Fan Page  

-----------------------------------------

 

The Company is the Data Controller of Your Personal Data collected while using

the Service. As operator of the Facebook Fan Page

<https://www.facebook.com/2metersapp/>, the Company and the operator of the

social network Facebook are Joint Controllers.

 

The Company has entered into agreements with Facebook that define the terms

for use of the Facebook Fan Page, among other things. These terms are mostly

based on the Facebook Terms of Service: <https://www.facebook.com/terms.php>

 

Visit the Facebook Privacy Policy <https://www.facebook.com/policy.php> for

more information about how Facebook manages Personal data or contact Facebook

online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road,

Menlo Park, CA 94025, United States.

 

Facebook Insights  

-----------------

 

We use the Facebook Insights function in connection with the operation of the

Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized

statistical data about Our users.

 

For this purpose, Facebook places a Cookie on the device of the user visiting

Our Facebook Fan Page. Each Cookie contains a unique identifier code and

remains active for a period of two years, except when it is deleted before the

end of this period.

 

Facebook receives, records and processes the information stored in the Cookie,

especially when the user visits the Facebook services, services that are

provided by other members of the Facebook Fan Page and services by other

companies that use Facebook services.

 

For more information on the privacy practices of Facebook, please visit

Facebook Privacy Policy here: <https://www.facebook.com/full_data_use_policy>

 

Your California Privacy Rights (California's Shine the Light law)  

=================================================================

 

Under California Civil Code Section 1798 (California's Shine the Light law),

California residents with an established business relationship with us can

request information once a year about sharing their Personal Data with third

parties for the third parties' direct marketing purposes.

 

If you'd like to request more information under the California Shine the Light

law, and if you are a California resident, You can contact Us using the

contact information provided below.

 

California Privacy Rights for Minor Users (California Business and Professions

Code Section 22581)  

==================================================================================================

 

California Business and Professions Code section 22581 allow California

residents under the age of 18 who are registered users of online sites,

services or applications to request and obtain removal of content or

information they have publicly posted.

 

To request removal of such data, and if you are a California resident, You can

contact Us using the contact information provided below, and include the email

address associated with Your account.

 

Be aware that Your request does not guarantee complete or comprehensive

removal of content or information posted online and that the law may not

permit or require removal in certain circumstances.

 

Links to Other Websites  

=======================

 

Our Service may contain links to other websites that are not operated by Us.

If You click on a third party link, You will be directed to that third party's

site. We strongly advise You to review the Privacy Policy of every site You

visit.

 

We have no control over and assume no responsibility for the content, privacy

policies or practices of any third party sites or services.

 

Changes to this Privacy Policy  

==============================

 

We may update our Privacy Policy from time to time. We will notify You of any

changes by posting the new Privacy Policy on this page.

 

We will let You know via email and/or a prominent notice on Our Service, prior

to the change becoming effective and update the "Last updated" date at the top

of this Privacy Policy.

 

You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this

page.

 

Contact Us  

==========

 

If you have any questions about this Privacy Policy, You can contact us:

 

  * By email: info@2meters.app

 

  * By visiting this page on our website: <https://www.2meters.app/imprint>

Свяжитесь с нами!

arrow&amp;v

© 2020 by 4Tuna OÜ