Last Updated: November 1, 2021

This Privacy Policy describes the collection and processing of information about you that can directly or indirectly identify you (the “Personal Data”) carried out by the mobile app “NaviCY”.

We are committed to safeguarding privacy of our users and other persons concerned. Please read this Privacy Policy carefully before starting using NaviCY to better understand NaviCY approaches to the processing of your Personal Data.

This Privacy Policy covers the following issues:

  • What Personal Data do we collect?
  • How do we process your Personal Data?
  • When can we share your Personal Data?
  • Transfer of Personal Data
  • How long do we retain your Personal Data?
  • What rights do you have?

We may update this Privacy Policy from time-to-time to keep it in conformity with the relevant legislation, including the Regulation of the European Parliament and of the Council (EU) 2016/679 (the “GDPR”), and to ensure the high level of privacy protection. We will keep you informed about the changes to our Privacy Policy. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your Personal Data, we will request your consent or your renewed consent (in case it was obtained previously).

Contact Details of Data Controller:

Tel.: +357 97 792370

E-mail: [email protected]

WHAT PERSONAL DATA DO WE COLLECT?

We respect your privacy and aim to limit the Personal Data that we collect from you to the amount which is strictly necessary to fulfil the purposes of processing. Categories of Data that we process can be found in the following section.

HOW DO WE PROCESS YOUR PERSONAL DATA?

We use your Personal Data for the purposes and on the legal bases indicated below:

Purpose of the processing

Data

Legal basis for the processing

To identify you in the system and monitor your number of clicking the “Let’s go” button

Device ID

The number of clicking the “Let’s go” button

Terms of Use

To allow you to use location-related features of NaviCY

Current location

Your explicit consent which you provide in the settings of your device

To communicate with you

E-mail, or

Phone number, or

Any other information that you have made public in the messengers you used to contact us at the time of contacting us (name, photo, etc.)

Information that you provide us with when you contact us

Our legitimate interest in receiving communication from you and reacting to it and your interest in getting our response

To manage and optimise NaviCY users’ experience by improving our knowledge of our users

Information about the users’ experience provided by Google Analytics

Our legitimate interest in evaluating and creating statistics on the use of NaviCY and your interest in the NaviCY updates which will be tailored to your needs

We neither use automated decision-making nor refer to the automated profiling.

WHEN CAN WE SHARE YOUR PERSONAL DATA?

We do not share your Personal Data with third parties, except in response to valid requests by public authorities (e.g. a court or a government agency) or in other cases when we are required to share your Personal Data by legislation.

For the analytical purposes we can share a strictly limited amount of data which is necessary for the mentioned purposes with Google Analytics. Google Analytics is a web analytics service provided by Google, Inc, address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, California 94043, USA. Data processing by Google Analytics is conducted in accordance with Privacy Policy of Google Inc. which can be found via the link: https://policies.google.com/privacy?hl=en.

TRANSFER OF PERSONAL DATA

We store your Personal Data only on servers located within the European Union.

International data transfer only takes place with Google Analytics since Google Inc. uses cloud-based servers, most of which are located in the US. Data transfer to Google Inc. is GDPR compliant since it is based on the Standard contractual clauses (SCC) approved by the European Commission.

HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We retain your Personal Data for no longer than it is necessary to fulfill the purposes specified in the section “How do we process your Personal Data” or for a longer period to comply with our legal obligations, resolve disputes, establish and defend legal claims.

The retention period of data processed within the Google Analytics is 14 months. After this period the data will be automatically deleted.

INFORMATION ABOUT THE OBJECTS ON THE MAP

One of the features of NaviCY is the ability to explore objects on the map (the businesses, restaurants, shops, etc.) and getting reference information about them, including their names, addresses, office telephone numbers, etc. Information about the objects indicated in NaviCY aims to give you the information about the legal persons that offer certain services or products. Please contact us directly if you notice any Personal Data of natural persons while using NaviCY. We take all actions in our power to stop the processing of this data as soon as we receive such notification.

WHAT RIGHTS DO YOU HAVE?

Under the GDPR you have the following rights in relation to your Personal Data:

  • The right of access to your Personal Data meaning that you can receive a copy of the Personal Data that we hold about you, as well as other supplementary information.
  • The right to rectification of your Personal Data which is incomplete or inaccurate.
  • The right to erasure of your Personal Data meaning that you can ask us to delete or remove your Personal Data in certain circumstances. Note, that we can retain your Personal Data as necessary to comply with our legal obligations or resolve disputes. If we have no grounds to continue processing your Personal Data, we will delete or remove it and notify you about such deletion or removal.
  • The right to restrict processing of your Personal Data if (a) the accuracy of the Personal Data is contested by you, (b) the processing is unlawful and you oppose the erasure of the Personal Data, (c) we no longer need the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, and (d) you have objected to processing pending the verification whether the legitimate grounds override this.
  • The right to data portability. Please note that this right only applies to information that we processed based on your consent or Terms of Use.
  • The right to object to the processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to the processing on this ground. We will no longer processthe Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
  • Right to withdraw consent at any time where we are relying on the consent to process your Personal Data. If we have no other grounds for processing your Personal Data, after you send us a request to withdraw consent, we will stop processing your Personal Data that we were processing under your consent.
  • Right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes the relevant legislation.

You may exercise these rights by sending a relevant request to the e-mail indicated in the contact details. We will address your request as early as possible and no longer that within one month. Please note that this period may be extended by two further months where necessary, taking into account the complexity and number of the requests. In this case, we will inform you of the extension within one month of receipt of your request and will explain you the reasons for the delay.

Please note that if you request deletion of your Personal Data (3), restriction of Personal Data processing (4), object to Personal Data processing (6) or withdraw your consent to the processing of your Personal Data (7), we can no longer process your Personal Data, in particular your device ID. At the same time without access to your device ID we are technically unable to provide access to NaviCY, accordingly you will lose access to NaviCY without the right to a refund, unless otherwise expressly stipulated in the marketplace policies. If you wish to begin using NaviCY again, you will be re-submitting your Personal Data to us, and the request you previously submitted and implemented does not apply to such future processing.

AGE LIMITS

We do not knowingly collect or solicit your Personal Data to anyone under the age of 16 or knowingly allow such persons to use NaviCY. If you are under the age of 16, please do not provide any Personal Data to us. If we learn that we have collected Personal Data about a child under the age of 16, we will delete that Personal Data as soon as possible. If you believe that we might have any Personal Data from or about a child under the age of 16, please contact us at the e-mail indicated in the contact details.