Privacy Policy

Last Update: Feb 19th 2024

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.

This Privacy Policy can be printed for reference by using the print command in the settings of any browser.

1. Introduction

1.1 SEAMOBI TECH PTE LTD(hereinafter referred to as "We" or "us" or "our") takes user privacy very seriously, and We are committed to protecting and respecting user privacy. This value drives all of the decisions We make, including how We collect, use, share, store and respect Users' personal information.

1.2 We are both the data controller and the data processor who determines the purposes and methods of the data processing in relation to your personal data collected by us and is responsible for the data processing in relation to your use of our services. If you have any questions, you can contact us at the following contact@seamobitech.com


2. Information we process

There are several categories of information that can be processed.

2.1 Functional information and information that you submit

We process the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.

2.2 Information That Is Processed Automatically

On the basis of your permission we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our App (Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices). Some integrated advertising or analytics tools launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements. Processing information through automatic data processing technologies starts automatically once you allow our App to track your activity. You can withdraw your permission at any time.

We may process some information about your device and your user behaviour on the ground of our legitimate interest. This information falls within categories of data described above in Subsection “Information That Is Processed Automatically”, it is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We use this information to improve our App and give our users the best experience.

Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties.


3. Type and place of data processing

3.1 Processing Methods

We take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data. The processing of the data is carried out with the help of computers and/or IT-supported tools, according to organizational procedures and modes that are strictly related to the stated purposes. In addition to us, in some cases the data may be accessible to certain types of persons involved in the operation of this application (administration, sales, marketing, legal, system administration) or to external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communication agencies), which we may designate as data processors. An updated list of these parties may be requested from us at any time.

3.2 Legal basis for processing

We may process Personal Data relating to You if one of the following applies:

You have given their consent for one or more specific purposes. Note: Under some legislations We may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

processing is necessary for compliance with a legal obligation to which We are subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;

processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

In any case, We 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.

3.3 Location

The data will be processed in our offices and in any other place where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve the transfer of the User's data to a country other than his or her own. To find out more about the place of processing of such transferred data, you may consult the section containing details about the processing of personal data.

You also have the right to learn about the legal basis of data transfers to a country outside the European Union or to an international organization governed by public international law or established by two or more countries, such as the United Nations, and about the security measures we take to protect your data.

If such a transfer takes place, you can find out more by reviewing the relevant sections of this Policy or by contacting us using the information provided in the Contact Us section.

3.4 Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between You and us shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests pursued by us within the relevant sections of this Policy or by contacting us.

We may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.


4.The purposes of the processing

4.1 The Data concerning the User is collected to allow us to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Platform services and hosting, Handling payments， and Contacting the user.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.


5. Detailed information about the processing of personal data

Personal information is collected for the following purposes and services:

5.1 Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Trackers to identify You or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.

Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, You may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this Policy.

5.2 Platform services and hosting

These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to us – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.

Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

App Store (Apple Inc.)

This Application is distributed on the App Store, a platform for the distribution of mobile apps, provided by Apple Inc..

By virtue of being distributed via this app store, Apple collects usage and diagnostics data and share aggregate information with us. Much of this information is processed on an opt-in basis.

You may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.https://support.apple.com/en-us/HT202100

Personal Data processed: Usage Data.

5.3 Handling payments

Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, You are requested to provide their payment details and personal information directly to such payment service providers.

This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Payments processed via the App Store (Apple Inc.)

This Application uses a payment service provided by Apple Inc. that allows us to offer the purchase of the app itself or in-app purchases. Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App store.

personal data processed: payment info; Usage Data.

5.4 Contacting the user

By filling in the contact form with their Data, the User authorizes these Applications to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: country; email address; first name; last name.


6. The rights of You

6.1 You may exercise certain rights regarding their Data processed by us.

6.2 In particular, You have the right to do the following:

Withdraw your consent at any time. You have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing of your Data. You have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

Access your Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. You have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of their Data. In this case, We will not process their Data for any purpose other than storing it.

Have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Data from us.

Receive your Data and have it transferred to another controller. You have the right to receive your Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

Lodge a complaint. You have the right to bring a claim before your competent data protection authority.

6.3 Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, You may object to such processing by providing a ground related to your particular situation to justify the objection.

You must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether We are processing Personal Data for direct marketing purposes, You may refer to the relevant sections of this Policy.

6.4 How to exercise these rights

Any requests to exercise User rights can be directed to us through the contact details provided in this Policy. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.


7.Cookie Policy

We may use cookies, or similar technologies on our Apps to store information locally on your device(s) (hereinafter referred to as “Cookies”). Cookies may be used to track the browsing activities of visitors on our Apps, count the number of unique visitors, and facilitate better use of our Apps and/or services. Please refer to our Cookies Policy for further information. Cookies will be saved to your device(s) after You have accepted our Cookies Policy which will be presented to You when You required to log in to your account on a social platform. Such Cookies will be deleted when You log out. PLEASE NOTE THAT You may become unable to use our services or functions that rely on Cookies if You decline such Cookies.


8.Children's Privacy

In order to download, install, access or use the App, you must be eighteen (18) years of age or older. All users who are minors in the jurisdiction in which they reside (generally under the age of 18) must have the permission of, and be directly supervised by their parent or guardian to use the App, so if you are between the ages of thirteen (13) and seventeen (17) years and you wish to use, download, install, access the App, before doing so you must: (a) assure and confirm (if needed) that your parent or guardian have read and agree (get your parent or guardian’s consent) to this Agreement prior to you using the App; (b) have the power to enter a binding contract with us and not be barred from doing so under any applicable laws.

Parents and guardians must directly supervise any use of the App by minors.


9. More information about data collection and processing

9.1 Legal action

The User's Personal Data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that We may be required to reveal personal data upon request of public authorities.

9.2 Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

9.3. System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

9.4 Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the beginning of this Policy.

9.5 How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

9.6 Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to You via any contact information available to us. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, We shall collect new consent from the User, where required.


11.Security safeguards

We takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Services in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.


12.Do we actually "sell" personal data?

We does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, We does not sell your data.

However, we have disclosed some categories of personal data we collect to the third parties for business purpose as explained under “Detailed information on the processing of Personal Data”.

To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at contact@seamobitech.com to exercise your right to withdraw your consent on sharing your personal data with third parties.


13. Information for Californian consumers

13.1 This part of the Policy integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates.

13.2 The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018", and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in this privacy policy.

13.3 This part of the Policy uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

13.4 Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this Policy.

13.5 Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information and internet information.

We will not collect additional categories of personal information without notifying you.

13.6 How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

13.7 How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this Policy.

13.8 Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

13.9 Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

13.10 Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this Policy.

13.11 What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this Policy), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

13.12 Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;

in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose: for sales, the personal information categories purchased by each category of recipient; and for disclosures for a business purpose, the personal information categories obtained by each category of recipient. The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

13.13 The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

13.14How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this Policy.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;

describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

13.15 How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.


14. Information for Users residing in Brazil

14.1 This part of the Policy integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates.

14.2 The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados". For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in this privacy policy.

14.3 This part of the Policy uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

14.4 The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

your consent to the relevant processing activities;

compliance with a legal or regulatory obligation that lies with us;

the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;

studies conducted by research entities, preferably carried out on anonymized personal information;

the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;

the exercising of our rights in judicial, administrative or arbitration procedures;

protection or physical safety of yourself or a third party; the protection of health – in procedures carried out by health entities or professionals;

our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this Policy.

14.5 Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this Policy.

14.6 Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this Policy.

14.7 Your Brazilian privacy rights, how to file a request and our response to your requests

You have the right to:

obtain confirmation of the existence of processing activities on your personal information;

access to your personal information;

have incomplete, inaccurate or outdated personal information rectified; obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;

obtain information on the possibility to provide or deny your consent and the consequences thereof;

obtain information about the third parties with whom we share your personal information;

obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;

obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;

revoke your consent at any time;

lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;

oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;

request clear and adequate information regarding the criteria and procedures used for an automated decision; and

request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

14.8 How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this Policy, or via your legal representative.

14.9 How and when we will respond to your request

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an ACCESS or PERSONAL INFORMATION processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

14.10 How and when we will respond to your request

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;

when the transfer is necessary to protect your life or physical security or those of a third party;

when the transfer is authorized by the ANPD;

when the transfer results from a commitment undertaken in an international cooperation agreement;

when the transfer is necessary for the execution of a public policy or legal attribution of public service;

when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.


15.Contact

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at contact@seamobitech.com