Privacy Policy
Effective date: July 31, 2021
This Privacy Policy explains how Azure Aurora Limited (“Company” or “we” or “us”) collects, stores, uses, transfers and shares Personal Data from our users (“you”) in connection with: The “Cycle Tracker” Mobile Application;
We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you specified through the App pop-ups, and presenting you with a new version of this Privacy Policy. Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to accept changes to the Privacy Policy explicitly. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.
Personal Data and information we collect from you
Personal Data you provide us directly
General Information:
Date of birth;
Health and Well-being. When you use the App, you may choose to provide personal information about your health and well-being such as:
Weight;
Body temperature;
Menstrual cycle dates;
Various symptoms related to your menstrual cycle and health;
Other information about your health (including sexual activities), well-being, and related activities, including personal life (collectively, “Personal Data”).
You also may give us the ability to import into the App Personal Data about your health and activities from third-party services such as Apple HealthKit and Google Fit. Such imported Personal Data may include sports activities, weight, calories burnt, heartbeat rate, number of steps/distance traveled, and other data about your health. In order for us to process any Personal Data under this category we will explicitly ask your consent through the register procedure.
Personal Data we may collect automatically. When you access or use the App, we may automatically collect the following information:
l Device Information
l Hardware model;
l Information about the operating system and its version;
l Unique device identifiers (e.g. IDFA);
l Mobile network information;
l Device storage information.
l Location Information:
l IP address;
l Time zone;
l Information about your mobile service provider.
l App usage data, including, among others:
l Frequency of use;
l Areas and features of our App you visit;
l Your use patterns generally;
l Engagement with particular features.
To collect this information, we may also send cookies to your mobile device. Cookies are small data files stored on your device memory.
How we use your Personal Data
Purposes of processing
We may use your Personal Data for the following purposes:
l To analyze, operate, maintain and improve the App, to add new features and services to the App, to support the existing functions of the App.
Example: We may use your Personal Data to predict your cycles or ovulation to customize content and materials you see when you use the App.
Example: Based on your Personal Data we may provide you certain suggested articles to read to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders.
Example: We may send you a reminder to log your period or symptoms to make predictions more accurate.
l To customize product and service offerings and recommendations to you, including third-party products and offerings (excluding data from Apple HealthKit and Google Fit).
Example: We may send you a discount offer for Cycle Tracker Premium.
l To verify your identity when it is required by law.
Example: We may ask for age verification if we have reasonable doubts regarding your age.
l To send you technical notices, updates, security alerts and support and administrative messages.
l To respond to your comments, questions and requests and to provide customer service.
Example: We may process the data to reply to your support request.
l To monitor and analyze trends, usage and activities in connection with our App.
Example: We may analyze your activities in the App to understand what you like or dislike about it in order to improve your future experience.
For any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.
Example: We will contact you directly, if we need your Personal Data for anything else.
Principles of processing
Data minimization and purpose limitation. We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amounts and types of Personal Data that is strictly needed for the mentioned purposes.
No sale of Personal Data. We will never sell, rent, or disclose your Personal Data. We may share only some of your Personal Data to our service providers strictly limited to cases and purposes stipulated in this Privacy Policy. We will also not use the information gained through your use of the HealthKit and Google Fit framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.
Your privacy rights
It does not matter what country or region you come from. We are committed to providing you vast privacy rights for your Personal Data.
l Correction of Personal Data
If you believe that your Personal Data is inaccurate, you have a right to contact us and ask us to correct such Personal Data.
l Restriction of Processing
You also have a right to request that the processing of your Personal Data be restricted, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.
l Erasure of your Personal Data
You may ask us to erase your Personal Data, if you withdraw your consent to processing, if you believe such processing is not compliant with applicable law and in some other cases. Please be aware that erasing some Personal Data may affect your App experience.
l Right to object to the processing of your Personal Data
In some cases you can object to the processing of your Personal Data, for example, if we process it under legitimate interest basis.
How to exercise your privacy rights
Contact us at azureaurora04@gmail.com to exercise any of your privacy rights.
We will exercise them within 30 days after receipt. It may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.
What else?
Please keep in mind that if we receive a vague request, we may engage the individual to better understand the motivation and content of the request. We may also refuse manifestly unfounded and excessive (repetitive) requests.
Subject to applicable laws, you may have a right to lodge a complaint with your local data protection authority about any of our activities (related to your privacy rights, among others) that you think are not compliant with applicable law. However, if you think that we do something incorrectly, let us know first at azureaurora04@gmail.com. We care about your privacy and want to make sure that we did everything to address any of your concerns.
Third parties processing your Personal Data
We will not share your Personal Data with any third parties except as specified below.
Processing to find new Cycle Tracker users and stay in touch with you.
1. You become a Cycle Tracker user and we start sharing Personal Data, strictly limited to the following set:
a) Technical identifiers: IP address (which may also provide general location information), User agent, IDFA (Identifier for advertisers), Android ID (in Android devices), Google Advertiser ID, Customer-issued user ID and other similar unique technical identifiers.
b) Your age group;
c) Your subscription status;
d) The fact of application launch.
2. This is how you and new users find out more about Cycle Tracker, get accurate cycle predictions, learn about the meaning of their bodies’ cues and receive credible information about their health. You contribute to the growth of the Cycle Tracker community by providing your consent to use the Cycle Tracker app.
Processors are companies that help us run the App, support our communication with you or perform other App-related activities. They may process certain Personal Data on our behalf to accomplish the goals related to the App functions and associated activities. Processors act only in accordance with our instructions and process only such amount of Personal Data as we instruct them to process. We remain fully liable for any acts or omissions of our processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.
Aggregated information
We may share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you, with our partners or research institutions. For example, we may share, including, without limitation, in articles, blog posts and scientific publications, general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users. Sharing such data contributes to the advancement of scientific research on women’s health.
Special circumstances
We may also share some of your Personal Data in the following special circumstances:
In response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements);
When disclosure is required to maintain the security and integrity of the App, or to protect any user’s security or the security of other persons, consistent with applicable laws. In such cases we may also delete some of your Personal Data.
When disclosure is directed or consented to by the user who has input the Personal Data;
In the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.
Retention of your Personal Data
When you use the App, we will retain your Personal Data as long as your account is active or needed to provide you Services, and only for as long as it serves purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can erase your Personal Data in accordance with the Privacy Policy.
You should be aware that we may retain certain Personal Data and other information after your account has been terminated or deleted in an aggregated, anonymized form. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.
Personal Data you elect to share with third parties
You can direct us to share data from the App with other parties. For example, you can permit us to share data with other health apps and services like Google Fit and Apple HealthKit. Once you direct us to share your data with a third party, that third party will have their own privacy policy and we do not control how the third party uses or handles the information.
We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern the processing of your Personal Data.
Security of your Personal Data
General security measures
We take all reasonable and appropriate measures to protect all Personal Data collected from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:
Pseudonymization and tokenization of certain categories of your Personal Data;
Encryption of your Personal Data in transit and in rest;
Systematic vulnerability scanning and penetration testing;
Protection of data integrity;
Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake a privacy audit in the event of the Company’s merger or takeover.
Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information will not be intercepted while being transmitted to us.
Security breaches
If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in Section 3 of the Privacy Policy (such as notifying you in certain cases), we will also undertake particular actions to remedy the breach, including, but not limited to, logging you out from all the devices,and performing other reasonably necessary activities and actions.
If you want to report a security incident related to the App please contact us at azureaurora04@gmail.com.
Children’s privacy
General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at azureaurora04@gmail.com and we will take the required steps to delete such information and (or) delete her account.
Age limitation for the European Union residents. Due to legal requirements you shall be at least 16 years old to use the App. We do not allow the use of the App by the European Union residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at azureaurora04@gmail.com and we will take steps to delete such information and (or) delete her account.
Communication with you
We may contact you from time to time via email or through other means (like popups or push notifications) to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you.
Storage and international Personal Data transfers
General
The Company is based in the British Virgin Island, and Personal Data we collect is governed by Euro Lawa. Please be advised that Euro law and laws of other countries may not offer the same protections as the law of your jurisdiction.
In addition, you agree that Personal Data collected may be stored and processed in Canada and the United States, where the Company rents servers, or in any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities, and by using the App, you consent to any such transfer of Personal Data outside of your country.
Complaints and Dispute Resolution. In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your Personal Data. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at azureaurora04@gmail.com.
We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the following link for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Arbitration. You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country (including Switzerland) participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from JAMS; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident. The arbitration option may not be invoked if the individual’s same claimed violation of the Principles (1) has previously been subject to binding arbitration; (2) was the subject of a final judgment entered in a court action to which the individual was party; or (3) was previously settled by the parties.
Onward Personal Data transfers. In the context of an onward data transfer we have responsibility for the processing of Personal Data we receive under the Privacy Shield. We remain liable under the Principles if our processor processes such Personal Data in a manner inconsistent with the Principles and applicable laws, unless we prove that we are not responsible for the event giving rise to the damage. For any onward transfer we commit to execute a formal agreement with any receiving party or processor acting on our behalf.
If we receive Personal Data subject to our certification under the Privacy Shield and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the Personal Data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.
Data Protection Officer (DPO)
To communicate with our Data Protection Officer, please email at azureaurora04@gmail.com.