Privacy Policy

DATA PRIVACY POLICY

MOBILE APPLICATION "Think Body"



This Privacy Policy explains what information is collected by the Owner of the Mobile Application "Think Body" Individual - Entrepreneur Gordeev Denis Mikhailovich, (hereinafter referred to as the Administration, Owner, We, Our, in all variable forms) when you use the Mobile Application "Think Body" (hereinafter referred to as the Application, Mobile Application), use any services provided by the Application, or communicate with us. The purpose of this policy is to inform you and explain exactly how you can control the information we collect, how this information will be used and how to contact us. In addition, this document describes how we protect your personal data and other important information.



INTRODUCTION

The Administration collects information about the Users of the Application to provide you with services to provide you with feedback, protect our and your legitimate interests within its competence, as well as your data from unauthorized access by third parties, analyze and improve our Services, communicate with you and fulfill our legal and regulatory obligations in accordance with the norms of the current legislation of Ukraine and the European Union.

From time to time, we may revise or amend this Privacy Policy to reflect changes in the law, our methods of collecting and using personal information, the functions of the Services. This Privacy Policy does not apply to the activities of organizations that we do not own or control, or people not associated with us.

On May 25, 2018, the General Data Protection Regulation of the European Union entered into force. This new legislation has significantly affected everyone whose business is related to the processing of personal data about EU residents or within the EU. Given that our Users can receive the Services using the Application from the territory of the European Union, this privacy policy has been developed taking into account the requirements of the General Data Protection Regulation of the European Union, and the provisions of this law apply to this policy in situations provided for by this regulatory act.

DEFINITION OF TERMS



Personal data - information or a set of information about an individual who is identified or can be specifically identified using such data.

Processing of personal data - any action (operation) or a set of actions (operations) carried out using automation tools or without the use of such tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

Confidentiality of personal data is a mandatory requirement not to allow distribution, or other related actions without the consent of the owner of personal data or without any other legal basis.

User - an adult who has access to the Application and uses them for their functional purposes.



Third Parties - Any parties other than the User and the Administration.

DATA COLLECTED BY THE ADMINISTRATION AND SITUATIONS IN WHICH SUCH COLLECTION IS POSSIBLE



The Personal Data Policy of the App focuses on collecting the least amount of personal data as possible for the proper and quality provision of services, in this regard, we may collect, store and use the following types of your personal data in the following situations:



When you contact us:

We collect the data that you send to us as a result of contact with us, taking into account your appeals to the support service, or by any contact indicated by us.



When you register your account:

Before you start providing the Services in the Application, you need to create your account as a User. We collect the data that you provide to us when registering an account, to provide access to the Services provided on the Resource and for quick authorization (login) to your account. If you choose to register with GOOGLE, FACEBOOK, or ITUNES, these services provide us with information about your accounts.



When you perform operations using the Resource:

Some services provided by the Application require the exchange of information between you, the Application, as well as in exceptional cases - by Third Parties. These services include all transactions that are necessary to secure purchased courses to your account, information about your passing certain courses, marathons, or challenges.

When you make a transaction (since the purchase of paid services does not go directly to Us, but through a store, such as PLAY MARKET or ITUNES), we exchange data with a Third Party, the store through which you make a purchase.



In other cases, with your consent:

We may use your Personal Data if you have consented to us doing so for a specific purpose not mentioned above. For example, with your permission, we may publish customer reviews or selected customer stories to promote our products and services or record phone calls in order to improve quality and training.



Metadata: Like most mobile applications, We collect certain Personal Data of Users. This type of data collection allows us to better understand how people use our App.

For example, we may collect metadata about you, including technical data about your performance or use of our App. We may also collect data about your device to help us determine that users of one type of device are using our App in different ways than users of another type of device, which in turn allows us to solve problems and investigate the performance of our products and services, improve our product, for example, by optimizing screen size or providing a more efficient user experience.

We may collect these types of personal data as part of your use of our App.

One of the common technologies we use to collect metadata that may be considered Personal Data is the use of cookies, but we may use other third-party services to collect such information as depicted in this policy.



Cookies are small text files that are placed in your web browser and help us recognize your device as a unique visitor in different ways depending on the type of cookies. There are three main types of cookies:



Basic cookies. Basic cookies are essential for functionality and security. For example, our App may require cookies for authentication, security and session.



Functional cookies. We use functional cookies to improve the effectiveness of the provision of services, for market research or other analytics or advertising that is not tied to a particular person. For example, we may use Google analytics to help us track how many people have visited our App. We may also use HTML5 local storage cookies for the reasons described in this section.



Targeted or advertising cookies. We use targeted and promotional cookies to help us understand our marketing efforts and reach potential customers online. For example, we contract with third-party advertising networks that can track your activity over time and various channels, including our websites, email activities and other websites and apps that show ads. They may use this tracking information to understand and anticipate your interests in order to advertise the App on another service.



Processing of personal data in the presence of legal grounds (for the United Kingdom and the European Economic Area and other relevant jurisdictions)

If you are an individual in the United Kingdom, the European Economic Area (EEA) or another relevant jurisdiction, we collect and process information about you only if there are legal grounds or grounds for doing so in accordance with applicable law. This means that we collect and use your personal data only where:



We need it to operate and provide you with our products and services, customer support and personalized features, and to protect the security of our products and services;

It satisfies the legitimate interest of the Administration (which does not override your interests and data protection rights), for example, for research and development, to provide you with information about our products and services that we believe may be useful to you and your organization, and to protect our legitimate rights and interests;

You consent to this for a specific purpose;

or

We must fulfill a legal obligation.

If you have consented to our use of personal data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect the processing that has already taken place. If we use your Personal Data because we or another entity (such as your employer) has a legitimate interest in doing so, you have the right to object to such use; however, in some cases this may mean that you no longer use our products and services.

In the event that we de-identify (depersonalize) any Personal Data for future use, we undertake to maintain and use the information in a de-identified form and will not attempt to re-identify the information except for the purposes of determining whether our de-identification processes comply with applicable legal requirements.



Third-party services for collecting information. Our App uses third-party services to collect standard log information and details about visitor behavior patterns, including publicly available visitor-related contact information and company names with which visitors are associated. To collect this data, we use Google Analytics та Facebook Pixel.



We use this data to pursue our legitimate business interests, including identifying the most relevant potential customers and/or potential companies and personalizing our marketing efforts to provide users with personalized content and improve their experience in our App.



Google Analytics, provides us with information about user behavior, platforms and browsers used to access the App, pages visited on subdomains, the region from which the visitor accesses the app and subdomains, how the visitor accesses our App (e.g. through search engines, jump pages or direct visits) and other information about behavior.

You can find more information about how Google uses information from sites and apps that use its services at https://policies.google.com/technologies/partner-sites.



Facebook Pixel is an analytics tool that tracks how Facebook users behave if they click on a link from this service, which pages they visit, which buttons and links that caused the transition to advertising pages or downloads.

You can find more information about how Meta uses information from sites and apps that use its services on https://www.facebook.com/business/m/privacy-and-data



Information from third-party services is processed strictly anonymously, is not combined with personal data, but only forms statistical data that is displayed on the platforms defined above.



METHODS OF PERSONAL DATA PROCESSING AND METHODS OF USE



Processing of personal data of the User is carried out without limitation of the term, in any legal way, including in information systems of personal data with the use of automation means or without the use of such means. In the course of data processing, the Administration uses the following methods: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.



The administration uses your data only in exceptional cases, namely:



For feedback from you:

We will use your email address or other contact information that you provide to us in writing or orally to contact you and provide you with the services and information that you request, as well as in the case of requests to us.



To exchange information with Third Parties:

Sometimes the application needs to exchange information with Third Parties. Such exchange of information occurs only if such an exchange is necessary to ensure the proper operation of the Application, or to perform certain actions in it. Such actions, in particular, include the exchange of information when registering an account (in the case of choosing a registration option with the help of third parties).



In case of legal appeal from the authority:

The User's personal data may be transferred to the authorized state authorities only on the basis and in the manner established by the current legislation. In this case, the Administration strictly complies with the legislation of Ukraine and the General Data Protection Regulation of the European Union.



For research (including marketing):

The Administration can use the data to better understand its user, conduct research, or take into account the User's metrics to improve the quality of service delivery.

PROTECTION AND STORAGE OF PERSONAL DATA

Protection of Personal Data:

The Administration guarantees the protection of Personal Data and Confidential Information from accidental loss or destruction, from illegal processing, including illegal destruction or access to Personal Data and implements appropriate technical and organizational measures that are designed to effectively implement the principles of data protection, such as minimizing data, and integrate the necessary guarantees into the processing, namely:

• Uses data encryption;

• Personal data is isolated and protected by several levels of security;

• The service provider ensures the continuous confidentiality, integrity, availability and stability of processing systems and services;

• Ensures timely recovery of Personal Data in the event of a technical accident;

• Blocks data at all levels and applies many technical and organizational measures to ensure its safety and prevent data leakage and unauthorized access to data, such as

• Firewall of web applications;

• Input data verification;

• Continuous security management and monitoring;

• Daily data backup.



To store Confidential Information and Personal Data, the Administration uses exclusively safe and secure resources, including Cloud media.



Separately, it should be noted that the Administration has no control over what happens between the User's device and the information infrastructure outside the Application. Users should be aware of the numerous existing information security risks and take appropriate measures to protect their own information. The administration is not responsible for violations that occur outside the scope of its control.



Storage of Personal Data:

We store the User's personal information as long as it is necessary for the purposes specified in this Privacy Policy. The Administration may sometimes retain this information for longer periods as permitted or required by law, for example, to maintain prohibition lists, prevent abuse if necessary in connection with legal action or litigation, to enforce our agreements, for tax purposes, accounting purposes or to comply with other legal obligations.

When we no longer have a legitimate need to process this information, we delete or anonymize this information from our active databases.



Storage of User data takes place on the servers of the Administration and Cloud media, which are located in the territory of the European Union.

USER'S RIGHTS



You, as a User (subject of personal data), have the right to:



CHILDREN

The app is not aimed at children. We do not knowingly collect personal data of children under the age of 18. If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us using the information in the section below and we will take steps to remove such Personal Data from our systems.

CONTACTS FOR COMMUNICATION WITH US

For communication with us in matters of protecting confidential, personal information of the user, interpretation of the rules of this policy and in case of any situation related to violation of the rules of this policy, please contact us at these contacts: