Privacy Policy

 

This Privacy Policy (“Privacy Policy”) applies to the processing of personal data of users (“user” or “you”) of the mobile application (“app”)  (“we” or “us”), in accordance with Regulation (EU)  – General Data Protection Regulation (“GDPR”), the Italian Legislative Decree (as amended) and other applicable local laws, as amended or replaced (jointly, “Applicable Privacy Laws”).

 

1. Data Controller and Data Protection Officer

 

Our Data Protection Officer can be contacted by sending an email to modymineru@gmail.com for any requests relating to the processing of your personal data or this Privacy Policy.

 

2. Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing

 

We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all of the below information may be deemed personal data in your jurisdiction in all cases.

 

Purpose              Legal Basis          Categories of Processed Data

To enable you to use the app and to provide you with its functionalities.

 

The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).            

Identifiers and internet and network activity information (such as IP address, device model, device type, OS version, device language, device name, country set in the device settings, information about your interactions with the app, and unique identifiers, including IDFA or AAID), and other information necessary to enable you to use the app.

 

The app requires your permission to access your keyboard. When you enable FULL ACCESS mode in the app settings, please remember that it may allow to access, collect and transmit any data and/or information you type, including any data and/or information you have previously typed with your keyboard when FULL ACCESS mode was disabled: however, we are not interested to process such data.

 

To improve our products and services (for example, by conducting statistical analysis or other research activities to optimize our features and provide you with new ones). We may develop autocorrection features but, in such a case, we will only process anonymised data.

 

The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) to improve our products and services.                Identification and contact information you provide us (such as name, age, country or email address, when requested), identifiers and internet and network activity information (such as IP address) and information collected or generated to improve the app’s functionalities (such as information about your interactions with the app, inferences we generate and other related information about your usage of the app, frequency of use, payment details, app version, and other apps/platforms/services on which app is used).

To ensure the quality of our products and services by analyzing, preventing or correcting failures, illicit use or misuse of products and services.

 

The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) to improve our products and services.                Any information necessary to ensure the performance of these purposes.

To comply with our legal obligations, including requests from public authorities.

 

The legal basis for the processing is compliance with legal obligations to which we are subject (art. 6(1)(c) of the GDPR).                Any information which may be required by law or under the instructions of public authorities.

To process and respond to customer support communications and to requests for information you may raise with us.

 

The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).                Identification and contact information you provide us (such as first and last name, email address) and the content of your communication or request.

To establish, exercise or defend our rights and those of our employees, and to carry out corporate transactions or operations (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions).

 

The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) to establish, exercise or defend our rights and to carry out corporate transactions or operations. Any information necessary to ensure the performance of these purposes.

To create user profiles by analyzing preferences, behaviors, interests and choices expressed through the use of our products and services, also in order to:

 

- conduct surveys, statistical analysis or other research activities to improve our products and services;

 

- optimize our features and provide you with new ones;

 

- create lookalike audiences;

 

- carry out re-engagement activities of inactive users;

 

- use attribution data to measure the effectiveness of our campaign and make our advertising more relevant.

 

The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR)            Your identification and contact information (such as name, age or email address, when requested), identifiers and Internet and network activity information that we collect (such as IP address, IDFA or AAID), information about your interactions with the app, and other related information about your usage of the app.

To carry out marketing activities, send you information and marketing communications about our products and services - such as tips, offers, and newsletters - through emails and push notifications (only if you grants permission by enabling push notification on your mobile operating system settings) and conduct interviews.

 

The legal basis for the processing is your consent (art. 6(1)(a) of GDPR).             Your identification and contact information (such as name, age or email address, when requested), identifiers and internet and network activity information (such as IP address), information we may receive from third-party advertising networks and platforms (such as unique identifiers, including IDFA or AAID), information collected or generated to improve the app’s functionalities (such as your responses and your voice in case you take part in our interviews, excluding video recordings which will be deleted immediately after the interviews) and information about your interactions with the app.

3. Data Storage and Protection

 

Personal data may be processed by both automated and non-automated means, and may be stored at our premises and on our service providers’ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.

 

Personal data processed for the purposes referred to in Section 2.a), 2.d), 2.e) and 2.f) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than 10 (ten) years from the termination of the agreement.

 

Personal data processed for the purposes referred to in Section 2.b), 2.c), 2.g) and 2.h) will be kept for no more than 2 (two) years from the termination of the agreement.

 

Except for any legal obligation that sets a longer data retention period, at the end of these periods, the personal data processed will be deleted or anonymized.

 

4. Your Choices with Regard to the Use of Your Personal Data

 

It is mandatory for you to provide your personal data for the purposes referred to in Sections 2.a), 2.d) and 2.e). If you do not provide the personal data, you will not be able to enjoy the app’s services and features.

 

Where we rely on your consent for the purposes referred to in Section 2.h), your provision of personal data is optional, and you have the right to withdraw your consent at any time. If you do not provide the personal data, you will still be able to enjoy the app’s services and features.

 

Where we rely on our legitimate interest for the purposes referred to in Sections 2.b), 2.c), 2.f) and 2.g), your provision of personal data is still optional and you may, at any time, exercise your right to object to such processing as explained in Section 7 (Your Rights) below.

 

You can also manage how you share certain information with us by adjusting the privacy and security settings on your mobile device (such as “Limit Ad Tracking” on iOS, or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android). You should refer to the instructions provided by your device’s operating system or its manufacturer to learn how to adjust your settings.

 

5. Sharing Your Personal Data

 

We may share or disclose your personal data to the following categories of recipients:

 

Vendors carrying out activities that are related or instrumental to our business and operational activities as outsourced data processors appointed in writing in accordance with Applicable Privacy Laws, or acting as autonomous data controllers (such as IT or storage service providers, mobile measurement partners, suppliers of mobile marketing services, social networks and advertising networks and platforms).

 

If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers, and may be one of the assets that is transferred to another owner.

 

Public, judicial or police authorities, within the limits established by applicable laws.

 

Personal data will not be disclosed for any reason other than those stated above, unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.

 

6. Transfers of Personal Data Outside the European Economic Area

 

We may transfer personal data from the European Economic Area (“EEA”), the UK or Switzerland to other countries outside the EEA. Such data transfers are based on appropriate safeguards in accordance with Applicable Privacy Laws, including (a) the standard contractual clauses developed by the European Commission; (b) Swiss-U.S. Privacy Shield, and the decisions of adequacy of the European Commission; or (c) binding corporate rules.

 

More information on the appropriate warranties are available by sending an email to privacy@bendingspoons.com.

 

7. Your Rights

 

At any time and free of charge, you can exercise the following rights, as specified and subject to certain limitations and exceptions under Applicable Privacy Laws:

 

Right of access. You have the right to obtain information about the processing of your personal data and to access it.

 

Right to rectification. You have the right to ask for the updating, rectification or integration of your personal data.

 

Right to erasure. You have the right to request the deletion of your personal data.

 

Right to restriction of processing. You have the right to request the restriction of the processing of your personal data.

 

Right to data portability. You have the right to obtain a portable electronic copy of your personal data.

 

Right to object. Where we rely on our legitimate interest to process your personal data, you have the right to object to such processing, wholly or partly, on grounds related to your particular situation. In particular, you are entitled to object to the processing of your personal data for direct marketing purposes, including profiling.

 

Right to withdraw your consent. Where we rely on your consent to process your personal data, you have the right to withdraw your consent, although the processing carried out before your withdrawal of consent will remain valid.

 

You also have the right to lodge a complaint before the competent national Data Protection Authority, in particular before the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

 

To exercise your rights, you may contact us by sending an email to privacy@bendingspoons.com. We may take reasonable steps to verify your identity prior to responding to your request.

 

8. Children’s Personal Data

 

The app is not intended for anyone under the age of 13. We do not knowingly collect personal data from children. If you believe we have received personal data from children under the age of 13, please email us at modymineru@gmail.com. If we learn that a user is under the age of 13, we will take reasonable steps to delete any processed data and close such user’s account.

 

9. Third-party Websites and Services

 

The app may include links to other websites or services operated by third parties. The activities described in this Privacy Policy do not apply to data processed by such third-party websites and services. We have no control over, and we are not responsible for, the actions and privacy policies of third parties and other websites and services.

 

10. Changes to this Privacy Policy

 

We may modify, integrate or update, in whole or in part, this Privacy Policy, and we will notify users of any modification, integration or update in accordance with Applicable Privacy Laws. If we make modifications, we will notify you by revising the date at the bottom of this Privacy Policy and, under certain circumstances, we may also notify you by additional means such as pop-up or push notifications within the app or our website, or email.