1. DEFINITION OF CONCEPTS

"Law" means the General Data Protection Regulation (GDPR) of the European Union, including all amendments and supplements, as well as other applicable legislative acts of the European Union and its member states governing the processing of personal data.
"Mobile Application" is software (with all existing additions and enhancements) designed to run on smartphones, tablets, watches and other mobile devices, and developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the Mobile Application means the following software: TAKE TIME.
"Personal Data" means a set of personal data and/or non-personalized information about the User, provided by the User himself/herself to the Licensor and/or automatically collected by the Licensor and/or third parties.
"Policy" means this Mobile App Privacy Policy (with all existing additions and modifications).
"User" means a legal or natural person who has downloaded the Mobile Application to a smartphone, tablet, watch or any other mobile device and/or has performed the activation of such Mobile Application on one of these devices.
"User Agreement" means an agreement concluded between the Rightholder and the User regarding the procedure, rules and peculiarities of the User's use of the Mobile Application. The User accedes to such agreement and has no right to make and/or request any amendments or additions to it.
"Rights Holder" means the following organization that owns the exclusive rights of ownership of the Mobile Application
TAKE TIME INTERNATIONAL LIMITED
Company Nr 15504758
101 KING’S CROSS ROAD
LONDON
ENGLAND WC1X 9LP
"Cookies" means small files sent to any mobile application or website and placed on User's smartphones, tablets, watches and other mobile devices to improve the performance of such applications or websites and the quality of the content posted therein.

2. RELATIONSHIPS COVERED BY THE POLICY

General Provisions

This Policy is used and applicable solely to Personal Data received from the User in connection with the User's use of the Mobile Application. The provisions of this Policy are aimed at:
(1) determining the types and kinds of Personal Data to be obtained, the directions and purposes of use (processing) of Personal Data, as well as the sources of obtaining such Personal Data;
(2) determining the User's rights regarding the protection of the confidentiality of the Personal Data transmitted by the User;
(3) identifying the persons responsible for processing and storing Personal Data, as well as third parties to whom such data is disclosed (in full or in part).
The rules of this Policy do not apply in the case of processing by third parties of Personal Data that are voluntarily provided by the User.
By installing and/or activating the Mobile Application on a smartphone, tablet, watch or other mobile device, the User agrees to the terms and conditions of this Policy and gives his/her consent to the Rightholder to collect, process, retain and store Personal Data in the manner and on the terms and conditions stipulated by this Policy.
If the User does not agree with the terms of the Policy and/or individual terms of the Policy are not clear to him/her, in such case the User is obliged to immediately stop using the Mobile Application.

User's rights regarding protection of personal data

In connection with the provision of Personal Data, the User automatically obtains the following rights:
(1) obtain data concerning their processing (grounds and purposes of such processing, processing methods applied, information about persons who have access to them or to whom they may be disclosed on the basis of a contract or the Act).
(2) to obtain data on the location and identification data of the persons performing the processing of Personal Data.
(3) obtain data on the retention periods of Personal Data.
(4) to obtain data on transfers of Personal Data made or suspected to have been made across borders.
(5) obtain information about the location and identification data of the persons storing Personal Data.
(6) to appeal the actions or inaction of the Right Holder to the authorized body for the protection of the rights of personal data subjects or in court.
(7) receive compensation for losses and/or compensation for moral damage in court as a result of violations of the User's rights to protection and defense of his/her Personal Data committed by the Rights Holder and/or third parties.
(8) exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.

3. LIST OF PERSONAL DATA TO BE COLLECTED

Non-personalized information about users

In connection with the use of the Mobile Application, the Licensor may automatically collect and process the following non-personalized information about the User:
(1) information about traffic, possible number of clicks, logs and other data.
(2) information about the User's location (geolocation). The User may disable geolocation at any time by changing the settings of the device from which the User logs into the Mobile Application. Geolocation is used by the Mobile application only when the User is actively using such application. Geolocation stops functioning when the User exits the Mobile application.
(3) information about the device (identification number, mobile operator network) from which the login is performed, operating system, platform, browser type and other browser information, IP address.

Personal data about users

The User provides the following personal data about himself/herself to the Licensor:
(1) e-mail address.
(2) cell phone number.
(3) a photograph depicting the User.
(4) all photos, video clips, audio files and other types of media that are stored on the device from which you log into the Mobile App.
(5) data contained in the User's personal account (profile), all internal correspondence of the User (if any), as well as other activity of the User's personal account (profile).
(6) data on orders/purchases made by Users and/or services received/paid for via the Mobile Application.
(7) the address where the service is to be provided
(8) data and information resulting from the aggregation of those or other Personal Data of a particular User, as well as data and information obtained from third parties (partners, marketers, researchers) about the User.
The User is the only person responsible for the completeness of the personal (personal) data provided and is obliged to make timely changes (update, verification, correction) on a regular basis.
The Rightholder assumes that all personal data provided by the User are true and that the User keeps such information up to date.

Information on transactions in progress

The User can pay for goods or services through the Mobile application by entering information about the payment card and identification data of the owner of such card into a special field. The User may make payment in the Mobile application in the following ways:
● via bank card.
● as well as the following ways: YandexPay, Stripe.
The collection and processing of User data in this case is carried out solely for the purposes of payment processing, fraud prevention, and compliance with other requirements of the Law.
The User gives his/her consent to access and collection of such Personal Data by the Licensor and the respective payment system or banking institution, through which/which the payment is made, as well as agrees with the privacy policy of the respective payment system or banking institution.

Use of cookies

This Mobile Application uses certain Cookies to store IP address, User preferences or the type of device used in order to:
(1) keep statistics on visits and traffic to the site
(2) personalization of the data displayed on the User's screen
(3) storing data necessary for identification of the User, including when accessing from different devices
(4) displaying advertisements according to the User's interests and preferences. The Mobile Application may use both its own Cookies belonging to the Rights Holder and Cookies of third parties.
The mobile application uses the following Cookies:
(1) Technical (functional) Cookies, which are necessary to control traffic and data transmission, to identify Users and to provide User access to the Mobile Application content and without which the use of the Mobile Application is functionally limited, as well as to prevent the provision of recommendations that are not in the User's interest.
(2) Statistical Cookies, which are necessary to track how often Users visit the Site, to identify how Users use the Mobile Application, and to identify the type and kind of content that is popular or interesting to Users.
(3) Geolocation Cookies that are necessary to determine the User's location in order to personalize the content displayed on their device in the Mobile Application.
(4) Third party cookies, which are set by third parties with the User's permission and are designed to conduct statistical research regarding the User's online behavior and/or to send personalized advertising or marketing materials to the User and/or to provide goods or services.
The User has the right to disable Cookies in the Mobile Application at any time by changing certain settings on their smartphone, tablet, watch or other mobile device. Such disabling may entail limiting or modifying the User's access to the functionality of the Mobile Application and/or content. To disable Cookies, you must follow the steps below:

4. PURPOSES OF PERSONAL DATA COLLECTION AND PROCESSING

Determination of processing objectives

Personal Data is collected and processed for the following purposes:
(1) to analyze the User's behavior, as well as to identify the User's preferences for certain types of content.
(2) to operate the Mobile Application promptly and correctly, improve the functioning of the operation of the Mobile Application, improve the content of the Mobile Application, and improve the internal architecture and functionality of the Mobile Application.
(3) to identify the User.
(4) to send personalized advertising and marketing materials to the User's specified email address and/or cell phone.
(5) to comply with the requirements of the Act.
(6) to track orders/purchases made by the User through the Mobile Application.
(7) to determine the location of the User.
(8) for technical support of the Mobile Application, identification of problems in its operation and their elimination.
(9) to communicate with the User (communication).
(10) to fulfill other obligations of the Licensor that have arisen to the User.
(11) to provide personalized advertising and marketing materials
(12) for any other purpose, subject to separate consent from the User.
The processing of Personal Data is carried out on the basis of the principles:
(1) the legitimacy of the purposes and modes of processing
(2) integrity
(3) compliance of the purposes of processing Personal Data with the purposes predetermined and declared at the time of collection of such Personal Data
(4) compliance of the scope and nature of the Personal Data processed with the stated purposes of their processing.

Conditions of personal data processing

Processing of Personal Data is carried out in cases of:
(1) obtaining consent from the User
(2) the achievement by the Rights Holder of the objectives provided for in the international treaty or the Law
(3) the provision of Personal Data by the User to an unlimited number of persons
(4) fulfill other obligations of the Rights Holder to the User, including, but not limited to, providing certain content to the User
(5) saving the User's life or health when consent to the processing of their Personal Data cannot be obtained in advance.
In case of anonymization of Personal Data, which does not allow to identify the User directly or indirectly, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy no longer apply to them.
The Licensor shall take all possible measures to protect the confidentiality of the Personal Data received, unless the User has made such data publicly available.
Processing of Personal Data shall be carried out with or without the use of automation tools.

5. THIRD PARTY ACCESS TO PERSONAL DATA

Use of remarketing services

The Rightholder uses remarketing to advertise to the User the content of the Mobile Application on other websites visited by the User.
Remarketing services to the Rightholder are provided through the following platform: Yandex Direct. The said provider collects and processes non-personalized data that does not directly identify or identify the User. The collected information may typically include:
(1) content viewed by the User
(2) the date and time when the User viewed the content
(3) geolocation data. The collection and processing of such non-personalized information allows to provide the User with more targeted advertising or marketing content.
By installing the Mobile Application, the User agrees to the Privacy Policy and Terms of Use of the said remarketing service provider, as well as to the automatic installation of the relevant Cookies on the User's device.
The User has the right to refuse such advertising at any time by changing the appropriate settings of the browser and the device from which the Mobile Application is accessed.

Utilization of analytical platforms

The rightsholder uses Firebase's analytics platform to:
(1) tracking the frequency of visits to the site by Users
(2) tracking the ways in which the User uses the Mobile Application and/or its content
(3) identifying the type and kind of content that is popular among Users
(4) determination of the User's location. The User also gives its consent to the Right holder to use the information received about the User from Firebase.
For these purposes, Firebase's analytics platform may collect data about the User's IP address, geolocation, behavior, and the User's preferences and interest in certain content.
Firebase analytical platform gets access to Personal Data in order to provide the Rightholder with an understanding of how effectively its Mobile Application works, what kind of content is popular, how effective is the placement of advertising in it, as well as for the purposes of developing and/or improving the existing marketing strategy of the Rightholder.
By installing the Mobile Application, the User agrees to the Privacy Policy of Firebase, as well as the automatic installation of appropriate Cookies on the User's device.

Disclosure of personal data to third parties

The Licensor has the right to disclose Personal Data:
(1) to its affiliates, branches and representative offices opened both in the territory of the European Union and in the territory of other states
(2) to the legal successors of the Rights Holder who have arisen as a result of its liquidation, reorganization or bankruptcy and who have obtained the exclusive rights of ownership of the Mobile Application
(3) to payment service providers or banking (financial) institutions, for conducting User's transactions through the Mobile Application
(4) to third parties solely for the purpose of providing the User with receipt of or access to certain content
(5) to third parties when the User has consented to the disclosure, transfer or processing of his/her Personal Data, as well as in other cases expressly provided for by the Law or this Policy.
The Rights Holder will only disclose Personal Data if:
(1) is sure that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data as the Licensor itself does
(2) consent to such disclosure has been previously expressed by the User and/or is permitted under the Act.

Sending promotional materials to users

The User automatically with the installation of the Mobile Application on the device agrees to the right of third parties to send personalized advertising and marketing materials to the provided email address and/or cell phone.
The User has the right to opt-out of receiving such advertising and marketing materials at any time by doing the following:

6. ADVERTISING PLACEMENT

Advertising in the mobile application

Together with the content, the Rights Holder places various advertising and marketing materials in the Mobile Application, taking into account the identified preferences of the User for this or that content. Placement of advertisements in the Mobile Application implies the installation of certain Cookies on the device of the Rights Holder.

Sending promotional materials

With the installation of the Mobile Application on the device, the User automatically agrees to the Rightholder's right to send personalized advertising and marketing materials to the provided e-mail address and/or cell phone.
The User has the right to opt-out of receiving such advertising and marketing materials at any time by doing the following:
Please note that in case of refusal to receive advertising and marketing materials, the User may continue to receive any notifications from the Rights Holder related to the procedure of using the Mobile Application and/or its content.

7. SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER

Request for termination of personal data processing

Each User has the right to express his/her objection to the Licensor against the processing and/or storage of his/her Personal Data. Such objection may be expressed as follows: send an e-mail to the following address: support@taketime.net. You may also use this address to send requests for the exercise of your rights or complaints regarding the incorrectness of your Personal Information or the unlawfulness of its processing.
Also, the User has the right to change or delete his/her Personal Data at any time by himself/herself, except where such change or deletion may result:
(1) to violate the rules of this Policy
(2) to a violation of the Act

Request for information about personal data

If the User has any questions related to the procedure of application or use of this Policy, the procedure and/or method of processing Personal Data, the User may ask such a question as follows: send an e-mail to support@taketime.net.

Amendment (update, addition, correction) or deletion of personal data

The User has the right to modify or delete his/her Personal Data at any time by himself/herself, except where such modification or deletion may result:
(1) to violate the rules of this Policy
(2) to a violation of the Act
The Rightholder has the right to delete the User's personal account/profile, as well as all Personal Data about the User at any time, if the User has violated the terms of this Policy and/or the User Agreement.

8. TERMS AND PROCEDURE FOR STORAGE OF PERSONAL DATA

Storage is carried out by third parties on behalf of the Licensor. The User gives his/her consent to the storage of his/her Personal Data by third parties on behalf of the Licensor, provided that such third parties maintain the confidentiality of the Personal Data received. The functions of storing the Information are entrusted to the following person: Google (hereinafter referred to as "Custodian"). The Personal Data shall be stored on the territory of the European Union.
The storage is carried out during the entire period of the User's use of this Mobile Application.
The Licensor undertakes to destroy or anonymize the User's Personal Data immediately upon termination of the User's use of the Mobile Application.

9. ACCESS OF MINORS TO THE MOBILE APPLICATION

The mobile application can be used by persons under the age of 18.
The mobile application collects personal data about Users, therefore the use of this application by underage Users is allowed only with the prior consent of the legal representative (guardian) for the processing of Personal Data.
If a minor User cannot provide consent to the processing of his/her Personal Data from a legal representative (guardian), in such case such User shall immediately stop using the Mobile Application.

10. PERSONAL DATA PROTECTION PROCEDURE

Protection of the confidentiality of Personal Data is a primary and important task for the Licensor. The Licensor adheres to all required international standards, rules and recommendations for the protection of Personal Data.
The Licensor has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access to it by third parties.

11. FINAL PROVISIONS

Availability of the policy text for consultation

Users may review the terms of this Policy at the following link:
This version of the Policy is effective as of September 1, 2023.

Modifying and amending the policy

This Policy may be amended from time to time. The Rightholder does not bear any responsibility to the User for changing the terms of this Policy without the permission and/or consent of the User.
The User himself undertakes to regularly check the provisions of this Policy for possible changes or amendments. However, in the event of a material change in the terms of this Policy, the Licensor undertakes to notify the Users in the following manner:

Applicable law

This Privacy Policy has been developed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Risk of disclosure

Regardless of the measures taken by the Licensor to protect the confidentiality of the Personal Data received, the User is hereby deemed to be duly informed that any transmission of Personal Data on the Internet cannot be guaranteed to be secure, and therefore the User makes such transmission at his/her own risk.