BetterMe: Walk, Run & WeightlossPRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use BetterMe: Walk, Run & Weightloss mobile application (the "Application", "Service"), how such personal data will be used, shared, and how you can control it.

If you disagree with the practices described in this Privacy Policy, you should take the necessary steps to delete your account following the setting in Application, if registered, and remove Application from your device.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU).

If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account using the functionality found in "Settings" in the Application, or contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android); and (c) delete the Application from your devices.

"GDPR" means the General Data Protection 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.

"EU/EAA" includes all current member states to the European Union and the European Economic Area.

"Process", in respect of personal data, includes to collect, store and disclose to others.

TABLE OF CONTENT

  1. CATEGORIES OF PERSONAL DATA WE COLLECT

    We collect data you give us voluntarily (e.g., when you choose your problem areas or send us an email). In addition, we collect data automatically (for example, your IP address). We also may receive data about you from third parties.

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    1. Data you give us

      You provide us information about yourself when you register for and/or use the Service. For example: date of birth, topics that are of interest to you, email address.

    2. Data we collect automatically

      1. Data about how you found us

        We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).

      2. Device and Location data

        We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

      3. Usage data

        We record how you interact with our Service. For example, we may log your taps on certain areas of the interface, the features and content you interact with, how often you use the Application, how long you are in the Application, and your subscription orders. We also record the ads in our Application with which you interact (and the Internet links to which those adds lead).

      4. Advertising IDs

        We collect your Apple Identifier for Advertising (IDFA) or Google Advertising ID (AAID) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device's operating system (but we do not control this).

      Your consent. By using our Service, you explicitly consent that:

      1. We may process your health data which you provide when using the Application for the purpose of providing services to you.
      2. Personal data you provide to us when using the Application includes personal health data you enter into the Application.
  2. FOR WHAT PURPOSES, UNDER WHAT LEGAL BASIS AND HOW WE PROCESS PERSONAL DATA

    Your personal data is collected for the following purposes and using the following services:

    1. To provide our Service

      This includes delivering the Service to you in accordance with our Terms and Conditions of Use in a seamless manner, and preventing or addressing Service errors or technical issues. We also use your personal data, such as parameters and activity level, to tailor Service content.

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      To host personal data and enable this Application to operate and be distributed we use service Amazon Web Services (AWS). Amazon Web Services (AWS) is a hosting and backend service provided by Amazon.com Inc. These services work through geographically distributed servers, making it difficult to determine the actual location where the personal data are stored. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the personal data are stored.

      To monitor infrastructure, we use Crashlytics (Google Inc.). Crashlytics is a monitoring service provided by Google Inc. Personal data collected: Locations data , Advertising data and various types of data as specified in the privacy policy of the service.

      We use Firebase Performance Monitoring and Firebase Crash Reporting (Google Inc.). These are monitoring services provided by Google, Inc. Personal data collected: various types of data as specified in the privacy policy of the service.

      Processing of personal data for this purpose is based on:

      6.1. a) of GDPR ("the data subject has given consent to the processing") and/or

      6.1. b) GDPR ("processing is necessary for the performance of a contract to which the data subject is party")./

    2. To manage your account and provide you with customer support

      We may use your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. Please note that irrespective of your email settings, we may send you notifications pertaining to the performance of our Service, messages about the availability of our Service, security, payment transactions, legal notices regarding revision of our Terms of Use or this Privacy Policy, or other Service-related information.

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      Processing of personal data for this purpose is based on:

      6.1. b) of GDPR ("processing is necessary for the performance of a contract to which the data subject is party").

    3. To communicate with you regarding your use of our Service

      We communicate with you, for example, by push notifications. These may include, for example, information about Application. To opt out of receiving push notifications, you need to change the settings on your device.

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      To communicate with you we use Firebase Cloud Messaging (Google Inc.). Firebase Cloud Messaging is a message sending service provided by Google, Inc. Firebase Cloud Messaging allows us to send messages and notifications to you across platforms such as Android and iOS.
      We also use (i) Firebase Notifications (Google Inc.). Firebase Notifications is a message sending service provided by Google Inc. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events; and (ii) Apple Push Notification service (APNs) (Apple Inc.), that is remote notifications feature provided by Apple Inc. Apple Push Notification allows us to send information to iOS devices.
      These services may also collect data concerning the date and time when the message was viewed by you, as well as when you interacted with it, such as by clicking on links included in the message. Google's privacy policy. Apple's privacy policy.

      Processing of personal data for this purpose is based on:

      6.1. f) GDPR (“processing is necessary for the purposes of the legitimate interests pursued by the controller”), more specifically through that communication we wish to encourage your use of Service.

    4. To perform research and analysis about your use of Application

      This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop Application and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features of the Application our users like more. As a consequence, we often decide how to improve the Application based on the results obtained from this processing. For example, if we discover that users more often engage in some section of the Application, we may focus on improving and providing material for this section.

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      To perform research and analysis about your use of Application we use Appsflyer (AppsFlyer Ltd) Appsflyer is an analytics service provided by AppsFlyer Ltd. Personal Data collected: Device data, Usage data, Advertising data, in-app events, and other provided in privacy policy. Opt Out.

      To track and analyze your behavior regarding changes to the structure, text or any other component of this Application, we use Firebase Remote Config (Google Inc.). Firebase Remote Config is an A/B testing and configuration service provided by Google Inc. Personal Data collected: various types of data as specified in this privacy policy.

      To monitor and analyze web traffic, we use Fabric Answers (Google Inc.). Fabric Answers is an analytics service provided by Crashlytics, a business division of Google Inc. In order to understand Google's use of data, consult Google's partner policy. This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Fabric Answers privacy policy. Personal data collected: Advertising data and Usage data. You may opt-out of certain Fabric Answers features through applicable device settings.

      We use Facebook Analytics for Apps (Facebook, Inc.) This service provided by Facebook, Inc. connects data from the Facebook advertising network with actions performed on this Application. Privacy policy.

      Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google's use of data, consult Google's partner policy. Personal data used: Advertising data and Usage data. You may opt-out of certain Firebase features through applicable device settings.

      Processing of personal data for this purpose is based on:

      6.1. f) GDPR ("processing is necessary for the purposes of the legitimate interests pursued by the controller"), our legitimate interest for this purpose is to improve and make our Service up to date by providing you with a more developed and consistent experience (in particular, make sure that users enjoy the use of, and easily navigate the Application; understand users' preferences to develop new features and change the existing ones).

    5. To send you marketing communications

      We process your personal data for our marketing campaigns. We will add your email address to our marketing list. As a result, you will receive information about our products, such as for example, special offers.

      We may show you advertisements in our Application, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device.

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      Processing of personal data for this purpose is based on:

      6.1. f) GDPR ("processing is necessary for the purposes of the legitimate interests pursued by the controller"), the legitimate interest we rely on for this processing is to promote our Service.

    6. To optimize advertising

      We and our partners, including Facebook, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have tapped on an ad of a sport event shown to you in our Application, we might continue showing you more of these. You may opt out of some of these practices following the information here.

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      Facebook Custom Audience (Facebook, Inc.). Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Opt Out

      Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Opt Out

      AdWords Remarketing (Google Inc.) AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network. Opt Out

      Remarketing through Google Analytics for Display Advertising (Google Inc.) Google Analytics for Display Advertising is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics with the Adwords advertising network and the Doubleclick Cookie. Opt Out

      Snapchat Audience Based Match is a remarketing and behavioral targeting service provided by Snapchat, Inc. that connects the activity of this Application with the Snapchat advertising network.Opt Out

      Processing of personal data for this purpose is based on:

      6.1. f) GDPR ("processing is necessary for the purposes of the legitimate interests pursued by the controller"), the legitimate interest we rely on for this processing is to promote our Service.

    7. To detect and resolve any fraud or other illegal or undesirable user behavior

      We use personal data to protect the security of our Service, to detect and prevent fraud or abuse, to resolve disputes and to enforce our agreements and contractual commitments. This purpose may also include the processing of personal data to the extent when we have a good faith belief that such processing is reasonably necessary to comply with a law, regulation or compulsory legal request, to protect the safety of any person from death or serious bodily injury.

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      Processing of personal data for this purpose is based on:

      6.1. c) GDPR ("processing is necessary for compliance with a legal obligation to which the controller is subject"), and/or

      6.1. f) GDPR ("processing is necessary for the purposes of the legitimate interests pursued by the controller"), and, more specifically, we wish to provide our Service in a safe and harmless manner.

  3. WITH WHOM WE SHARE YOUR PERSONAL DATA

    We will only disclose your personal data with your knowledge and as stated in this Privacy Policy. This includes disclosures that will enable us to fulfill our obligations to you, and allows us to manage our business operations. Your personal data may be shared as follows:

    1. We share your personal data with service providers

      We share with service providers your personal data (such as Usage data, Analytical data, Advertising data) to help them and us understand the usage patterns of Service for analytical purposes so that we can better consider new features or otherwise tailor or enhance our Service. We share your personal information with the following types of service providers:

          1) cloud storage providers;
          2) data analytics providers;
          3) measurement partners;
          4) marketing partners (in particular, social media networks).
    2. We may share your personal data for safety, legal purposes and law enforcement

      We use and disclose personal data as we believe necessary under applicable law, to enforce our Terms of Use, to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

    3. We may share you personal data with third parties in case of change of control

      As we develop our business, we may buy or sell assets or business offerings. Customer information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g., parent company or subsidiary) and may transfer such information in the course of corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

  4. PRIVACY RIGHTS

    If you reside in the EU, you may:

    Delete your personal data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Service to you) through your account or send us an email at support@betterme.tips.

    When you request to delete your personal data, we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such data and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any data, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud detection or similar purposes.

    Change or correct your personal data: You can edit, change, update or fix some of your personal data through your account or send us an email at support@betterme.tips.

    Object to, or limit, or restrict, use of your personal data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held) by sending us an email at support@betterme.tips.

    Access your personal data: You can ask us for a copy of your personal data through your account or send us an email at support@betterme.tips. You can ask us for a copy of your personal data in machine readable form by sending us an email at support@betterme.tips.

    Lodge a complaint with a supervisory authority: For this you may contact Office of the Commissioner for Personal Data Protection of Cyprus at http://www.dataprotection.gov.cy/.

  5. CHILDREN'S PRIVACY

    Although our Service is a general audience service, we restrict the use of our Service to individuals age 16 and above. We do not knowingly collect, maintain, or use personal data from children under 16 years of age, and no part of the Service is directed to children under the age of 16. If you learn that your child has provided us with personal data without your consent, you may alert us at support@betterme.tips. If we learn that we have collected any personal data from children under 16, we will promptly take steps to delete such information and terminate the child’s account.

  6. INTERNATIONAL DATA TRANSFERS

    BetterMe is a global business. We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms of Service. These countries may not have the same data protection laws as the country in which you initially provided the information. We deploy safeguards if we transfer personal data originating from the EU/EEA to other countries not deemed adequate under applicable data protection law. In particular, as a legal basis for data transfer from the EU/EEA we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the EU-U.S. Privacy Shield Framework (details available here), or (iii) the European Commission adequacy decisions about certain countries (details available here).

  7. CHANGES TO THIS PRIVACY POLICY

    We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, we will provide notice through our Service, or by other means, to provide you an opportunity to revise changes before they become effective. If you disagree with the changes to this Privacy Policy, you should stop using Service. Your continued use of our Service after we send a notice about our changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

  8. CALIFORNIA PRIVACY RIGHTS

    This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

    For more details about the personal information we have collected, including the categories of sources, please see Section 1 above. We collect this information for purposes described in Section 2 of this Privacy Policy. We may also share your information with certain categories of third parties as indicated in Section 4.

    Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

    California consumers may make a request pursuant to their rights under the CCPA by contacting us at support@betterme.tips. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.

    Access rights under California’s Shine the Light

    California also provides its residents with additional access rights. Under Shine the Light law, the residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.

    To obtain this information from us, please send an email message to support@betterme.tips, which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

  9. DATA RETENTION

    We will retain your personal data for as long as you maintain an account or as needed to provide you the Service. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  10. 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.

  11. PERSONAL DATA CONTROLLER

    BetterMe Limited, a company registered in the Republic of Cyprus with registration number HE 385565 and having its registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Service.

    If you have any questions about how we protect or use your data, please email us at support@betterme.tips.

  12. CONTACT US

    You may contact us at any time for details regarding this Privacy Policy. For any questions concerning your account or your personal data please contact us at support@betterme.tips.

This Privacy Policy was posted on December 27, 2019. It is effective upon acceptance for new users, and from December 27, 2019 for all other users. This Privacy Policy is incorporated into, and is subject to the Terms of Use.