Privacy policy

1. INTRODUCTION Confidentiality policies of the Sprouty.app by developer Dmitrii Rumbeshta. Before we explain why, when, how, and what personal data the Application collects and processes, we will explain some basic concepts related to personal data protection. We believe that in this way you, as a user or non-user of the Application, can better understand why the Application processes selected data when processing personal data. Personal data Personal data is any information about an identified or identifiable individual (the data subject). An identifiable person is an individual who can be identified, directly or indirectly, in particular by reference to a specific identifier (name, number, network identifier) or to one or more specific elements of the physical, physiological, genetic, psychological, economic, cultural or social identity of the individual. Subject of personal data This refers to the natural person to whom the personal data relates and who can be identified by the personal data or is identifiable. Special categories of personal data (sensitive personal data) This is a new designation for sensitive personal data. It refers to such personal data that in itself could harm the data subject in society, at work, at university or could lead to discrimination against him or her. Such personal data usually reflect racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as the processing of genetic and biometric data in order to uniquely identify the individual and data about his or her health, sexual life or sexual orientation. By deciding to provide this information, the user consents to its processing. Administrator The Administrator is the person or entity that determines the purposes and means of processing personal data and is primarily responsible for its processing. Unless otherwise specified in these principles or conditions for a particular service, the administrator of personal data is the Application. Processor This refers to the natural or legal person who processes personal data for the Administrator based on their instructions. Processing of personal data Processing is any operation or set of operations that are performed on personal data or arrays of personal data, with or without the use of automatic procedures, such as collection, recording, systematization, structuring, storage, clarification or modification, search, review, use, access in transmission, distribution or any other grant of access, arrangement or combination, restriction, deletion or destruction. 
 2. WHAT INFORMATION DO WE COLLECT? By using our App, you are entering into a legal agreement with us, and we are processing your data to provide the service in accordance with the terms of this Privacy Policy. Typically, the App only collects your email address. However, in some cases, we may collect additional information necessary for the provision of our services. 
 3. LEGAL BASIS. Under EU data protection laws, we are required to inform you of our legal basis for using your data. To the extent that we are provided with the consent of the person involved for the processing of personal data, the legal basis for processing is Consent. The legal basis for the processing of personal data necessary for the execution of an agreement, the provision of services, in which the User is one of the parties involved, is the Contractual Necessity. This also applies to processing operations that are required for the performance of pre-contractual activities. If the processing of personal data is necessary to fulfill a statutory obligation that the Application must comply with, the legal basis is Legitimate Interests. If there are vital interests of the User or another natural person that require the processing of personal data, the legal basis is the Legitimate Interest of the User. If the data processing is necessary to protect the legitimate interests of our company or a third party, and the interests, fundamental rights and freedoms of the person involved do not override the previously mentioned interests, the Legitimate Interests of the Application and the third party shall be the legal basis for the data processing. 
 4. WHAT DATA IS COLLECTED ABOUT ME WHEN I USE THE MOBILE APP? When you use the mobile app, we may collect information about your language as well as your location (latitude and longitude). If you have the location feature enabled but want to turn it off, you can do so in the system settings of your device. 
 5. HOW LONG DOES THE APP KEEP MY INFORMATION? We only keep your personal information for as long as we need it for legitimate business purposes and in accordance with applicable law. If we no longer need your personal information, we will securely delete or destroy it.  
 6. WHAT INFORMATION DOES THE APP COLLECT ABOUT ME IF I AM UNDER 18? Our app is not intended for use by individuals under the age of 18, and we do not knowingly collect personal information from anyone under the age of 18.  
 7. WITH WHOM DOES THE APP SHARE MY DATA? We take your privacy seriously and will only share your data when necessary to provide our services or when required by law. We may share aggregate information, which includes your personal information (but which does not directly identify you) along with other information, including third party data, with third parties for market analysis and demographic data in order to display relevant advertising about other products and services. We may share your data with the following categories of third parties: Advertising Partners and Targeted Advertising Providers: We may share your device ID and IP address (and your intended location based on the IP address) with third-party advertising partners and targeted advertising providers for the purpose of displaying relevant ads. Service Providers: We may share your data with third-party service providers who assist us in providing our services, such as payment processors, email services, and analytics providers. We ensure that these parties act in accordance with the data protection and privacy provisions of this Policy and take appropriate measures to ensure the security of your data. Law Enforcement: We may share your personal data with law enforcement when required by law, when a potential crime is being investigated, or when it is necessary to protect someone's vital interests. Fraud prevention and anti-spam services: We may share your email address, phone number, IP address, and IP session information with third-party fraud prevention and anti-spam services to protect our service from criminal activity. We make every effort to ensure that all data remains anonymous, in an encrypted, human-readable form. In the event that the Appendix or any of our partners who legally hold your data transfers business or changes ownership, such as through a takeover by another company or merger, reorganization or sale of all or part of the assets, or in the event of insolvency, we may be required to disclose your personal data. However, we will ensure that any such disclosure is made in accordance with applicable data protection laws and regulations. We believe that these changes will help to provide greater clarity and transparency around how your data is shared and used by the app. Please let me know if you have any further questions or concerns. 

 8. YOUR RIGHTS You have a number of rights under European data protection law if you are an EU citizen. The right to be informed: You have the right to know which personal data is being processed by the organization and for what purposes (this is a notification). Right of access: You can request a copy of your data or have it transferred in a machine-readable format to another provider, as well as review and update your personal information in your profile settings. The right to correction: If your personal data is inaccurate or incomplete, you have the right to have it corrected. The right to erasure: You have the right to have your personal data erased in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected, or when you withdraw your consent to the processing of your personal data. Right to restrict processing: In certain circumstances, you have the right to request that the processing of your personal data be restricted, while still allowing it to be stored. Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format and to transfer it to another provider. Right to object: You have the right to object to the processing of your personal data in certain circumstances, including when it is processed for direct marketing purposes or based on legitimate interests. Rights related to automated decision-making, including profiling: You have the right to be informed when automated decision-making is being used, and to challenge and request human intervention in such decision-making processes. If you would like to exercise any of the rights listed above, please contact us. For your protection and for the protection of our users, we may need to verify your identity before processing your request. If you believe that we have not resolved your issue, you have the right to file a complaint at any time with the Information Commissioner's Office (ICO), the UK data protection watchdog (www.ico.org.uk). If you reside in a country or territory within the European Union (EU) or the European Economic Area (EEA), you can also contact your local data protection regulator. If you reside outside the EU, you may have the right to file a complaint with your local privacy or data protection authority. 

 9. HOW DOES THE APP PROTECT MY PERSONAL DATA? The App takes appropriate security measures to protect against the loss, misuse, and alteration of information under our control, including your personal data. We take reasonable precautions against possible security breaches of our app, website, user database, but no app, website, or data transmission over the Internet is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. 

 10. WHERE IS MY PERSONAL DATA STORED? To ensure that our service runs smoothly we use a network of servers located both within and outside the European Union. Data collected by our advertising partners may also be stored outside the European Economic Area. We guarantee that your personal data will be adequately protected in accordance with applicable legal schemes, including EU-approved templates, and that reliable contractual standards will be implemented. 
 11. FOR WHAT PURPOSES DOES THE APPLICATION USE MY PERSONAL DATA? We use your personal data for the following purposes: To provide and improve our services To communicate with you about our services To respond to your inquiries and requests To detect, prevent, and address fraud, unauthorized access, and other illegal activities To comply with legal obligations and enforce our terms and policies 
 12. CHANGES TO THIS POLICY The Application may revise this Privacy Policy from time to time. The most recent version of the policy always takes precedence in regulating our use of your information.  
 The date this Privacy Policy was last revised: January 12, 2023.  Effective January 12, 2023.