AGEify App Privacy Notice

AGEify App Privacy Notice

-Last updated May 31, 2018 

 

Thank you for choosing to be part of our community at Upcom Bvba (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at privacy@upcom.euWhen you visit our mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Apps and our services. This privacy policy applies to all information collected through our mobile application, (“Apps”), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites”). Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

 

1. WHAT INFORMATION DO YOU COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when registering with the Apps, such as your Date of Birth and Credentials.  The personal information that we collect depends on the context of your interactions with us and the Apps, the choices you make and the features you use. The personal information we collect can include the following: Date of Birth. We can collect your actual Date of Birth or simply a proof that you’re an adult. Credentials. We collect PINs, and similar security information used for authentication and account access. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Apps. We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.

Information collected through our Apps

We may collect information regarding your mobile device, when you use our apps. If you use our Apps, we may also collect the following information: Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.   

 

2. HOW DO YOU USE MY INFORMATION?

We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.  We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive: 

  • To facilitate account creation and logon process with your Consent.
  • To allow you to prove that you are above a certain age to websites that offer age-restricted products, content and/or services.
  • To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

 

3. WILL MY INFORMATION BE SHARED?

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. We only share and disclose your information in the following situations:

  • Service Providers. We may share your information with our business partners (Service Providers) that want to verify that you are above a certain age to access their products, content and/or services.
  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • With your Consent. We may disclose your personal information for any other purpose with your consent.

  

4. HOW LONG DO YOU KEEP MY INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

5. HOW DO YOU KEEP MY INFORMATION SAFE? 

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

 

6. WHAT ARE MY PRIVACY RIGHTS? 

In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

Account Information 

If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements. You can also access your account settings and update your preferences. 

 

7. DO YOU MAKE UPDATES TO THIS POLICY? 

Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

 

8. HOW CAN I CONTACT YOU ABOUT THIS POLICY? 

If you have questions or comments about our policies, you may email us at privacy@upcom.eu or by post to:

Upcom Bvba

ICAB Business & Technology Incubator  

Witte Patersstraat 4 rue des Pères Blancs  

Etterbeek, Brussels, 1040  

Belgium