PRIVACY POLICY

Last Updated: 14 August 2023

For Amila Tech Ltd, the security of your personal data is of paramount importance. Ensuring a transparent process of personal data processing, which allows you to independently control such processing, holds great significance in building a trustworthy relationship with you. In this regard, the Privacy Policy is developed to provide you with up-to-date information on what we and affiliated companies (jointly referred to as “Amila” or “we”, “us”, “our”) do with your personal data.

This Privacy Policy applies to Amila’s Period Tracker App (the “App”) as a guide to understand your rights and our obligations. It shows you how your data is being processed.

Table of contents

1.        HOW DO WE PROCESS YOUR PERSONAL DATA?

2.        RETENTION OF PERSONAL DATA

3.        WHO HAS ACCESS TO YOUR PERSONAL DATA?

4.        YOUR PRIVACY RIGHTS

5.        OTHER INFORMATION ABOUT PROCESSING

6.        OUR CONTRACT DETAILS

1. HOW DO WE PROCESS YOUR PERSONAL DATA?

1. The Privacy Policy applies to relationships related to our processing of personal data of users Period Tracker App.
2. Amila performs the following actions with personal data: collection and disclosure by transmission (the latter does not apply to special personal data).
3. We collect personal data about you in either (a) automatically when you use our App or (b) directly from you. We collect personal data from you to the amount which is strictly necessary to fulfil the purposes of processing. Categories of personal data that we process are specified below.

1. Personal data we collect automatically

2. Personal data you provide to us directly

2. RETENTION OF PERSONAL DATA

1. We exclusively collect your personal data without retaining it. All personal data is exclusively stored on your devices as long as you’re using our App.
2. Our third-party collaborators adhere to a data retention policy, ensuring the removal of your personal data according to each third-party collaborators' privacy policies, but in any case, but this does not exceed 2 years from the point of collection. For example, Google Analytics retains data for 2 months, Google Firebase – for 90 days.

3. WHO HAS ACCESS TO YOUR PERSONAL DATA?

1. We may engage third-party service providers as follows:

• Advertising Networks. We may collaborate with advertising networks to exhibit advertisements, which can be personalized. These networks may gather particular information about how you interact with the App and use it to provide advertisements based on your preferences and interests. For this propose we engage following third-party:

Google Inc. (Google AdSense)

Privacy Policy: https://policies.google.com/privacy

https://policies.google.com/technologies/partner-sites

• Analytics Platforms. To improve our App’s quality and provide a better user experience, we may utilize analytics platforms that gather and analyze data on our behalf. These platforms help us understand user behavior and App performance, among other things. The data collected is aggregated and anonymized to safeguard your privacy. For this propose we engage following third-party:

Google Inc. (Google Analytics, Google Firebase)

Privacy Policy: https://policies.google.com/privacy

https://policies.google.com/technologies/partner-sites

https://firebase.google.com/support/privacy?hl=ru

2. We may occasionally engage other third-party service providers. The list of such contractors could be subject to changes, but each time before transferring your personal data to new counterparties, we:

• assess the level of adequacy of personal data protection by such third-party service providers;
• enter into a Data Processing Addendum with such third-party service providers.

Moreover, we ascertain the existence of legitimate bases for cross-border data transfers (if applicable). The details concerning the utilization of these entities will be expeditiously incorporated into this Privacy Policy.

3. Please note that we may engage reputable partners located outside the EU and EEA in our operations for specialized services. While our preference is to engage partners within the EU or EEA where data protection standards are aligned with the General Data Protection Regulation (GDPR), there may be instances where we need to collaborate with reputable partners located outside these regions. We carefully select partners who meet stringent data protection standards and establish comprehensive data protection agreements to ensure the privacy and security of personal data. Our commitment to data protection remains consistent across all partnerships.
4. PLEASE NOTE THAT WE DON’T DISCLOSURE BY TRANSMISSION YOUR SENSITIVE PERSONAL DATA TO THIRD PARTIES.

4. YOUR PRIVACY RIGHTS

1. You have the following rights regarding the processing of your personal data:

1. Access to your personal data. You have the right to access a copy of your personal data, along with any supplementary information.
2. Restriction of processing. You can restrict of processing your personal data under specific conditions, such as when its accuracy is contested, when the processing is unlawful or when you have objected to the processing.
3. Erasure of your personal data. You can delete or remove your personal data in certain circumstances.
4. Rectification of your personal data. You can correct incomplete or inaccurate personal data.
5. Right to data portability. This right applies to information processed based on your consent or a contract (Terms & Conditions). You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and, if technically feasible, transmit it to another data controller.
6. Right to object to the processing of your personal data. If we rely on legitimate interests for processing your personal data, you have the right to object to such processing based on your specific situation.
7. Right to withdraw consent. If you provided explicit consent for the processing of your personal data, you have the right to withdraw your consent at any time.
8. Right to lodge a complaint. If you believe that our processing of your personal data violates applicable legislation, you have the right to lodge a complaint with a supervisory authority.

1. For the execution of the rights as stipulated in sections 4.1 (a), (c), (d), (e), and (g), you can effectuate these actions through the functions within the App (“Settings” – “Manage privacy options”).
2. For the execution of the rights as stipulated in sections 4.1 (b) and (f), contact us using the contact information provided in this Privacy Policy. We will review your request as soon as possible, but not more than within 1 month. Please note that this period may be extended for an additional 2 months, if necessary, based on the complexity and number of your requests. In that case, we will tell you about the extension within 1 month of receipt of your request and explain the reasons for the delay.

5. OTHER INFORMATION ABOUT PROCESSING

1. Security measures. To protect your persona data, we have taken the following steps:

• abstained from implementing a server-side system;
• implemented confidentiality commitments with all our employees, supplemented by comprehensive training sessions that underscore the importance of safeguarding personal data;
• adopted a highly restricted approach in selecting third-party services for integration into our applications, with contractual agreements established for each such entity.

2. Age limits. We do not intentionally collect or request personal data from individuals under the age of 16, nor do we permit such individuals to use our App. If you’re below the age of 16, please refrain from providing us with any personal data. If we discover that we’ve obtained personal data from a person under the age of 16, we will delete it immediately. If you suspect that we possess any personal data about or from someone under the age of 16, please reach out to us through the contact information provided.
3. Profiling. The App feature profiling functionalities that analyze personal data and potentially other user-related information. Through this process, the App generate predictions concerning the duration of the menstrual cycle, calculation of ovulation days, and similar outcomes. To the extent that these actions could be considered profiling according to the definition set out in applicable personal data legislation, we do not undertake any other actions that could potentially be regarded as profiling.

6. OUR CONTRACT DETAILS

1. If you have any questions about this Privacy Policy, please contact us using the address provided below:

Amila Tech Limited

44 Georgiou Griva Digeni, Atlantic House, 4th floor, 8047

Paphos, Cyprus

developers.amila@gmail.com

2. Be also informed, that since we are registered under the law of the Republic of Cyprus, the personal data authority overseeing us regarding the personal data processing is Commissioner for Personal Data Protection. In case you have any doubts how we process your personal data, you may contact the personal data authority of the Republic of Cyprus anytime.

You may also contact your local data protection authority. A list of local data protection authorities is available here.