PRIVACY POLICY

Last updated: 20 March 2019
DATA CONTROLLER AND CONTACT DETAILS

VisionAppster
Salvesenintie 6
40420 Jyskä, Finland
(”VisionAppster”)
dpo@visionappster.com

PURPOSE OF PROCESSING PERSONAL DATA

The purposes of processing the personal data are the basic operation of VisionAppster’s services, including user support operations, service maintenance and technical support, responding to inquiries, organizing competitions, collecting statistics regarding service usage, and conducting scientific and market research.

VisionAppster may also use your information for the purposes of creating, administering and troubleshooting accounts, for invoicing, user account management, statistics and development purposes. Data may be used to enable user-to-user communication (e.g. via Development Forum) and to inform users of new products and services, including promotional offers. Personal data may be used to inform of VisionAppster services, such as sending a newsletter or informing about email campaigns or other ways of maintaining the customer relationship.

VisionAppster may use your information to prevent fraud, enforce the relevant terms of service or licenses, and protect users.

As part of data processing the data may be used for profiling purposes and to perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of products and services that VisionAppster provides.

VisionAppster may collect date of birth or personal / business ID, billing or financial account information and tax ID or other similar information for the purposes of 1) providing the VisionAppster Services for Users; and 2) paying a competition participant(s) or winner(s) an awarded prize, subject to competition rules.

The legal justification for processing personal data is fulfilling the contract between the parties or the legitimate interest of the controller, which is based on the relationship between the parties. The legal justification may also be the data subject consent, if the applicable legislation so requires.

You are not required to provide the personal information that we have requested, but, not providing the requested personal information may in many cases means that we will not be able to provide you with our products or services or respond to your queries.

In certain transactions, such as in VisionAppster Store where VisionAppster only provides the Store and transfer of payments by VisionAppster or third-party payment processor as further described in Store Seller’s terms, VisionAppster is in the role of data processor. In such events the data controller such as the seller is responsible for ensuring that it has the necessary rights and has acquired the necessary consents to process personal data. The Seller maintains privacy policy records as required by the data protection legislation.

CATEGORIES OF PERSONAL DATA

VisionAppster may collect following data related to personal information of users using VisionAppster services, downloading VisionAppster software, registering a user account, participants of competitions and other data subjects:

• Name
• Address, email address
• Nationality
• Registering information such as user name and password(s) that users create to access certain VisionAppster services, such as Developer Forum
• IP address and other log information such as device information, browser information, cookie information, date / time of access
• Date of birth or personal / business ID and billing or financial account information and tax ID
• Subscription related information such as subscription type, subscription’s start and end dates
• Newsletter subscription (on/off)
• Consents

SOURCES OF PERSONAL DATA

Most of the personal data that we collect is provided actively by the users themselves, for example when user creates an account and becomes a registered user or when user uses our services as registered user. We may collect personal data also from other users participating in licensing or other transaction or communicating with other users. Users may share information with us that we store on their behalf and use to enhance their experiences. Users may provide us with information when they participate in Development Forum page on the service. User device information and similar information is collected passively while user using our services.

In addition, we may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

We use Google Analytics to understand how our sites are used and to improve, execute and govern experiences within our services. If you want to know more about how Google Analytics works or to exercise choice in regard to the data collected by it, please visit https://policies.google.com/technologies/partner-sites?hl=fi

TRANSFER OF PERSONAL DATA, INFORMATION AVAILABILITY

Personal data may be disclosed to purposes described in this Privacy Policy in accordance with applicable data protection legislation. No information is, however, given to any third party for direct marketing purposes without an explicit permission of the user, excluding legal reasons for giving the information for authorities.

VisionAppster may also share information to safety, security, and legal compliance for the purposes such as to satisfy any applicable laws or regulations. Personal data may be shared or transferred, if VisionAppster explores or undergoes a business transition, such as a merger, acquisition by another company, transfer of control, or sale of assets.

Personal data may be processed by authorized third parties, who process the data on behalf of VisionAppster for the purposes described in this Privacy Policy (for instance, third-party service providers of technical infrastructure or services). Such service providers may use the personal data only according to the instructions from VisionAppster, i.e. only for the purpose for which the data has been collected.

Personal data may be processed outside the EEA or European Union by VisionAppster’s third party payment processors or as between the seller and purchaser in the Store, as further defined in applicable privacy policies of third parties. The transfer of personal data to third countries may be affected by an appropriate transfer agreement in accordance with template clauses currently in force at the EU Commission and/or any other personal data transfer requirements at that time or as otherwise permitted by applicable law. In the event the transfer transaction takes place as between the seller and purchaser in Store, privacy policies of such third parties shall apply. VisionAppster shall not be liable for such transactions and further policies.

INFORMATION SECURITY

VisionAppster takes the security of your personal information very seriously. The information is stored in a secure location and all connections accessing and/ or modifying the information is secured with SSL connection. The information can be accessed only by authorized and authenticated users, who have the obligation of confidentiality. You are, however, aware and understand that you are fully liable for your own actions, including but not limited to the security measures related to your devices and connections. You are also responsible for any personal information you submit in using VisionAppster’s services. You are responsible for studying applicable third party’s privacy policies (such as privacy policy of applicable third-party payment processor or seller in the Store). We advise you to study such policies carefully.

DATA RETENTION PERIOD

The personal data shall be stored for as long as registered user has a valid account and thereafter for the applicable period for limitation of legal claims, and any additional periods required or permitted under applicable law.

RIGHTS OF THE DATA SUBJECT

The data subject has the rights according to the personal data legislation applicable in Finland, including the EU General Data Protection Regulation (GDPR), to inspect his/her personal information, change or request to change his/her information and under some circumstances, the right to request erasure of personal information.

The data subject has the right to receive confirmation from VisionAppster as to whether or not personal data concerning the data subject are being processed. The data subject is entitled to receive a copy of the processed personal data and the personal data undergoing processing. Whether the data subject makes the request by electronic means and he or she has not requested it by any other means, the information shall be provided by electronic means. The data subject has also the right to obtain from VisionAppster the rectification or erasure of personal data concerning him or her and the data subject has the right to prohibit the processing of personal data for direct marketing purposes.

If processing of personal data is based on consent, the data subject has the right to withdraw his / her consent. The withdrawal of consent may, however, affect the usability and functionality of the service in question. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

In certain cases, the data subject has also the right to request from the controller restriction of processing of personal data or otherwise object to processing. Furthermore, the data subject may require the transmission of the personal data, which he or she has provided to the controller in a machine-readable format based on the GDPR. All requests mentioned here shall be provided to the above-mentioned contact person of VisionAppster. Whether the data subject finds the processing of his or her personal data unlawful, he or she has the right to lodge a complaint to the authorities responsible for personal data protection.

COOKIE POLICY

VisionAppster uses cookies and similar tracking technologies such as Google Analytics on its website to help provide, protect and improve the VisionAppster services, to assist with navigation, and to analyse your use of our products and services. A cookie is a small piece of text that is stored on your browser or device by website. It helps the website to remember information about your visit, like your preferred language and other settings. You may refuse to accept cookies or delete cookies already stored on your computer through the settings of your web browser. If you choose to decline cookies, some parts of the service may not work as intended.

CHANGES TO THIS PRIVACY POLICY

VisionAppster reserves the right to change our practices and this policy at any time. We encourage you to check this page regularly so that you know what our current practices are. This description of the personal data processing has been last updated 20.03.2019.