Privacy Policy
Last update: August 3, 2022
This Privacy Policy explains how Palta Labs Inc. (further will be referred as “we” or “us”) collects, stores, uses and protects your Personal Data in connection with usage of our website https://paced.com and our application Paced (together referred to as the “Services”). This policy also explains your personal data protection rights, and we are happy to help you exercise them. We value your privacy and do our best to ensure its security.
1. What data we collect and why
When you use our Services, we may collect the following data:
| Data Category | Collection means | Purpose of collection and processing | Legal basis for collection and processing |
|---|---|---|---|
| Technical information (hardware model; device type; unique device identifiers; operating system information; browser type; IP address; platform; system language; Wi-Fi status; time stamp and zone etc.) | Collected automatically | We use such information while analyzing error reports and performing error correction | Art. 6.1 (f) – we have a legitimate interest to process these data |
| We use such information for analytics purposes in order to improve our Services | |||
| Technical information related to your use of our Services (your clicks, installations, your communications with our team, etc.) | Collected automatically | We use such information for analytics purposes in order to improve our Services and marketing activities | Art. 6.1 (f) – we have a legitimate interest to process these data |
| Your name and your e-mail | You provide it to us | We may use such information to process your requests | Art. 6.1 (b) – we perform our contractual obligations |
| We may use such information if you subscribe to our newsletter. You can opt out of it anytime by contacting us at [email protected]. | Art. 6.1 (a) – we receive your consent | ||
| We may use such information for contacting you in connection with any researches and/or sweepstakes, if you have previously consented to it. You can opt out of it anytime by contacting us at [email protected]. | Art. 6.1 (a) – we receive your consent | ||
| ID documentation | You provide it to us | We may request such information in order to prove your identity in certain cases | Art. 6.1 (c) – we have a respective legal obligation |
| Google / iOS calendar integration data (including event titles, emails of invitees, locations of events, other calendar metadata) | You allow access to your Google/iOS calendar | We use this information for the provision of the Services only. We do not transfer the data to any third parties, except as provided in the Privacy Policy, do not use such data for advertisement purposes. | Art. 6.1 (f) – we have a legitimate interest to process these data |
| We use such information for analytics purposes in order to improve our Services | |||
| Your data derived from integration with Apple Health (your activities, sleep data and cardio performance) | You allow access to your Apple Health account | We use this information for the provision of the Services only. We do not transfer the data to any third parties, except as provided in the Privacy Policy, do not use such data for advertisement purposes | Art. 6.1 (a) – we receive your consent |
| Information about your activities | You provide it to us through the application | We use this information for the provision of the Services. | Art. 6.1 (b) – we have respective contractual obligations |
| This information is processed for analytics purposes to provide you with better user experience. | Art. 6.1 (f) – we have a legitimate interest to process these data |
If the user chooses to take part in our early adopter program, we will also store the following categories of data:
| Data Category | Collection means | Purpose of collection and processing | Legal basis for collection and processing |
|---|---|---|---|
| Other data you choose to share with us during the interviews | You share with us | We use this information for the provision of the Services only. | Art. 6.1 (b) – we perform our contractual obligations |
All the above data are collectively referred to in this Privacy Policy as “Personal Data”.
2. How long we retain your Personal Data
We retain your Personal Data for no longer than is necessary for the purposes of its collection and processing but no longer than for 3 years, unless we are required to retain your Personal Data for a longer period due to applicable legislation requirements, any ongoing dispute resolution or in order to enforce our agreements.
3. What are your data protection rights?
We want to make sure that you are fully aware of all your data protection rights and they ways you can exercise them. You are entitled to the following:
The right to access. You can ask us for a confirmation that we process your Personal Data with the information related to its processing.
The right to data portability. You can request that we provide you with your Personal Data in a structured and portable format. Apart from that, you can ask us to transmit those data to another controller directly, where technically feasible.
The right to correction. You can ask us to correct your Personal Data if you believe that it might be inaccurate.
The right to erasure. You may ask us to erase your Personal Data upon your withdrawal of the consent to processing if you believe that such processing is unlawful. You may also ask us to erase your Personal Data in some other cases indicated in art. 17.1 of the GDPR. Please note that erasure of your Personal Data may affect your use of our Services.
The right to restrict processing. You can request a restriction of your Personal Data processing if you contest the accuracy of your Personal Data
The right to object to processing. You can object to the processing of your Personal Data that is processed under certain legal bases - for example, the data that we process under the legitimate interest basis.
The right to lodge a complaint with your local data protection supervisor. You can do so in case you believe that our activities are not compliant with the applicable data protection regulations. However, if you have such concerns about our data protection activities, we would kindly ask you to first contact us at [email protected] and we will do our best to ensure proper handling of your Personal Data.
If you wish to exercise any of the rights 3.1 – 3.6 above, please contact us at [email protected] and describe your request in the plain language. If you make a request, we have 30 calendar days to make respective actions in connection with your request. In case we need any more time to help you exercise any of your rights, we will let you know.
In case your request is vague or unclear, we may engage into a conversation with you in order to better understand your request. We may also refuse manifestly unfounded and excessive requests.
We might ask you to prove your identity while exercising your data protection rights. This is made to ensure that you are indeed entitled to receive certain information and that no rights of third parties are violated by your request.
4. Security measures
We take the protection of your Personal Data very seriously and take all reasonable and appropriate measures to protect them from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the Services, or that your information won’t be intercepted while being transmitted to us. In case your Personal Data got compromised due to a security breach, we will act promptly to identify the cause and take all reasonable steps to remedy the breach. We will inform you of the incident, if necessary, in connection with the applicable legislation.
If you want to report a security incident related to our Services, please contact us at [email protected].
5. Children’s privacy
We are committed to protecting the privacy of children. We do not knowingly collect Personal Data of any person under the age of 13 (of 16 years old for the residents of the European Union). If you are aware of anyone under 13 (or 16 years old for the residents of the European Union) using the Services, please contact us at [email protected] and we will take required steps to delete such information and (or) delete the account.
6. Sharing of your Personal Data
We may use external service providers to process your Personal Data on our behalf. When we do so, we have appropriate agreements in place to protect such data. In the case of international transfers, we always make sure that additional safeguard mechanisms are in place (for example, by adding Standard Contractual Clauses).
Currently we share your Personal Data with the following service providers:
- Amplitude, Inc. (USA), Google Firebase (USA), Supabase, Inc (USA) – these processors perform data analytics services, which enable us to improve the functionality and usability of our Services and give us data vitally important for our marketing strategy;
- Palta Brain (Palta Software Ltd) – Cyprus – this processor performs data analytics services, which enables us to improve the functionality and usability of our Services and gives us data important for our marketing strategy;
- Sentry (Functional Software, Inc.) – USA – this platform assists in error processing that helps us resolve technical issues occurring to our Services and improve their functionality;
- Appsflyer Ltd. – Israel – this processor provides attribution and marketing analytics services. It helps us reach more people on different platforms and analyze our marketing campaigns.
7. Changes to our privacy policy
We review our policies regularly to reflect any changes in our collection, processing, sharing or retention procedures as well as any regulatory changes. You can always find the up-to-date version of our Privacy Policy on our website with the indication of the last update date.
Contact Us
You can contact us using the following email: [email protected].
You can also contact our EU representative: DPOEU LTD, Office 902, Oval, Krinou 3, Ayios Athanasios, 4103, Limassol, Cyprus. Email: [email protected]
