Updated: 13th August 2020
Insofar as we have developed this application and maintain it’s futher activity, thus we care a lot about privacy. Therefore, we strictly adhere to all applicable data protection procedures regarding the complete and comprehensive security of your personal data. We are the merchants - software and application developers “Smartwatch Sync technology” which owns “SmartWatch Sync & Bluetooth notifier”(hereinafter - Application).
In what way do we use your personal data?
We use your personal data to make our Application work quickly and efficiently. The main purpose of the processing of your data is to ensure your experience of our Application usage will be comfortable and constant. Also, we use your data for other reasons such as safety and security, customer support, communications from us, marketing purposes, compliance with legal obligations, accounting requirements and software development.
What are the legal grounds for data processing?
Before proceeding to the processing of your personal data we assess and check the data that we collect and after that, we determine the legal basis of processing. We use the following basis to collect and process your personal data: performance of a contract, compliance with legal obligations, our legitimate interest, and your active consent.
What categories of personal data do we collect?
You may find below the specific personal data categories and the relevant purposes of such collection and (or) processing which we proceed.
|Description of the purpose we process your personal data (“processing purpose”)||Categories of personal data we use for||Legal basis for the processing purpose||The term of storage|
|Safety and security||- Third-party data; - Google Account ® data.||Legitimate interest||Up to 3 (three) years|
|Marketing||- Account registration data; - Data that we receive automatically;||Legitimate interest and your Consent*||As long as our Application is installed|
|Location data.||As long as our Application is installed on your Devices|
|Compliance with legal obligations||- Account registration data; - Data that we receive automatically - Data collected via Application; - Payment data.||Compliance with legal obligations||Up to 3 (three) years|
|Research and development||- Account registration data; - Data that we receive automatically; - Data collected via Application.||Legitimate interest||As long as our Application is installed on your Devices|
* After installing our application on your device we shall ask your consent to (or the acceptance with):
• uses-permission android:name=android.permission.ACCESS_FINE_LOCATION Allows the app access to the exact location. Used to access the location required to find Bluetooth devices in range. • uses-permission android:name=android.permission.FOREGROUND_SERVICE Allows the application to use the Service.startForeground. Used to perform background work necessary for a stable Bluetooth connection between paired devices. • uses-permission android:name=android.permission.VIBRATE Allows app access to use vibration Used permissions to use system vibration in the app (specific use - notifying the user with vibration about new messages) • uses-permission android:name=android.permission.INTERNET Allows an application to open network links. Used to access the app to the internet, as well as app updates • uses-permission android:name=com.android.vending.BILLING Allows the app to use the in-app purchase feature. Used to enable monetization, namely purchases and subscriptions related to the application. • uses-permission android:name=android.permission.ACCESS_NETWORK_STATE Allows applications to access information about the state of the networks in use. Used to obtain information about the status of the network used (specific application - rejecting Internet requests when the network is not connected) • uses-permission android:name=android.permission.WRITE_EXTERNAL_STORAGE Allows an application to save data to external storage. Used to access files in the device storage (specific application - the ability to create and send a screenshot to tech support) • uses-permission android:name=android.permission.READ_EXTERNAL_STORAGE Allows the application to see external storage. Used to access readable files from the storage (specific application - the ability to create and send a screenshot when contacting support) • uses-permission android:name=android.permission.BLUETOOTH Allows the app to connect to devices with Bluetooth connectivity. Used to access Bluetooth devices to other paired devices via Bluetooth, to exchange information between gadgets (for example, send information) • uses-permission android:name=android.permission.BLUETOOTH_ADMIN Allows the application to discover and pair Bluetooth-enabled devices. Used to be able to pair the gadget with bluetooth devices, as well as to make the current device visible (a specific application is a connection to exchange information about notifications). • uses-permission android:name=android.permission.ACCESS_COARSE_LOCATION Allows an app to access approximate location • uses-permission android:name=android.permission.WAKE_LOCK Allows the app to prevent the phone from going to sleep. • uses-permission android:name=android.permission.RECEIVE_BOOT_COMPLETED Allows an application to receive the Intent.ACTION_BOOT_COMPLETED that is broadcast after the system finishes booting
These types of data may be stored by the third parties. Therefore, we neither keep, nore store these types data on our servers.
We require your consent to grant you with the further access to our Application and to ensure the robust and consistent Application performance and to be compliant with legal requirements. We are not intended to collect and (or) process your Personal Data until obtaining your clear and active consent.
How do we share and disclose your data?
We may share your personal data under the following conditions: Safety, Legal purposes, and Law enforcement. We will disclose your personal data to third parties to the extent necessary to:
•comply with a government request, a court order or applicable law; • defend ourselves against third-party claims; • assist in fraud prevention or investigation; • comply with the Google ® Monetization and Ads policy .
Subcontractors and Service providers. We may share your personal data with some service providers, which may process data on our behalf. For example: third-party developers, accountants, subjects who operate applicable payment systems, etc. We usually may transfer your personal data only to the subjects who are located in countries, where adequate level of data protection previously was confirmed by Government authority. You may find the list of such countries by clicking here .
With your personal and active consent. In cases where you have provided your consent, we may share your personal data, as described at the time of consent.
How do we handle your personal data?
Security Measures. We provide and implement industry-standard physical, electronic, and procedural safeguards to protect our users’ personal data we collect, process and maintain. For example, data which we receive is available only to authorized employees and to those subcontractors, who preliminary have concluded Data Processing Agreement.
If you have any doubts or reason to believe that your interaction with our Application is no longer secure and safe, please immediately notify us by contacting us via email at [email protected]
Retention of your personal data.
How can you manage your personal data?
In case you would like to access, review, update, rectify, and delete any personal data we received and hold about you, or exercise any other of your rights such as a right to object or restrict processing and a right to data portability, or the right to be forgotten, you can email us directly to [email protected]. In case you want to change the way we handle your data, you have a right to lodge a complaint with a supervisory authority. By following this link you may find your National Personal Data Authority.
However our Application is accessible for adults and children, we do not purposefully or knowingly collect or solicit personal data from anyone under the age of 16 (sixteen). If you believe or have any suspicious or reasons to believe that a minor has disclosed data to us, please contact us at [email protected] In case you are under 16 years old age, please do not attempt to send any personal data about yourself to us. If we learn that we have collected personal data from a child under age 16, we will delete that data as prompt as possible. If you believe or have any suspicious or reasons to believe that a minor has disclosed data to us, please contact us at [email protected].
We take care that our Application and related content that is accessible to children is appropriate for children.
Therefore, to comply with special requirements set by Developer Program Policy (effective January 20, 2021) we implement new methods and procedures in our internal processes, such as:
- using only certified ad SDKs;
- ensure ads displayed to those users do not involve interest-based advertising (e.g. we do not target the advertising at individual users who have certain characteristics based on their online browsing behavior);
- we do not use remarketing (advertising targeted at individual users based on previous interaction with an app or website);
- ensuring ads displayed to those users present content that is appropriate for children;
- ensuring ads displayed to those users follow the Families ad format requirements, set in Google Developer Program Policy;
- ensuring the compliance with all applicable legal regulations and industry standards relating to advertising to children;
- ensuring that our Application that solely targets children does not contain any APIs or SDKs that are not approved for use in child-directed services.
Also, we declare that:
- we do not collect any sensitive information and data related to children, such as, microphone and camera sensor data.
However, we may collect device data, Android ID, ad usage data, and advertising ID.
- we do not transfer the User location data to any third parties;
- we do not transfer any User’s sensitive personal data to the third party without obtaining prior consent in such transfer.
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