This use of this online application (“Application”) will result in the collection of some personal data (as hereinafter defined) from users (as hereinafter defined) of the Application. Any questions about this Policy can be directed to Owner as defined below. Owner may be contacted about this Policy at www.asimplethankyou.com.
Summary
The Application will collect Personal Data for the following purposes and when a User is using the following Services:
Full policy
Type(s) of Personal Data collected. Among the types of Personal Data that this Application collects, by itself or through third parties, is camera permission.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Personal Data requested by this Application is mandatory and the failure to provide this Personal Data may make it impossible for this Application to provide its Services. In cases where this Application specifically states that some Personal Data is not mandatory, Users are free not to communicate this Personal Data without consequences to the availability or the functioning of the Application or the Services provided thereby.
Users who are uncertain about which Personal Data is mandatory are welcome to contact Owner.
Any use of Cookies – or of other tracking tools – by this Application or by Owners of third-party services used by this Application serves the purpose of providing the Service requested by the User, in addition to any other purposes described in this Policy and in any Cookie Policy, if available or applicable.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
Methods, Basis and Place of Processing Personal Data
Methods of processing
Owner takes reasonable and appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data, but cannot and does not guarantee security at all points and times. The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Owner, in some cases, the Personal Data may be accessible to certain types of persons in charge or involved with the operation of this Application (administration, sales, marketing, legal, system administration), or to certain external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by Owner. The updated list of these parties may be requested from Owner at any time.
Legal basis of processing
Owner may process Personal Data relating to Users if one of the following applies:
In any case, Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract or otherwise allow Owner to legally act.
Place
The Personal Data is processed at Owner’s operating offices, the offices of Owner’s duly authorized agents, and/or in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Personal Data to a country other than their own. To find out more about the place of processing of such transferred Personal Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Personal Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Owner to safeguard the Personal Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with Owner using the information provided in the contact section.
Retention Time
Personal Data shall be processed and stored for as long as required by the purpose for which such Personal Data has been collected. Therefore:
Therefore:
Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing and retention, as long as such consent is not withdrawn. Furthermore, Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of any court, regulatory or legal authority.
Once the retention period expires, User’s Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Purposes of Processing
Personal Data concerning the User is collected to allow Owner to provide its Services, as well as for device permissions for Personal Data access. Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this Policy.
Device Permissions for Personal Data Access
The exact procedure for controlling app permissions may be dependent on the User’s device and software. Depending on the User’s specific device, this Application may request certain permissions that allow it to access the User’s device data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact Owner for support at the contact details provided in this Policy.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e. accessed to, modified or removed) by this Application.
Camera permission
Used for accessing the camera or capturing images and video from your device.
Detailed Information on the Processing of Personal Data
Personal Data is collected for the following purposes and using the following Services:
The Rights of Users. Users may exercise certain rights regarding their Data processed by Owner. In particular, Users have the right to:
Details About the Right to Object to Processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Owner or for the purposes of the legitimate interests pursued by Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to Owner through the contact details provided in this Policy. These requests can be exercised free of charge and will be addressed by Owner as early as possible and always within one (1) month.
Additional Information About Personal Data Collection and Processing
Legal Action
The User’s Personal Data may be used for legal purposes by Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares and acknowledges that User is aware that Owner may be required to reveal User’s Personal Data upon request of public authorities.
Additional information About User’s Personal Data
In addition to the information contained in this Policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System Logs and Maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (system logs) and/or use other Personal Data (such as the IP address) for this purpose.
Information Not Contained in This policy
More details concerning the collection or processing of Personal Data may be requested from Owner at any time. Please see the contact information at the beginning of this Policy.
How “Do Not Track” Requests are Handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read the respective privacy policies of such third-party services.
Changes to this privacy policy
Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to Owner. It is strongly recommended that User check this page often, referring to the date of the last modification listed at the bottom of this Policy.
Should the changes affect processing activities performed on the basis of the User’s consent, Owner shall collect new consent from the User, where required.
Definitions and Legal References
Application shall deemed to be referring to the means by which the Personal Data of the User is collected and processed.
Data Processor means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Owner as described in this privacy policy.
European Union, unless otherwise specified, shall mean all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Owner means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is Owner of this Application.
Personal Data shall mean any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Service means the service provided by this Application as described in the relative terms (if available) and on this site/application.
Usage Data shall mean information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User shall mean the individual using this Application.
LEGAL INFORMATION
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Application unless otherwise specifically stated within this document.
Latest update: January 9, 2019
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