Privacy Policy

Last updated April 10, 2019

This Privacy Policy is aimed to inform you (“You”) as a user of Fitty (“Application”, “Service”) about the information Burgen Valley Limited (“we”, “us”, “our”), with registered office at Suites 41/42, Victoria House, 26 Main Street, GX11 1AA, Gibraltar, as the Application developer, collects, how that information may be used, with whom it may be shared, and Your options about such use and disclosure. This Privacy Policy is incorporated into, and is subject to, the Application’s Terms of Use. We shall not collect, use or share Your information except as described in this Privacy Policy.

By choosing to use our Service You explicitly: (I) agree to the collection and use of information in relation to this policy, (II) warrant and guarantee that You are over 16 years of age (or are a parent or guardian with such authority to agree to this Privacy Policy for the benefit of an individual under 16 years of age). Please do not use the Application or access the services provided by it if You do not agree to this Privacy Policy.

What kind of information do we collect?

We may collect information that can identify You, such as Your name and email address (“Personal Information”), and other information that does not identify You, as listed below.

Information you provide

• the contact information You provide, such as name, email address, and Your photo (if applicable). We may collect and store the above-mentioned information when You register and use the Service or provide it to us in some other manner, for example by corresponding with us (by email or chat, for instance) when You report a problem with the Service or when You subscribe to any of our services, search for a service or share data via any of the social media functions on our Service;
• the personally identifiable information You provide, including information about Your physical state, such as height, actual weight, desired weight, areas of Your body which You consider concerning, and demographic information such as age and gender;
• social links. When You choose to link Your social media account to Your Service profile, we collect Personal Information from that social media website. For example, when You link Your Facebook account, we may collect the Personal Information You made publicly available on Facebook, such as Your name, user ID, profile picture, cover photo, username, gender, networks, age range, language, country, friend list, and any other information You have made public. Please also note that Facebook receives information about how You use the Application. For information about the purpose and extent of data processing, the further processing and use of data by Facebook, and Your rights and setting options to protect Your privacy, please refer to the Facebook data privacy policy: http://www.facebook.com/policy.php. You can also find more detailed description of Facebook use of Your Personal Information herein below. We may also obtain other non-public information from social media websites should You give them Your permission to provide us with such information.

Note: Information about a third party

When You provide us with information about a third party, You must have the consent of that third party before providing us with that information. By providing us with information regarding a third party You warrant that You have their permission to provide that information to us.

Information collected automatically

• Device and Usage Information that may include information specific to Your mobile device (e.g., model, operating system, mobile device id (similar to a website IP address); information about Your logging in, use of features, functions, or notifications on the device. We also collect and use Your Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID) to recognize Your device and support advertising activities on our Services. These number values are not permanently tied to Your device and, depending on Your operating system, You can reset it through Your device settings.
• Cookies. A cookie is a small amount of data stored on Your device used as an anonymous unique identifier. Please note that cookies commonly do not contain personal information. This Service does not use these cookies explicitly.

What do we collect this information for?

• enhancing Your user experience on our Service by operating, maintaining, and providing You with all of the content and features of the Services;
• managing Your account and providing You with customer support. We may use Your Personal Information to respond to Your requests for technical support, Service information or to any other communication You initiate (“customer support purposes”);
• performing research and analysis about Your use of, or interest in, our products, services or content, or products, services or content offered by others (“analytics purposes”);
• communicating with You via email, push notifications and/or through other digital methods about products or services that may be of interest to You either from us or other third parties. You can opt out of receiving push notifications by changing the settings on Your device;
• developing and providing content and advertising tailored to Your interests on our Service and other third party services (“marketing purposes”);
• detecting and resolving any fraud or other illegal or undesirable user behavior;
• performing background checks on users and taking other legally-required actions.

With whom and what do we share this information for and how may we disclose it?

Service Providers

We may share Your Personal Information with third parties that perform certain services on our behalf, such as our authorized service providers or analytics providers. In general, the third-party providers engaged by us will only collect, use and disclose Your information to the extent necessary to allow them to perform the services they provide to us, e.g. facilitating our Service and analyzing how our Service is used. Please note that they are obligated not to disclose or use the information for any other purpose.

Hereunder You can find more detailed list of some third parties - service providers with whom we may share Your Personal Information as described above, along with links to such service providers privacy policies, which we recommend You read:

1) AppsFlyer

We use AppsFlyer for analytics and marketing purposes as described herein above.

As for analytics purposes, Appsflyer helps us to understand, in particular, how users find our App (for example, which advertiser had delivered an ad that led You to our App in App store). Appsflyer also provides us with different analytics tools that enable us to research and analyze Your use of the Service.

As for marketing purposes, Appsflyer helps us to tailor our and third parties ads to Your interests and show the relevant ads to You.

In order to receive those services from Appsflyer, we share such data as:

• device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier (“Technical Information”);
• IP address (which may also provide general location information), User agent, IDFA (Apple identifier for advertisers), Google Advertiser ID and other similar unique identifiers (“Technical Identifiers”);
• information relating to our ad campaigns and Your actions in the App, such as: clicks on the ads, ad impressions viewed, the URL from the referring website, downloads and installations of Applications, and other interactions, events and actions, such as add to cart, in-app purchases made, clicks, engagement time etc. (“Engagement Information”).

Please read AppsFlyer privacy policy regarding its collection and use of data in order to perform services for us, available at https://www.appsflyer.com/services-privacy-policy, to acknowledge how AppsFlyer operates Your Personal Information. Please note that You may cancel collection of Your Personal Information for and sharing it with AppsFlyer using this link: https://www.appsflyer.com/optout.

2) Facebook

Application has not been using Facebook Analytics services as of v.2.1.1 for AppStore.

We use Facebook for analytics and marketing purposes as described herein above.

As for analytics purposes, we use an instrument called Facebook Analytics from which we get, in particular, aggregated demographics and insights on how many people launch our app, how often users make purchases and other interactions.

As for marketing purposes, we use instruments called Facebook Ads Manager and Facebook Custom Audience, which allow us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose aggregated users groups based on certain criteria (age, sex, Facebook preferences), that are a potential Application targeted audience. As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while You are using Facebook or other Facebook’s products (for example, Instagram).

In order to receive those services from Facebook, we share such data as:

• Explicit events - information from events that we explicitly configure the Application to send, such as "AddtoBasket" or "logPurchase", along with any additional parameters provided.
• Implicit events - information from events that are logged implicitly, if we choose to make use of other features of the Facebook SDK, such as integration with Facebook Login or the "Like" button.
• Automatically logged events - basic interactions in the Application (e.g., Application installs, Application launches) that are collected automatically.
• Facebook app ID - a unique identifier provided by Facebook to reference our website and Application.
• Mobile advertiser ID - the iOS IDFA (Apple identifier for advertisers).
• Technical Information and Identifiers - the mobile OS type and version, Application name, Application version, the device opt-out setting, Your user agent string and IP address, along with the following device related metrics: time zone, device OS, device model, carrier, screen size, processor cores, total disk space, remaining disk space.

Please read Facebook privacy policy regarding its collection and use of data in order to perform services for us, available at https://www.facebook.com/policy.php, https://www.facebook.com/full_data_use_policy, to acknowledge how Facebook operates with Your Personal Information. Please note that You may choose which ads in particular to receive (or not to) via Facebook by visiting the following link: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

3) Amplitude

We use Amplitude for analytics and customer support purposes as described herein above.

As for analytics purposes, Amplitude helps us to understand, in particular, how users find our App (for example, which advertiser had delivered an ad that led You to our App in App store). Amplitude also provides us with different analytics tools that enable us to research and analyze Your use of the Service.

As for customer support purposes, Amplitude helps us to respond to Your requests for technical support. For example, it enables us to track Your interaction with our App and in order to detect particular technical issues with our App.

In order to receive those services from Amplitude, we share such data as:

• age, gender, email, locale, referral source, plan type (“user related information”);
• Platform, device type, device family, country, city, region, carrier, OS, language, IP Address (“technical information”);
• Your interaction with the App (i.e. taps on the particular screens).

We may also share Your Personal Information with the Apple HealthKit application installed on Your device, provided You expressly gave a permission for that in the Apple HealthKit App. Personal Information may be shared only to the extent required by the Apple HealthKit App, so for more information on it please see http://www.apple.com/ios/health/.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for Your purchase-related transactions. For these providers, we recommend that You read their privacy policies, so that You can understand the manner in which Your Personal Information will be handled by these providers. For example, Apple may be such third-party company that provides payments and it can be contacted through its website: https://www.apple.com.

Information Disclosure

We may disclose information:

• in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
• when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Service terms or other agreements or policies.
• in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Aggregate Data

We may anonymize or aggregate data collected through the Service and use and disclose it for any purpose.

International Data Transfers

Please note that our business is global, so when You provide Personal Information through our Service, the information may be sent to servers located in different countries around the world.

If You reside in the European Economic Area, please note that we take all adequate security measures to provide suitable safeguards due to data transfer to third countries. Our sub-processors located in such countries are also bound by respective data transfer agreements between them and us to provide all available legal security measures in regard to data privacy. Should You have questions concerning data transfer to third countries please contact us at support@fitty.fitness. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

HOW YOU CAN ACCESS YOUR INFORMATION

If You would like to update or correct any information that You have provided to us through Your use of the Service, You may use the Service to do so. If You need help with rectification of data You think is inaccurate, please contact us via email at support@fitty.fitness.

You may also change certain Personal Information in Your account by going to the “Settings” menu or sending an email request to us at support@fitty.fitness.

You can make a request to erase Your Personal Information through the ‘Settings’ menu of this Application. Please note that it may affect the Services provided, and You will not be able to use the full scope of the Services. When we delete any information, it will be deleted from the active database, but it may remain in our archives. Should You require the deletion of such personal information from our archives, please contact us at support@fitty.fitness. Please note that we may be required to keep such information in our archives and not delete it (or to keep this information for a certain time, in which case we will comply with Your deletion request only after we have fulfilled such requirements). Please also note that the erasing of Your Personal Information does not mean the automatic cancellation of Your subscription or refund of Your payments.

You can make a request to receive the Personal Information related to You through the ‘Settings’ menu of this Application. Should You make such a request, You will be required to provide us with an email address, which we would be able to send Your Personal Information to. Please note that You confirm and guarantee that the email address You provide to us in order to receive Your Personal Information shall belong to You and You shall be solely responsible for its correctness and validity and therefore we shall in any case not be liable for any breach of Your Personal Information due to sending it to that email address.

You may object to the processing of Personal Information concerning You for marketing purposes by contacting us at support@fitty.fitness and the related Personal Information shall no longer be processed for such purposes.

Opting-out via Your device

Please note that You may also opt out from collection of Your data for marketing and advertising purposes not only via our Application, but also on Your entire device using:

1) Your device settings

iOS: go to “Settings” -> “Privacy” -> “Advertising” -> “Limit Ad Track”. You may additionally reset Your advertising identifier (this also may help You to see less of personalized ads) in the same section.

You may additionally reset Your advertising identifier (this also may help You to see less of personalized ads) in the same section.

2) and links below:

• Network Advertising Initiative – http://optout.networkadvertising.org/
• Digital Advertising Alliance – http://optout.aboutads.info/
• Digital Advertising Alliance (Canada) – http://Youradchoices.ca/choices
• Digital Advertising Alliance (EU) – http://www.Youronlinechoices.com/
• DAA AppChoices page – http://www.aboutads.info/appchoices

Please note that the result of such objection or cancellation may affect the process of the Services improvement. However, You would still be able to use the App.

If You think that the Personal Information related to You is inaccurate, but You can’t rectify it as described above, You may contact us at support@fitty.fitness to restrict the processing of such data for the period of time we need to verify the accuracy of the Personal Information, which we will inform You of.

You can stop all collection of information by the Application by uninstalling the Application from Your mobile device. You may use the standard uninstall processes as may be available as part of Your mobile device or via the Application marketplace or network.

Security

We place great importance on the security of all personally identifiable information associated with our users. We have security measures (including physical, electronic and procedural measures) to help safeguard Your Personal Information from unauthorized access and disclosure. While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we make all reasonable efforts to prevent it. However, You should bear in mind that submission of information over the internet is never entirely secure.

We do not collect and we are not responsible for the collection or security of payment details.

Links to Other Services

There are a number of places on our Service where You may click on a link directing You away from our Service to access other applications or websites that do not operate under this Privacy Policy. These third-party websites may independently solicit and collect information, including Personal Information, from You and, in some instances, provide us with information about Your activities on those websites. We recommend that You consult the privacy statements of all third-party websites You visit by clicking on the “privacy” link typically located at the bottom of the webpage You are visiting.

Children’s Privacy

This Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from children under 16. If we discover that a child under 16 has provided us with Personal Information, we shall take steps to delete such information and terminate the child’s account. If You are a parent or a guardian and You are aware that Your child has provided us with Personal Information, please contact us so that we will be able to take the necessary actions.

Retention

We will retain Your information for as long as the Application is installed on Your mobile device or as needed to provide You with our Service. If You remove the Application, we will remove Your information and use copies of Your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, You are advised to check our Service occasionally to inform Yourself of any changes. We will notify You of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page. Your continued use of the Application after changes have been posted to the Privacy Policy will constitute Your acceptance of such changes.

Contact Us

Please submit any questions, concerns or comments You have about this Privacy Policy or any requests concerning Your Personal Information via email to support@fitty.fitness.