Privacy Policy for the Unicorn Way mobile app

  1. Definitions and concepts.

“Law” – means the legislation of the Republic of Serbia with all changes and additions.

“Controller” – means the person who is responsible for the processing of the protection of personal data of users.

“Mobile application” is software with all existing enhancements, designed to work on smartphones, tablets, watches and other mobile devices, developed for a specific iOS , Android platform , for the purposes of this policy, mobile application means the following software: ” Unicorn way ” .

“Personal data” – means a set of personal data and / or non-personalized information of the user, provided by him to the copyright holder and / or automatically collected by the copyright holder and / or third parties

“Policy” – means this privacy policy of the mobile application with all existing additions and changes.

“User” – means a legal or natural person who has downloaded a mobile application to a smartphone, tablet, watch and any other mobile device and / or activated such a mobile application.

“Copyright holder” – means the following person who owns the exclusive right to own the mobile application, in this case, the copyright holder is Finlife Venture Partners DOO, duly registered in the Republic of Serbia, located at: Serbia , Belgrade , Brace Jerkovica 219, kv 25, index 11000.

“Processor” – means a person in the understanding, on behalf of the controller, stores and fractions or processes personal data received from users.

” Cookies ” – means small files sent by any mobile application or site placed on smartphones and tablets, watches and other mobile devices of the user, to improve the operation of such applications or sites, as well as the content placed in them

  1. Rights and obligations for the protection of personal data.

In connection with the provision of personal data, the User automatically receives the following rights:

  1. Receive data relating to their processing (grounds and purposes of such processing, methods of processing used, information about persons who have access to them or to whom they can be disclosed on the basis of an agreement or the Law.
  2. receive data on the location and identification data of persons performing the processing of personal data.
  3. receive data on the terms of storage of personal data.
  4. receive data on the carried out or proposed cross-border transfer of personal data.
  5. receive information about the location and identification data of persons storing personal data.
  6. appeal against the actions or inaction of the Copyright Holder to the authorized body for the protection of the rights of personal data subjects or in court.
  7. receive compensation for losses and / or compensation for moral damage in court as a result of violations of rights committed by the Copyright Holder and / or third parties, as a result of violations of the User’s rights to the protection and protection of his personal data committed by the Copyright Holder and / or third parties.
  8. exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.
  1. List of collected personal data.

Non-personally identifiable user information.

In connection with the use of the Mobile Application, the Copyright Holder may automatically collect and process the following non-personalized information about the User:

  1. information about traffic, the possible number of clicks made, logs and other data.
  2. information about the location of the User (geolocation). The User can disable geolocation at any time by changing the settings of the device from which he logged into the Mobile Application. Geolocation is used by the Mobile Application only when the User is actively using such application. When you exit the Mobile Application, geolocation ceases to function.
  3. information about the device (identification number, mobile operator network) from which you log in, operating system, platform, browser type and other information about the browser, IP address.

Personal data about users.

The User may, as part of the use of the mobile application, provide the Copyright Holder with the following personal data about himself:

(1) email address.

(2) a photograph of the User.

(3) data contained in the User’s personal account (profile), as well as other activities of the User’s personal account (profile).

(4) as well as the following data:

display name (nickname) in the profile, system information about the arrangement

(5) data and information obtained as a result of combining certain Personal data of a particular User, as well as data and information received data about the User received from third parties (partners, marketers, researchers).

The user is the only person responsible for the completeness of the personal (personal) data provided and is obliged to change them in a timely manner (update, check, correct) on a regular basis.

The Copyright Holder assumes that all personal (personal) data provided by the User are reliable, and that the User keeps such information up to date.

Using Captcha .

Captcha , which is a type of Cookies, the purpose of which in this case is (1) to protect the User from possible spam from third parties on the Internet, as well as from other irrelevant and / or prohibited content, and (2) identification of the User in order to distinguish him from bots/robots, and (3) improvement of the User’s ability to use the content of the Mobile Application.

Logging into the site through the Mobile App allows Captcha to automatically access and collect the following information:

(1) Cookies set in the browser within the last 6 (six) months; and/or

(2) the number of touches on the touch screen of the device made by the User (the number of clicks made); and/or

(3) web page styling information ; and/or

(4) browser language settings; and/or

(5) plug-ins installed in the User’s browser; and/or

Javascript objects .

Use of cookies

This Mobile Application uses certain Cookies for the purpose of (1) keeping statistics of site visits and traffic, and (2) personalizing the data displayed on the User’s screen, and (3) storing data necessary to identify the User, including when accessed from different devices , and (4) displaying advertisements in accordance with the interests and preferences of the User. The Mobile Application may use both its own Cookies belonging to the Copyright Holder and Cookies of third parties.

The mobile application uses the following Cookies:

(1) Technical (functional) cookies that are needed to control traffic and data transfer, to identify Users and provide access to the content of the Mobile Application to the User and without which the use of the Mobile Application is functionally limited, as well as to prevent the provision of recommendations that do not correspond to interests User.

(2) Statistical Cookies, which are needed to track the frequency of visits to the site by Users, to identify how the User uses the Mobile Application, and to identify the type and type of content that is popular or interesting to the User.

(3) Location Cookies, which are needed to determine the location of the User in order to personalize the content displayed on the screen of his device in the Mobile Application.

(4) Advertising (marketing) Cookies that are necessary for placing advertising and / or marketing announcements in the Mobile Application that correspond to the preferences and interests of the User.

(5) Third party cookies, which are set by third parties with the permission of the User and are intended to carry out statistical research regarding the User’s behavior on the Internet and / or sending personalized advertising or marketing materials to the User and / or the provision of goods or services.

The User has the right to disable cookies in the Mobile Application at any time by changing certain settings in his smartphone, tablet and other devices. Such disabling does not entail limiting or changing the User’s access to the functionality of the Mobile Application and/or content.

4. Purposes of collection and processing of personal data.

Determining the purposes of processing

The collection and processing of Personal Data is carried out for the following purposes:

(1) to analyze the User’s behavior, as well as to identify the User’s preferences for a particular type of content.

(2) for the operational and correct operation of the Mobile Application, improving the operation of the Mobile Application, improving the content of the Mobile Application, improving the internal architecture and functionality of the Mobile Application.

(3) to identify the User.

(4) to provide personalized advertising and marketing materials.

(5) to comply with the requirements of the Law.

(6) to determine the location of the User.

(7) for technical support of the Mobile application, identification of problems in its operation and their elimination.

(8) to maintain communication with the User (communication).

(9) to fulfill other obligations of the Copyright Holder that arose before the User.

(10) to conduct statistical research.

(11) for any other purpose, subject to obtaining separate consent from the User.

The processing of Personal Data is carried out on the basis of the following principles: (1) the lawfulness of the purposes and methods of processing; and (2) good faith; and (3) suitability of the purposes of the processing of Personal Data for the purposes predetermined and declared at the time of collection of such Personal Data; and (4) suitability of the scope and nature of the Personal Data being processed for the stated purposes of their processing.

Conditions for the processing of personal data

The processing of Personal Data is carried out in the following cases: (1) obtaining consent from the User; or (2) achievement by the Copyright Holder of the goals provided for by an international treaty or the Law; or (3) the provision by the User of his Personal Data to an unlimited circle of persons; or (4) fulfillment of other obligations of the Copyright Holder to the User, including, but not limited to, provision of certain content to the User; or (5) saving the life or health of the User when consent to the processing of his Personal Data cannot be obtained in advance.

In case of depersonalization of personal data, which does not allow to directly or indirectly determine the user, the subsequent use and disclosure of such data to third parties.

The Rightholder takes all possible measures to protect the confidentiality of the received personal data, except when the User has made such data publicly available.

The processing of Personal Data is carried out using automation tools and without the use of such automation tools.

5. Access of third parties to personal data.

Use of remarketing services.

The Copyright Holder may use remarketing to advertise the content of the mobile application to the User on other sites visited by the User.

The specified provider collects and processes non-personalized data that does not directly allow to establish or identify the User. The information collected may typically include (1) the content the User viewed, (2) the date and time the User viewed the content, (3) geolocation data. The collection and processing of such non-personalized information makes it possible to provide the User with targeted advertising or marketing content.

By installing the Mobile application, the User agrees to the privacy policy ( Privacy Policy ) and the Terms of Use of the specified remarketing service provider, as well as with the automatic installation of the appropriate Cookies on the User’s device.

The User has the right to refuse such advertising at any time by changing the appropriate settings of the browser and the device from which the Mobile Application is accessed.

Use of analytical platforms

The Copyright Holder uses the analytical platform Google Analytics to (1) track the frequency of visits to the site by Users; (2) tracking how the User uses the Mobile Application and/or its content; and (3) identifying the type and type of content that is popular among Users; and (4) determining the location of the User. The User also gives his consent to the Copyright Holder to use the information received about the User from Google Analytics .

For these purposes, the analytical platform Google Analytics may collect data about the IP address, geolocation, user behavior, as well as user preferences for certain content.

The analytical platform Google Analytics gets access to Personal data to provide the Copyright Holder with an understanding of how effectively his application works, what kind of content is popular, how effective it is to place certain advertisements in it, as well as for developing and / or improving the existing marketing strategy of the Copyright Holder.

By installing the Mobile application, the User agrees to the privacy policy ( Privacy Policy ), as well as automatically installing the appropriate Cookies on the User’s device .

Disclosure of personal data to third parties.

The copyright holder has the right to disclose to third parties, branches and representative offices in the territory of other states; (2) on the result of its liquidation, reorganization of personal data (1) both to its affiliates and to the successors of the Copyright Holder, who received exclusive rights to own the Mobile Application; (2) to third parties solely for the purpose of providing the User with certain content or access to it; (3) to third parties when the User has given consent to the disclosure, transfer or processing of their Personal Data, as well as in other cases expressly provided for by the Law or this Policy.

Copyright Holder discloses Personal Data only if (1) it is sure that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data that the Copyright Holder takes, and (2) consent to such disclosure was previously expressed by the User and/or permitted by law.

Advertising.

The content of the Mobile Application may contain advertising banners and/or links to third party websites. The User’s use of such sites (by clicking on a link or in any other way) may entail the collection, processing and use of Personal Data, as well as the possible automatic transfer of Cookies to the User’s device from which the transition to the site of third parties is made. The Copyright Holder does not bear any responsibility for the methods, methods and procedure for processing Personal Data by third-party sites, as a result of which the Copyright Holder is also not a responsible person in the event that Personal Data is disclosed to an unlimited number of persons in connection with the use of such Sites.

The Copyright Holder strongly recommends that each User familiarize himself in detail with the personal data protection policy of the sites used.

Distribution of promotional materials

With the installation of the mobile application on the device, the User automatically agrees with the Rightholder’s right to send personalized and marketing materials to the provided email address.

7. Sending complaints and requests to the right holder.

Requirement to stop processing personal data.

Each User has the right to express his objection to the Right Holder against the processing and / or storage of his Personal Data. Such an objection can be expressed as follows:

The request must be sent to the Copyright Holder by e-mail: [email protected]

Change (update, addition, correction) or deletion of personal data

The User has the right to independently change or delete his Personal Data at any time, except in cases where such change or deletion may lead to (1) a violation of the rules of this Policy; or (2) in violation of the Law; (3) the nature of such Personal Data is evidence in any litigation that has arisen between the Copyright Holder and the User. To do this, the User needs to delete his personal account (profile) in the Mobile Application.

8. Terms and procedure for storing personal data.

The User agrees to the storage of his personal data by third parties on behalf of the Copyright Holder, provided that such third parties maintain the confidentiality of the received Personal Data.

Storage is carried out during the entire period of use by the User of this Mobile Application.

The Right Holder undertakes to destroy or depersonalize his Personal Data immediately after the termination of the User’s use of the Mobile Application.

9. Access of minors to the mobile application

The use of the Mobile Application is intended for persons over 18 years of age, who access it only subject to the provision of prior consent to the processing of their Personal Data. The Copyright Holder checks the age of the User as follows:

User needs to verify age

If the User is a minor, in which case he must immediately stop using this Mobile Application

Users in the European Union

The use of the Mobile application is intended for persons aged 16 years and older who get access to it only if they provide prior consent to the processing of their Personal Data` The Right Holder checks the age of the User.

10. Procedure for the protection of personal data.

Protecting the confidentiality of Personal Data is a paramount and important task for the Copyright Holder. The Rightholder adheres to all required international standards, rules and recommendations for the protection of Personal Data.

The Rightholder has implemented a number of technical and organizational methods aimed at protecting personal data from disclosure or unauthorized access to them by third parties to ensure the safety and confidentiality of the received Personal Data. The Right Holder uses the following means of protection:

(1) automatic data saving.

For users located outside the Republic of Serbia.

The Right Holder shall store personal data for a reasonable period of time necessary to achieve the purpose of processing, however, not less than the period established by the local legislation of the Member State of the European Union or the Republic of Serbia, on the territory of which the Mobile Application is available, for storing one or another type of Personal Data, after the expiration of the period established for storage, the Copyright Holder undertakes to immediately destroy or depersonalize such data.

11. Rights of users in the field of personal data protection.

According to Chapter 3 of the GDPR, Users located in the European Union and the Republic of Serbia have the following rights in the field of Personal Data protection: (1) the right to receive information about their personal data (” the right to be informed ); and (2) the right to access your personal data (” the right of access “); and (3) the right to correct personal data (” the right to rectification “); and (4) the right to erasure of personal data (” the right to erasure ” ), and (5) the right to restrict the processing of personal data (” the right to restrict processing “); and (6) the right to transfer personal data to third parties (” the right to data portability ), and (7) the right to object (” the right to object “).

12. Final provisions

Users can view the terms of this Policy at the following link:

This Policy may be translated into a foreign language for those Users who access the Mobile Application outside the Republic of Serbia and the European Union.

In case of discrepancy between the original text (English) and its translation, the original language shall prevail.

This version of the Policy is effective from August 12, 2022.

Changing and supplementing the policy.

This Policy may be changed from time to time. The Copyright Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and / or consent of the user.

Applicable Law.

This Policy has been developed in accordance with the current legislation on the protection of personal data of the Republic of Serbia, as well as the provisions of the General Regulation for the Protection of Personal Data ( General Data Protection Regulation or GDPR ) dated April 27, 2016.

Disclosure risk

Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the received personal data, the User is hereby considered to be properly aware that any transfer of personal data on the Internet cannot be guaranteed secure, and therefore the User carries out such transfer at his own risk.

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