PRIVACY NOTICE

Last updated February 28, 2021



Welcome to Relaxify Ltd Privacy and Data Protection Policy ("Privacy Policy") and thank you for choosing to be part of our community at Relaxify (" Company ", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at [email protected] .

When you use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the App ), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our App ), as well as, any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

At Relaxifyapp Ltd. we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the EU General Data Protection Regulation ("GDPR"). This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data. The individuals from which we may gather and use data can include:
  • Customers
  • Suppliers
  • Business contacts
  • Employees/Staff Members
Third parties connected to your customers and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
TABLE OF CONTENTS

1. WHO IS YOUR DATA CONTROLLER?
2. LEGAL BASIS FOR DATA COLLECTION
3. HOW WE USE YOUR PERSONAL DATA
4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
5. YOUR DATA AND THIRD PARTIES
6. HOW LONG WILL WE RETAIN YOUR DATA FOR
7. AGE LIMIT FOR OUR USERS
8. INTERNATIONAL TRANSFER OF DATA
9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
10. INTERPRETATION
11. WHAT ARE YOUR PRIVACY RIGHTS AS EU NATIONAL?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHO IS YOUR DATA CONTROLLER?
1.2 Who is Your Data Controller
Relaxifyapp LTD. is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at [email protected] or sent in a letter to our post address.
1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as "Processors"). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
  • Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
  • Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
  • Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
  • Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
  • Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
  • Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
  • Maintain a record of all categories of processing activities carried out on behalf of a Controller;
  • Cooperate, on request, with the supervisory authority in the performance of its tasks;
  • Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
2. LEGAL BASIS FOR DATA COLLECTION
2.1 Types of Data / Privacy Policy Scope
"Personal Data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
Financial Data: These are your banking details e.g. your account number and sort code.
Transactional Data: This is information of details and records of all payments you have made for our services or products.

Information automatically collected

Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when you visit our App or Webiste.

We automatically collect certain information when you visit, use or navigate the App . This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App , and for our internal analytics and reporting purposes.

We also collect, use and share Aggregated Data such as r data that we release such as how often founders subject their shares to vesting. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

"Consent": Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.

"Contractual Obligations": We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.

"Legal Compliance": We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

"Legitimate Interest": We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3. HOW WE USE YOUR PERSONAL DATA
3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below. Please refer to Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
Type of data Legal Justification Lawful basis for processing data Type of data Legal Justification Lawful basis for processing data
"when a customer purchases a product"; or "when a customer optsin to marketing communications" Profile /Identity Data Consent Contractual Obligations Legal Compliance Legitimate Interest Explicit Consent Necessity Incapacity Private Association "legitimate interest" to collect Financial Data you might explain that "We need to process this data so that we know who and where to charge for the products you have purchased from us".

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3.4 IP Address/Other information

The information we collect includes:
  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our App and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the App (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the App . Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

We collect information regarding your push notifications, when you use our App.

If you use our App, we also collect the following information:
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings. This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.
  • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
  • To post testimonials. We post testimonials on our App that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
  • Request feedback. We may use your information to request feedback and to contact you about your use of our App .
  • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • To protect our Services. We may use your information as part of our efforts to keep our safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.


4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US?

4.1 What Control Do I Have Over Relaxifyapp LTD. Use Of My Personal Data?

You may delete your account at any time – this will remove your account page from our systems and our related software. We guarantee this will delete all stored data. Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into your account you created with us.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to [email protected].
4.2 How Does Relaxifyapp LTD. Protect Customers' Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including We implement certain security measures to ensure the security of your Personal Data on our systems, including… An example of this might be “adopting a secure protocol and encrypting our databases.” Or, you may have bought specialist cybersecurity software you may want to specify. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.
However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Relaxifyapp LTD. to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.3 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time but you can ask us to stop sending you marketing messages at any time by [email protected].
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
4.4 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
5. YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data With Third Parties?

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that Relaxifyapp LTD. anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If Relaxifyapp LTD. is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
5.2 Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

6. HOW LONG WILL WE RETAIN YOUR DATA FOR


We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. AGE LIMIT FOR OUR USERS

In Short: We do not knowingly collect data from or market to children under 18 years of age.

You must not use Relaxifyapp LTD. unless you are aged 18 or older. If you are under 18 and you access Relaxifyapp LTD. by lying about your age, you must immediately stop using Relaxifyapp LTD.. This website is not intended for children and we do not knowingly collect data relating to children. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected]. .

8. INTERNATIONAL TRANSFER OF DATA
We are currently storing data in the EU and so, by using Relaxifyapp LTD., you are permitting and consenting to the transfer of information, including Personal Data, outside of the EU.

9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 28 February 2021.
By using Relaxifyapp LTD., you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Relaxifyapp LTD. will constitute your express acceptance of any modifications to this Privacy Policy.

10. INTERPRETATION
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Relaxifyapp LTD., waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Relaxifyapp LTD. address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Relaxifyapp LTD. rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Relaxifyapp LTD. legal department.

11. WHAT ARE YOUR PRIVACY RIGHTS AS EU NATIONAL?

In Short: You may review, change, or terminate your account at any time.
If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at [email protected] .

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:
  • Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list - however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
  • Access your account settings and update your preferences.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.


13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or by post to:

Relaxify Ltd.
Tzar Boris III num. 81. vh.B
Sofia
Bulgaria

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by sending dataprotection [at] relaxifyapp.com . We will respond to your request within 30 days.