This Privacy Policy applies to all users’ personal data that MyStream, LLC receives thought the mobile application Waistline (“our Product”) available for the download thought the App Store and Play Market (the “Marketplace”). This Policy describes what personal data we collect when you use our Product and how and for what it is used.
When this Privacy Policy mentions “we”, “us”, or “our” it refers to the MyStream, LLC, registration number 193346198, address: office 48H, 136 Grushevskaya street, Minsk, Republic of Belarus, e–mail – [email protected] .
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE, DO NOT USE OUR PRODUCT.
We reserve the right to make changes to this Privacy Policy at any time. We will notify you about any changes by indicating the latest update date each time we make any changes to this Privacy Policy. If we make any major changes to this Privacy Policy and will need your explicit consent for further processing of your personal data, we will request your consent or your renewed consent (in case it was obtained previously). Any changes shall take effect from the moment they are published in our Product. If you do not agree with the current conditions for the processing of your personal data in accordance with the relevant Privacy Policy, please do not use our Product.
1. How we collect your personal data.
We process your personal data in the following cases:
A. DATA THAT YOU PROVIDE TO US
1.1. When you first start using our Product, we may ask you to provide us with the following information to generate the training program:
a. Your gender;
b. Your age;
c. Your height and weight;
d. Your level of physical activity;
e. Your purpose in using our Product;
f. Information about your achievements (for example, how many centimeters you do not have to sit on the twine).
We process the information listed above in this paragraph based on our legitimate interest based on a balance of interests. Our common interest is to provide you with the most appropriate training plan and such actions do not infringe your rights.
1.2. If we enable you to create an Account in our Product, you may provide us with the following information, which we may use as set out below:
a. Your name – we use it to contact you by name if we contact you for technical support and other issues;
b. Your e–mail address and mobile phone number – we use it to respond to your technical support requests and to send you Product-related communications;
1.3. To make your Account completed, you can provide us with the following data:
a. Your last name;
b. Your photo.
Please note that the above data you can fill in is optional but it is not required.
1.4. When you contact us by email, phone, etc. on any matter, we will collect and use the data that you provide to us in this case to resolve the matter for which you have contacted us.
We process the information listed above in this paragraph based on your consent to use the above information for the relevant purposes that you give when you provide us with the above information.
B. DATA THAT IS COLLECTED AUTOMATICALLY
1.5. Our Product may also automatically collect certain data when you interact with our Product by using cookies – we collect data about your geolocation, the device you are using to access our Product (type, model), advertising identifier (with your consent), information about your use of our Product, the URL of the previous page, and other. This data is collected using cookie and is used for the following purposes:
a. Analysis of our Product and its improvement according to your preferences;
b. Identification of problems in the operation of our Product and technical troubleshooting;
We process the information listed above in this paragraph based on our legitimate interest based on a balance of interests. Our common interest is to be able to provide you with our Product that will work properly and meet your interests.
c. Offer you advertisements that will match your interests.
We will process the information listed above in this paragraph based on your consent.
C. PAYMENT DATA
d. We do not process your payment data. Your payment data is processed by Marketplace, through which you downloaded our Product.
D. AGGREGATED DATA
e. We also may collect, use and share aggregated data such as statistical data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate data on the use of our Product in order to calculate the percentage of users choosing certain program.
E. FEEDBACK INFORMATION
1.8. If you provide a feedback on our Product any platform on the web, you agree to process your full name (or username), profile photo, and feedback content provided on behalf of the user, including by posting your feedback in our Product. We assume that by providing a feedback, you intend to make your data public and want it to be further processed. We process data from your feedback based on a legitimate interest (our common interest is to provide you with our Product that will meet your preferences), based on a balance of interests, taking into account that such processing does not infringe your rights.
F. INFORMATION FROM YOUR EXTERNAL ACCOUNTS
1.9. We may enable you to login and authorize through accounts created on external platforms such as Facebook, VKontakte and others (the “External Accounts”). When you access our Product through your External Accounts, we collect from your External Accounts personal data to which you have provided access, such as name, email, personal profile information and preferences. This personal data is initially collected by the External Account operator and made available to us in accordance with its data processing policy. In general, you can control access to your personal data that we obtain from these sources through the privacy settings of your External Account.
2. Disclosure of your personal data.
2.1. Our Product is basically provided from the territory of the Republic of Belarus. If you are not located in the Republic of Belarus, then using our Product, you agree that we may process your personal data outside of your country of residence, to wherever we or our service providers operate. Whenever we transfer your personal data, we take steps to protect it.
2.2. We may share your personal information with certain third parties listed below:
a. Third party analysts: Facebook Pixel, Yandex Metrics, Amplitude;
b. Service used for sending messages: sendpulse.com;
c. E–mail service: business.yandex.ru/mail;
d. Hosting: fistvds.ru, cloudvps.by.
2.2.1. You can find out how the above services process your personal data in the documents of the respective service available on the website or on request.
2.3. We do not sell your personal data, i.e. we do not exchange it for a monetary reward. We may only share certain personal data with third parties, as described above, in order for these parties to achieve the purposes for which they were engaged.
2.4. We may also disclose your personal data when we have a good faith belief (i) we are required to do so by law, or (ii) it is necessary to detect, prevent and address fraud and other illegal activity.
2.5. We may share your personal data with our corporate affiliates to be used in a manner consistent with this Privacy Policy, and if we or our assets get acquired or transferred in part or whole to another organization, cessions, transfers of rights to our Product, your personal data we have collected may be among the items transferred.
3. Cookies.
3.1. Cookies are small text files located on a data storage device that are read by a web server in the domain in which they were created.
3.2. Some of the cookies that we use have been designed and implemented to make our Product easier to use (core cookies). We have developed and use core cookies to authenticate users, block malicious use of login credentials and prevent unauthorized access to users’ data.
3.3. We may also use third party cookies. These cookies help us evaluate and understand how our Product and its features are used and how they can be optimized. Our Product uses third–party cookies provided by our service providers specified in the clause “Disclosure of your personal data” herein.
3.4. We use session cookies and persistent cookies. Session cookies are temporary cookies that are not stored on your mobile device after a session. They are used for authentication and security purposes and to ensure that the features of our Product that you use are effective and appropriate. We may also use session cookies to remember your preferences when you use our Product. These session cookies will be deleted when you exit our Product. A persistent cookie is a cookie that is placed on your mobile device for a specific period of time after you used our Product.
3.5. You can disable tracking by using cookies in your mobile device settings or by contacting us at [email protected] . Please note that if disable tracking by using cookies, you may restrict the functionality of our Product, which will make some of the features unavailable to you.
4. Children. We do not knowingly collect or solicit personal data about or direct or target personalized advertisements to anyone under the age of 13, except in European Economic Area, where the age is limited to users under 16, or knowingly allow such persons to use our Product. If you are under the age of 13 (or 16 where applicable), please do not send any personal data to us. If we learn that we have collected personal data about a child under age 13 (or 16 where applicable), we will delete that personal data as quickly as possible. If you believe that we might have any personal data from or about a child under the age of 13 (or 16 where applicable), please contact us.
5. How can you dispose your personal data.
5.1. Rights of EU residents.
5.1.1. As required by General Data Protection Regulation, GDPR, we process and answer your requests without undue delay and in any event within 1 month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to 3 months in total.
5.1.2. You have the right to access personal data we hold about you, correct your personal data, have your personal data deleted, object how we process or share your personal data, restrict how we process or share your personal data, and request to transmit your personal data. You can at any time send us a relevant request via [email protected] . If your consent serves the basis for personal data processing, you can withdraw the consent at any time sending a relevant request via e-mail specified above.
5.1.3. Note that if you ask us to delete your personal data, we can retain some of your personal data as necessary to comply with our legal obligations or resolve disputes.
5.2. Rights of California residents.
5.2.1. As required by California Consumer Privacy Act (CCPA), we endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by e-mail.
5.2.2. Right to opt out. Under the CCPA each California resident can request business stops selling personal data to third parties. However, we do not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, we do not sell your personal data.
5.2.3. Other rights. You also have a right to be informed about what categories of personal data we are collecting: you can request us to disclose what personal data we have collected in the past 12 months and right to get a free copy of your personal data disclosed in a readily usable and readable format. You can also request us to delete the personal data we have collected in the past 12 months. We will not discriminate against you for exercising any of your rights granted under CCPA.
5.2.4. Mandatory verification. As required by CCPA we will need to verify your identity before processing your request. In order to verify your identity, we will generally match sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you have requested us to delete your personal data or your Account.
6. Data retention.
6.1. Generally, we retain your personal data within 1 (one) year since your last interaction with our Product. We only retain your personal data for as long as is necessary to comply with our legal obligations and legitimate interests. Please be advised that we may retain some of your personal data after you cease to use our Product. For instance, we may retain your personal data as necessary to meet our legal obligations, such as for tax and accounting purposes.
6.2. If we have no lawful basic for further processing of your personal data, we delete your personal data after the period for processing established in this Privacy Policy has expired, or after the expiration of the response period established by law, if you sent us relevant request.
7. Contact us. If you have any requests concerning your personal data or any queries with regard to this Privacy Policy please feel free to contact us at [email protected] .