PRIVACY POLICY & TERMS OF USE FOR THE OPERATION TRANSFORMATION APPLICATION
When you use the Operation Transformation Application (the “App”), we collect the following types of information and the terms of your use are governed by this Privacy Policy & Terms of Use of the Operation Transformation Application (the “Privacy Policy”).
INFORMATION WE OBTAIN FROM YOU
ACCOUNT DETAILS
Certain information is required to create an account on our App, such as your name, email address, password, date of birth, gender, height, and weight. This is the only information you have to provide us with to create an account. You may also choose to provide other information such as photos or exercise diary entries at your discretion.
INFORMATION WE RECEIVE FROM YOUR USE OF OUR APP
LOCATION INFORMATION
The App includes features that use precise location data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you grant us access to your location. You can always remove access for our App using your computer or mobile device settings. We may also derive your approximate location from your IP address.
USAGE INFORMATION
When you access or use our App, we receive certain usage data. This includes information about your interaction with the App such as when you log in, view or search content, pair your device to your account, or otherwise interact with the App.
We also collect data about the devices and computers you use to access the App, including IP addresses, browser type, language, operating system, mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.
INFORMATION WE RECEIVE FROM THIRD PARTIES
If you choose to connect your account on our App to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address, and friend list. It is open to you to stop sharing information from the other service with us at any stage by removing our access to that other service.
HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA
To the extent that information we collect is health data or another special category of personal data subject to the General Data Protection Regulation (“GDPR”), we ask for your explicit consent to process the data by expressly consenting to this Privacy Policy. You can use your account settings to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, unpairing your device, or deleting your data or your account.
HOW WE USE INFORMATION
We use the information we collect from you for the following purposes:
DELIVER AND PROMOTE THE APP
Using the information we collect, we are able to deliver the App to you and honour this Privacy Policy.
APP DEVELOPMENT
We use the information we collect to improve the App, to develop new features, rectify bugs and protect against errors, and perform data analysis on the App. When you allow us to collect precise location information, we use that information to provide and improve features of the App when location is a relevant factor. We also use your information to prompt you to access other content on the App that may be of interest to you.
COMMUNICATE WITH YOU
We use your information when needed to send you App notifications and respond to you when you contact us.
PROMOTE SAFETY AND SECURITY
We use the information we collect from you to safeguard the safety and security of the App, our users, and other parties. We may use the information you provide to authenticate users, protect against fraud and abuse, respond to a legal request or claim, and enforce our terms and policies. We use cookies and similar technologies for the purposes described above.
For personal data or sensitive personal data subject to the GDPR, we rely on several legal bases to process the data. These include your consent, which you may withdraw at any time using your account settings on the App, our legitimate business interests, such as in improving, personalising, and developing the App, promoting new features that may be of interest to you, and promoting safety and security as described above.
HOW INFORMATION IS SHARED
We do not share your personal information except in the limited circumstances described below. In particular, we do not share the personal data you supply to us in connection with the App to RTÉ.
HOW YOU AGREE YOUR INFORMATION IS SHARED
You consent to us to sharing your information with third-parties by expressly consently to this Privacy Policy and by your continued use of the App.
We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports, to partners under agreement with us.
FOR EXTERNAL PROCESSING
We transfer information to our service providers who process it for us, based on our instructions, and in compliance with this policy and any other confidentiality and security measures in place from time to time. These partners provide us with services such as customer support, information technology development and data analysis.
FOR LEGAL REASONS OR TO PREVENT HARM
We may preserve or disclose information about you to comply with legislation, regulation, legal process, or governmental request, to assert legal rights or defend legal claims, or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the App or the physical safety of any person.
If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.
YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA
Your account settings allow you to access and control your personal data, as described below, regardless of where you live. If you live in the European Economic Area, United Kingdom, and Switzerland (the “Designated Countries”), you have a number of legal rights with respect to your information, which your account settings allow you to exercise, as outlined below.
Accessing, Editing or Deleting your Data By logging into your account, you can access much of your personal information. Your account settings also allow you to edit or delete your personal information.
Should you elect to delete your account, please note that it may take up to 90 days to delete all of your information. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm.
Your account settings allow you to control our data use and designate the notifications you receive from us. You can also use the App to unpair your device from your account at any time.
If you live in a Designated Country, in certain circumstances, you can object to our processing of your information based on our legitimate interests. You have a general right to object to the use of your information for direct marketing purposes.
In addition to the various controls outlined above, if you reside in a Designated Country, you can seek to restrict our processing of your data in certain circumstances. Please note that you can always delete your account at any time.
If you need further assistance regarding your rights, please contact our Data Protection Officer at info@vipmg.tv, and we will consider your request in accordance with applicable laws. If you reside in a Designated Country, you also have a right to lodge a complaint with your local data protection authority.
DATA RETENTION
We keep your account information and password for as long as your account is in existence. In some cases, when you give us information for a feature of the App, we delete the data after it is no longer needed for that feature. We keep other information, like your food and exercise data, until you delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the App. We also keep information about you and your use of the App for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm.
ANALYTICS OF APP PROVIDED BY OTHERS
We may work with partners to provide us with analytics regarding the App. This includes helping us understand how users interact with the App, and measuring the performance of features of the App. These companies may use cookies and similar technologies to collect information about your interactions with the App and other websites and applications on our behalf.
OUR POLICIES FOR CHILDREN
Persons under the age of 13, or any higher minimum age in the jurisdiction where that person resides, are not permitted to create accounts unless their parent has consented in accordance with applicable law. If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at info@vipmg.tv.
INFORMATION SECURITY
We wish to keep your data safe and employ a combination of technical, administrative, and physical controls to maintain the security of your data. However, no method of transmitting or storing data is completely secure and we cannot offer any guarantees in this regard. If you have a security-related concern, please contact info@vipmg.tv.
OUR INTERNATIONAL OPERATIONS AND DATA TRANSFERS
We operate internationally and may transfer information to countries outside the European Union for the purposes described in this policy. We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and Swiss-US Privacy Shield, and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us.
Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create an account to use the App and click “Start The Plan” to data transfers, irrespective of which country you live in. If you later wish to withdraw your consent, you should delete your account and App.
CHANGES TO THIS POLICY
If we make any material changes to this policy you will have the opportunity to review the revised policy before deciding if you would like to continue to use the App.
WHO WE ARE AND HOW TO CONTACT US
If you have questions, suggestions, or concerns about this policy, or about our use of your information, please contact us at info@vipmg.tv.
We confirm that Vision Independent Productions Limited, an Irish limited liability company, controls your personal data and provides you with the App. If you are seeking to exercise any of your statutory rights, please contact our Data Protection Officer at info@vipmg.tv. You may also contact us at:
Vision Independent Productions Limited, Units 26-27, Finglas Business Park, Tolka Valley Road, Finglas, Dublin 11
Vision Independent Productions Ltd.
24.12.2018
