The last update of this Privacy Notice was made on 08 December, 2022
This Privacy Notice describes the privacy practices for the Website localize.mobi (hereinafter "Website", "Site") operated by AVIWELL LIMITED (hereinafter “we”, “us”, “our”, “Company”) and how the Website and Localize, operated by Company, collect and use the personal data you provide to the Company, with the purpose to use Localize (hereinafter referred to as the “Localize”). It also describes the choices available to you regarding our use of your personal information and how you can access, update and delete this information.
The use of the Website is possible without any indication of personal data; however, if a user wants to use the Localize, collecting and processing of personal data could become necessary. If the processing of personal data is necessary, we generally obtain consent from the user as a data subject, except cases when personal data processing is available under other grounds (legitimate interests, contract executing, etc.).
The processing of personal data, such as the address, e-mail address, telephone number or billing information of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Company. By means of this Privacy Notice, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects (users) are informed, by means of this Privacy Notice, of the rights to which they are entitled.
As the controller, Company has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this Website.
In this Privacy Notice AVIWELL LIMITED (Archaias Lidras 7, 2200, Geri Nicosia, Cyprus, registration number: HE 432943) as the Controller of personal data.
- personal data collection and use
- scope and categories of personal data, lawful basis for personal data processing and data subject categories
- encrypted data
- legal matters
- where data subject’s personal data are stored
- rights of the data subject
- children’s privacy
- target device data processing
- data storage and data removal
- Personal data
- means any information relating to an identified or identifiable natural person (“data subject/user”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is the Company.
- is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Data subject/user
- is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; a user of the Localize.
- is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject/user without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- is a security protection measure for personal data; as a form of cryptography, it is a process whereby personal data gets turned into an encoded and unintelligible version, using encryption algorithms and an encryption key, and whereby a decryption key or code enables users to decode it again.
- Consent of the data subject/user
- is any freely given, specific, informed and unambiguous indication of the data subject/user`s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
personal data collection and use
Anyone can access our Website without necessity to provide its personal data.
The purpose of processing your personal data by the Company and collection of information about you are as follows (the “Purpose”):
- Your intention to use Localize;
- For the performance of a contract to which the user is a party, in accordance with Article 6.1.b of the GDPR and the collected data are necessary in order for Localize to identify and bill the user and to charge its bank card number;
- For verifying your identity and providing customer care service and assistance;
- Analyze your use of our Website and Localize to better understand how they are being used so we can improve our Services and the user experience, and engage and retain users.
We may use your Personal data to: (a) improve your browsing experience by personalizing the Website and to improve the Localize; (b) send information to you by email regarding registration status, password verification, payment confirmation; (c) send you communications relating to your use of the Localize, and (d) provide our partners with statistical information about our users by secured channels under data processing agreements (DPA); (e) send you marketing and promotional materials and messages.
As you are willing to use Localize you are required to provide your personal data (to register an account and purchase the Localize), thus becoming a user of Localize.
Please be aware that you are not obliged to provide us with your personal data. However, if you do not provide us with your email address and payment information, you may not be able to create an account to log into and make a purchase of Localize.
SCOPE AND CATEGORIES OF PERSONAL DATA, LAWFUL BASIS FOR PERSONAL DATA PROCESSING AND DATA SUBJECT CATEGORIES
We strive to be compliant with GDPR and implemented data minimization principles.
|No.||Scope and categories of personal data||Data subject categories||Processing purpose||Lawful basis for personal data processing|
|1||e-mail address and phone number||Localize users||to provide Localize;|
to communicate information about our services;
|performance of a contract|
|2||e-mail address||Localize users;||to send marketing communications||consent|
|3||IP address||website users||to provide the features of the Website||Legitimate interest|
|4||location data – for statistics of user’s areas involvement||website users||to provide the features of the Website||Legitimate interest|
|5||Automatically collected data (cookies and similar technologies, device and connection data)||website users||to provide the features of the Website||consent|
|6||Phone numbers of target device users||Target device users||To provide Localize||consent|
|7||Location data||Target device user’s||To provide Localize||consent|
The storage of this data takes place against the background that this is the only way to prevent the misuse of Localize, and, if necessary, to make it possible to investigate committed offenses.
The personal data are not transferred to third parties, except events, when it’s necessary with an aim to provide Localize and/or there is a lawful obligation to transfer these data under request of government authorities and/or the transferring is executed in respect of criminal proceedings.
We do not authorize the use of your personal data by any third party (only under exceptional conditions as described under "Legal Matters" below). We operate and maintain a variety of online security measures to safeguard and keep your personal information private and secured.
When you purchase the Localize you have to fill the User’s Information, which should contain your personal information as email, which is processed and stored by us.
You also have to fill the Payment Information, which should contain your Personal data, which is partly processed by us and processed by the payment providers.
Based upon the personal data you provide us at registration of an account, we may send you a welcoming e-mail to verify your login and password.
You may enter to your account on our Website under login and password sent to your email. All your activity in your account is password-protected, and you should keep and take all necessary measures to protect the secrecy of your password.
We will also communicate with you in response to your inquiries, regarding any information or services you request.
Based on your separate consent, we may send you the following marketing emails:
- Product Updates (info about new version releases, about new features, or about some issue, or requests to help us make our product better by taking the survey);
- Localize Tips and Tricks (e.g. Getting started emails, how to get the most out of Localize, educational content);
- Exclusive Deals (e.g Black Friday or New Year promo, some discounts, upsells and cross-sells);
- Newsletters (e.g. announcement about news in our niche. somethings that might be important to know for our customers);
- Localize Digest (e.g. once a month we send email to all user base where we include info about the company, some most popular blog posts, customer reviews, etc);
- Activation Reminders (e.g. welcome email schema for users who registered but did not buy).
You may always opt-out (unsubscribe) from any communication in your account (except operational and/or non-marketing notification as following: payment acceptance, payment notification, necessary updates notification, refunds issue etc.).
All Personal Data is stored in encrypted way on Localize servers with using of the last encryption and protection technologies and standards.
If you use a computer in a public place or share a computer with others, remember to log out/sign out and close your browser window when you finish accessing Localize in order to prevent others from accessing your personal information. You are solely responsible for the control and use of each password you create.
Target devices users are not defined as data subjects, because these individuals cannot be identified or are identifiable natural persons based on information, which may be collected or collects from target devices in encrypted form.
We implemented all necessary measures and standards in an area of payment security for Localize. We cooperate with different payment service providers and before our cooperation we check them according to our policies for the availability of licenses and other permits for the acquirer transactions. Within a payment execution you provide the following information to the payment service provider: (i) credit/debit card number; (ii) expiration date of credit/debit card; (iii) your full name; (iv) your e-mail. This information is collected and stored by the payment service provider and we don’t store and collect any bank cards data.
Data that we collect automatically.
We also collect and store information that is generated automatically as you navigate through our Website to enhance your experience on our Website by using tracking technologies such as Cookies, Log Files and Pixel tags.
As you navigate our Website(s) information that we automatically collect is information in "log files" about your device’s connection to the Internet, length of time spent on the Website, and the pages accessed during each visit to the Website. We use this information to analyze trends, administer the Website, track user movement on the Website, and gather broad statistical information for aggregate use.
The data subject may, at any time, prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of Cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of Cookies in the Internet browser used, not all functions of our website may be entirely usable.
If you do not wish to receive Cookies you may be able to refuse them by adjusting your browser settings to reject Cookies. If you do so, we may be unable to offer you some of our functionalities, services or support. If you have previously visited our Website, you may also have to delete any existing cookies from your browser.
Also, we may use Pixel tags (single-pixel image files also known as transparent GIFs, clear GIFs or web beacons) to access Cookies and to count users who visit the Website or open our HTML-formatted e-mail messages.
We have put in place security hardware, software and software update and network scanning procedures designed to safeguard and secure the information (including personal data) under our control and follow generally accepted industry standards. We work with third party service providers and vendors that use encryption and authentication to maintain the confidentiality of your personal data. If stored, we house personal information on systems behind firewalls that are only accessible to limited personnel, who are under DPA.
We store personal data of all our users in an encrypted way. We use asymmetric public-private key cryptosystem RSA with key size is 4096 bit (further RSA) and symmetric-key algorithm AES with key size is 256 bit (further AES).
Asymmetric public-private key cryptosystem RSA (key size is 4096 bit) use public encryption key and private decryption key. The public encryption key is storing in database (DB) in open way. The private decryption key is storing in DB encrypted using AES 256 using key which consist of the user’s password and secret key. It cannot be decrypted without user’s password and secret key.
User’s credentials are user’s login is stored in DB. User’s password is not stored. We store only hash of the password. We generate public-private key pair for cryptosystem RSA during user’s sign up. This public-private key pair is unique for each user. The key pair is stored in DB encrypted format using AES 256.
Login process: We use user’s password from login form for decrypting user’s original private key.
Encryption data: We get opened data from devices using encrypted https protocol. We immediately start encryption process of the data on the server in the RAM without storing on server`s disks. We encrypted data using RSA using user’s public encryption key.
The encrypted data is saved to our servers.
Decryption: We get user’s decrypted private key. We decrypt user’s text data using user`s original private decryption key. We show this information to user.
We consider your use of Localize to be private. However, we may disclose your personal information stored in your account and/or on our servers and databases, in order to:
- comply with the law or legal process served on us;
- investigate potential fraudulent activities; or
- protect the rights, property, or safety of our Company, its employees, its customers or the public.
In the event of a change of control of Localize (such as asset transfers through a merger, sale, assignment or liquidation of the business entity, or any of its properties, assets or equity) or, in the event of a direct or indirect sale of any of its publishing properties and/or its Website(s)in our possession will be transferred to the new owner/successor. You will be notified of any such transaction and have an ability to exercise your legal rights under GDPR. You may always change or delete your personal data or opt out by contacting us as provided below, or if the acquirer posts a new Privacy Notice with new contact information, you may change or delete your personal data or opt out by following any new instructions that are posted.
As a controller, we may also transfer to one or more processors (e.g. a payment provider under DPA) personal data of a data subject for (a) payment processing purpose, which is attributable to the controller and without which a user would not be able to purchase the Localize; (b) telecommunication purpose and without which a suers would not be able to use the Localize.
As we use third party technological services for the provision of Services, we may transfer your personal data internationally. Providers of such technological services may process personal data collected in the course of providing us their services as sub-processors only under DPA in accordance with GDPR.
In case there might be a risk of unauthorized disclosure of personal data the controller communicates the personal data breach to the data subject without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, as encryption, and it was applied to the personal data affected by the personal data breach, the controller is not required to communicate the data subject.
However, the encryption is useless if the access password or other credentials are weakly protected and stored by data subject. In this case the controller is not responsible for personal data breach.
In the case of a personal data breach, we, as a controller, shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.
where data subject’s personal data are stored
Usually, Personal data, which are provided by users and information, which are collected from a target device, are stored on the servers in Germany and Netherlands. Personal data, which are provided by users and information, which are collected from a target device, may be stored outside the EU. In some cases, these personal data and information may be stored in Canada. We adopted all necessary security measures for protection of your Personal Data according to the best practices of security, protection and confidentiality. If we transfer your Personal data to third party service providers, we will compel each third-party service provider to adopt necessary security measures for protection of your Personal Data according to our data protection agreement.
your rights as a data subject
You have right to request an explanation of the personal data we process about you. Also, you can request a copy of your personal data undergoing processing.
You have a right to receive the personal data concerning you, which you provided to us. You can make a request to transmit this data directly to another data controller in a structured, commonly used and machine-readable format. We will transmit your data directly to another controller in cases where it is technically feasible.
You have right to request us to temporarily or permanently stop processing all or some of your personal data.
You have right to request to rectify/correct any inaccurate data about you.
You have a right to be forgotten which means that we will delete all personal data that you have provided to us. Note, we may retain certain information as required by law and for legitimate business purposes permitted by law.
You can, at any time, object to the processing of your personal data on grounds relating to your particular situation. You have the right to object your personal data being processed for direct marketing purposes.
Right to lodge complaints.
You have the right to lodge complaints in relation to the data processing activities carried out by us to the competent data protection authorities.
Not to be subject to automated decision-making.
You have a right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
Right of confirmation.
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.
Right to withdraw data protection consent.
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Notice. We shall promptly ensure that the request is complied with immediately.
Provision of Localize generally not aimed at children. This Website is not intended for use by children under the age of 16.
The Company is acting in compliance with COPPA. We do not knowingly collect information from children and minors. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Notice by instructing their children to never provide information on our Website without their permission.
Our Website and Service is not directed to, nor do we knowingly collect personal data from children under the age of 13. If we obtain actual knowledge that we have collected personal data from a child, we will comply with industry guidelines and applicable laws and will promptly delete it, unless we are legally obligated to retain such data.
target device data processing
Target Device Data.
The Localize starts collecting data from a target device, on which was sent a location link, which may include personal data relating to a target device user(s) (“User Data”). User Data are start collected and processed from the moment, when target device users allow Website to track their location via browser. When a target device user allows Website to track his or her location, the target device user gives explicit consent to store and transfer his or her current location data to third parties. We collect, store and transfer only address, where the target device user allowed us to track it after tapping on the location link, which received by SMS.
We shall (a) implement appropriate technical and organizational measures to safeguard any Target Device Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to Target Device Data only to those employees who need to know it to enable the Processor to perform the Services; (c) only process the Target Device Data as specified by this Privacy Notice and in accordance with your instructions, and (d) will not use the Target Device Data for any purposes other than those related to the performance of the Services or pursuant to your written instructions. Upon the expiry or termination of this Agreement by way of de-registration, or upon your request, we will cease any and all use of the third-party Data and will destroy or return it to you except as provided above with respect to backed-up data and termination.
You are solely responsible for use of the Account and Users Data. We automatically use the configuration and the instructions given by you and you are solely responsible for the configuration of your Account.
You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of Target Device Data and other third-party personal data submitted to our systems during the course of use and provision of the Localize.
data storage and data removal
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period and when we no longer need personal data, we routinely and securely delete or destroy it, as long as it is no longer necessary for the Purpose. As the data controller, we shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of Localize provision, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
However, in case of conflict situations in progress we may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defense of legal claims and for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data and information gathered from a target device gets deleted.
To opt out of further e-mail communications from us, just click on the opt out button in the e-mail, or contact us as instructed at the end of this Privacy Notice. We may need up to 30 (thirty) calendar days to assure compliance with your request.
To change your personal data that you have provided to us, please contact us as instructed at the end of this Privacy Notice.
We may modify this Privacy Notice at any time and post any changes to the Privacy Notice on the Website, so please review it frequently. We indicate the date of the current version of this Privacy Notice below, so you know when it was last updated.
Changes to this Privacy Notice may not affect your personal data we have previously collected from you or after such changes.
If you object to the changes, please contact us as provided below.
This Privacy Notice is governed by and construed with the laws of Cyprus .
The Cyprus courts shall have exclusive jurisdiction to settle any claim or dispute which might arise out of or in connection with this Privacy Notice.
If you have any questions or propositions, please, get in touch with us by the e-mail: [email protected].