PRIVACY POLICY
This privacy policy describes what information we
collect when you use Been (the App), how it is used and shared. It is
important that you read and understand this information.
Before finalizing the installation of the App, you must
indicate your consent to our processing of your personal data (including your
name, contact details, device information) as described in this policy. You
should also consent to processing of your Location Data (including your current
location disclosed by GPS technology and/or other technology so that
location-is available for the purposes of the App. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, DO NOT DOWNLOAD OR USE OUR
APP.
Once you provide consent, you may change your mind and
withdraw consent at any time by contacting us olga@beenapp.io, but that will not affect the lawfulness of any
processing carried out before you withdraw your consent.
INTRODUCTION
This policy together with our Terms of Use applies to
your use of:
• Been mobile application software (App) once
you have downloaded or streamed a copy of the App onto your mobile telephone or
handheld device (Device).
• Any of the services accessible through the App
(Services). This policy sets out the basis on which any personal data we
collect from you, or that you provide to us, will be processed by us.
Our App is not directed to individuals under 16. We do
not knowingly collect personal information from children under 16. If we become
aware that a child under 16 has provided us with personal information, we will
take steps to delete such information. If you become aware that a child has
provided us with personal information, please contact us.
WHO WE ARE
WILFEN LIMITED is
a Cyprus registered company with its registered seat at 21, Aglantzias Ave., Complex 21B, 1st Floor, Flat/Office 1, Aglantzia, P.C. 2108, Nicosia, Cyprus ,
and is responsible for your personal data (referred to as ”Company”, “we”, “us”
or “our” in this policy). We collect and use
personal information about you. When we do so we are regulated under the
General Data Protection Regulation which applies across the European Union and
we are responsible as ‘controller’
of that personal information for the purposes of those laws.
We have appointed a data protection officer (DPO). If you
have any questions about this privacy policy, please contact olga@beenapp.io
You have the right to make a complaint at any time to
the Office of the Commissioner for Personal
Data Protection, Cyprus supervisory
authority for data protection issues or other competent supervisory authorities.
We keep our privacy policy under regular review.
This version was last updated on June 2023. It may change and if it does, these changes will be
posted on this page. The new policy may be displayed on-screen and you may be
required to read and accept the changes to continue using the App.
It is important that the personal data we hold about you is
accurate and current. Please keep us informed if your personal data changes
during our relationship with you.
Third party links
Our App may, from time to time, contain links to and from
the websites of our partner networks, advertisers and affiliates. Please note
that these websites and any services that may be accessible through them have
their own privacy policies and that we do not accept any responsibility or
liability for these policies or for any personal data that may be collected
through these websites or services, such as contact and location data. Please
check these policies before you submit any personal data to these websites or
use these services.
.
THE DATA WE
COLLECT
We collect several types of information from and
about users of our App, which can be grouped together as follow:
• Identity Data: name, username or similar identifier,
marital status, date of birth.
• Contact Data: email address.
• Device Data: type of mobile device you use, a unique
device identifier (for example, your Device’s IMEI number, the MAC address of
the Device’s wireless network interface, or the mobile phone number used by the
Device, mobile network information, your mobile operating system, the type of
mobile browser you use, time zone setting, and other information as determined
by the Company from time to time.
• Profile Data: your username and password, in-App purchase
history, your interests, preferences, feedback and survey responses .
• Usage Data: details of your use of our App or your visits
to any of Our Sites including, but not limited to, traffic data.
• Marketing and Communications Data: your preferences in
receiving marketing from us and your communication preferences.
• Location Data: your current location disclosed by GPS
technology OR other technology.
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), any information about criminal convictions and offences neither.
HOW WE USE YOUR
PERSONAL DATA
We will only use your personal data when the law allows us
to do so. Most commonly we will use your personal data in the following
circumstances:
• Where you have consented before the
processing.
• Where we need to perform a contract we are
about to enter or have entered with you.
• Where it is necessary for our legitimate
interests and your interests and fundamental rights do not override those
interests.
• Where we need to comply with a legal or
regulatory obligation.
PURPOSES FOR USING
YOUR PERSONAL DATA
Purpose/activity: to install the App and register you as a new App
user
Type of data: identity, contact, Device
Lawful basis for
processing: performance of a
contract with you
Purpose/activity: to process in-App services
Type
of data: identity, contact, transaction,
device, location
Lawful basis for
processing: your consent, performance of a contract with you
Purpose/activity: to manage our relationship with you including
notifying you of changes to the App
Type
of data: Identity, contact, profile,
marketing and communications
Lawful basis for
processing: your consent, performance
of a contract with you, necessary for our legitimate interests (to keep records
updated and to analyse how customers use our App), necessary
to comply with legal obligations (to inform you of any changes to our terms and
conditions)
Purpose/activity: to administer and protect our business and this App
including troubleshooting, data analysis and system testing
Type
of data: identity, contact, device
Lawful basis for
processing: necessary for our
legitimate interests (for running our business, provision of administration and
IT services, network security)
DISCLOSURES OF
YOUR PERSONAL DATA
We do not provide personal data to any third parties. However, we may need to:
● share personal data with external
auditors, e.g. in relation to the audit of our accounts;
● disclose and exchange information with
law enforcement agencies and regulatory bodies to comply with our legal and
regulatory obligations.
If you would like more information about who we
share our data with and why, please contact us.
We do not transfer your personal data outside the
European Economic Area (EEA).
DATA SECURITY
All information you provide to us is stored on our
secure servers.
Once we have received your information, we will use strict
procedures and security features to try to prevent your personal data from
being accidentally lost, used or accessed in an unauthorised
way.
We will collect and store personal data on your device using
application data caches and other technology. We limit access to your personal
information to those who have a genuine business need to know it. Those
processing your information will do so only in an authorized manner and are
subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected
personal data breach and will notify you and any applicable regulator when we
are legally required to do so.
The safety and security of your information also
depends on you. Where we have given you (or where you have chosen) a password
for access to certain parts of our App, you are responsible for keeping this
password confidential. We ask you not to share your password with anyone.
DATA RETENTION
Personal data
provided to us will only be stored until the purpose for which they were
processed has been fulfilled or – in the case of consent – until you withdraw
your consent. To determine the appropriate
retention period for personal data, we consider the amount, nature and sensitivity
of the personal data, the potential risk of harm from unauthorised
use or disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other means,
and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your
data: see below for further information.
In some circumstances we will anonymise
your personal data (so that it can no longer be associated with you) for
research or statistical purposes, in which case we may use this information
indefinitely without further notice to you. In the event that you do not use
the App for a period of 24 months then we may treat the account as expired and
your personal data may be deleted.
YOUR RIGHTS
To object to processing: You have the right to object to certain types of
processing, including processing for direct marketing (i.e. if you no longer want
to be contacted with potential opportunities)
To be informed: You have the
right to be provided with clear, transparent, and easily understandable
information about how we use your Personal Data and your rights
Right of access: You have the
right to obtain access to your Personal Data (if we are processing it), and
certain other information about or privacy practices with respect to your
Personal Data
To rectification: You are entitled
to have your information corrected if it is inaccurate or incomplete
To erasure ("to be forgotten"): You have the right to request the deletion or removal of your
personal information/Personal Data where there's no compelling reason for us to
keep using it. We will delete backup copies of that Personal data from our archives
as soon as is practically possible, to the extent allowed by our other data
retention obligations (e.g., to protect other data stored in the same backup
archives, or meet other regulatory or legal requirements). As soon as those
obligations have been fulfilled, we will permanently delete those archives as
quickly as possible
To restrict processing: You
have rights to "block" or suppress further use of your personal
information/Personal Data that we process. When processing is restricted, we
can still store your personal information/Personal Data, but may not use it
further
To data portability: You have rights
to obtain and refuse your personal information/Personal Data for your own
purposes across different services
To lodge a complaint: You
have the right to lodge a complaint about the way we handle or process your
personal information/Personal Data with your national data protection
regulator. However, we hope you will contact us first, so we will try to
address your complaint directly
To withdraw consent: If you have given
your consent to anything we do with your personal information/Personal Data,
you have the right to withdraw your consent at any time. This includes your
right to withdraw consent to us using your personal information/Personal Data
for marketing purposes
For further
information on each of those rights, including the circumstances in which they
apply, please contact us.
If you still feel that your
personal data has not been handled appropriately according to the law, you can submit
your complaint with the Office of the Commissioner for Personal Data
Protection, at 1 Iasonos Street, 2nd Floor, 1082
Nicosia, tel. +357 22 818456, email address: commissioner@dataprotection.gov.cy.