Privacy Policy

SECTION 1. PURPOSE OF THIS POLICY

 

We are committed to keeping your information safe and secure. Please read the following Policy so that you understand your rights in relation to this information, including how your information will be collected, stored, used and processed.

 

In providing you with our Application, we may collect some information about you. This Privacy Policy (“Privacy Policy”) sets out what we collect, how we use, how we store that information, who we might share it with, and the steps we take to make sure it stays private and secure. 

 

This Privacy Policy is inalienable part of Brightway Application Terms of Use (hereinafter referred to as the “Terms of Use”), as amended from time to time. The terms and definitions referred to in this Privacy Policy are specified in the Terms of Use.

 

Please read the following information carefully to understand our practices regarding Your information and how we will use it. By continuing to use our Application, you acknowledge that You have read, understood and accepted the information described in this Privacy Policy. If any User does not agree with this Privacy Policy in general or any part of it, such User should not access or use the Application.

 

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SECTION 2. COLLECTION, PROCESSING AND USE OF YOUR INFORMATION

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2.1. Information we collect when you access the Application

 

When you aсcess the Application, we collect the information sent to us by your mobile or other access device. This information includes:

• Your IP address;

• Device information including, but not limited to, identifier, name, and type of operating system;

• Mobile network information;

• Standard web information, such as your browser type and the content you access in our Application.

 

We collect this information in order to:

• Administer our Application, personalize our Application for you;

• Monitor and analyze trends, usage and activity in connection with our Application and services and provide third parties with aggregated and anonymized statistical information about our Users;

• Prevent, deter and investigate violation of this Privacy Policy and/orour Application or any fraud and other illegal activities.

 

When you access the Application or use our Service we may place small data files called cookies on your computer or other device. We use these technologies to recognize you as our User, customize our Application foryou and to monitor usage of our Application. See Section 3 of this Privacy Policy for more information.

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2.2. Information we collect when you use the Application and/or request support

 

The Application does not provide an option to create an account, therefore, we do not store nor have access to your entries and data. Your data are stored only locally on your device and all calculations are done on your device as well. You can optionally backup your data to Google Drive (Android) or to Apple iCloud and Google Drive (on iOS devices). Your backups are stored in your private cloud space and we do not have access to your backup files.

 

We will obtain your email address only when you request support via email or customer support contact form. We use your email only to contact you to provide support, feedback or important information.

 

We may collect feedback from you on the issues that you report to us, a feedback log, and any email addresses that you provide to us. This information will be used to help us better understand any problems you encounter as well as to allow us to contact you.

 

2.3. Location Data

 

When you use a location-enabled device to access our Application and services, we may collect geographical location data or use various means to determine the location, such as sensor data from your device that may, for instance, provide data on nearby cell towers and wi-fi access spots.

 

2.4. Notice to parents

 

We will not knowingly collect personally identifiable information from any person under the age of 13. We encourage parents to instruct their children to never give out personal information when online. Parents who are concerned about the transfer of personal information from their children may contact us by email as specified in “Contact” section of this Privacy Policy.

 

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SECTION 3. COOKIES

 

We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies”) to enhance your experience using the Application. Cookies are small text files that are placed on your computer or other device by Applications that you visit. They are widely used in order to make Applications work, or work more efficiently, and to deliver a better and more personalized Service.

 

Cookies may be either “persistent” Cookies or “session” Cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

 

We use the following Cookies:

 

• Strictly necessary Cookies. These are Cookies that are required for the operation of the Application.

 

• Analytical/performance Cookies. They allow us to recognize and count the number of Users and to see how Users move around the Application when they are using it. This helps us to improve the way the Application works. We use Google Analytics and other web analytics tools that help us understand how Users engage with the Application. These servicesuse first-party cookies to track User interactionsto collect information about how Users use our Application and how they use it. This information is used to compile reports and to help us improve our Application. The reports disclose Application trends without identifying individual visitors. You can opt out of these services without affecting how you when you visit our Application.

 

• Functionality Cookies. These are used to recognize you when you return to the Application. This enables us to personalize our content for you (for example, your choice of language).

 

You can find more information about Cookies and how to manage them at http://www.allaboutcookies.org/. You may control the use of Cookies within your internet browsers’ settings. If you reject or delete certain Cookies, be aware that the performance of the related features and functions of our Application and Services may be impaired.

 

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SECTION 4. ANALYTICS

 

Our Application may collect some anonymized usage data that are essential for us to deliver our Services, to understand your needs, and to improve our Services. Such as Application launches, taps, clicks, scrolling information, in-app purchases, screen visits, session durations, or other information about how Users interact with our Application. These data are fully anonymized and aggregated and thus not linked to any particular User. The Application may also collect crashes and performance reports, so we can improve the stability and performance of the Application.

 

We may use Google Analytics, Google Firebase and Facebook Analytics to collect information about use of the Services. Google Analytics, Google Firebase and Facebook Analytics collect information such as how often users visit the Services, what activities they do when they visit the Services, and what are the locations when they login the Services. We only collect aggregate information through Google Analytics and Facebook Analytics, for the purpose of copyright royalty calculation, marketing event implementation, and tailored service provision for users in specific territory. 

 

If you do not agree with the practices explained in this section, do not access, browse or use the Application or delete it from your mobile device and terminate all other uses of the Services, if you had already started using them.

 

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SECTION 5. HOW WE MIGHT SHARE YOUR PERSONAL DATA

 

5.1. We may share your personal data where:

 

• We need to in order to operate our Application and Service.

• We need in order to perform your payment transactions in the Application.

• We have a public or legal duty to do so (e.g. to assist with detecting fraud, tax evasion, financial crime prevention, regulatory reporting, litigation or defending legal rights and property, including our own).

• We have asked for your permission to share your information and you have agreed.

 

5.2. We may share your personal data and information with:

 

• Our subsidiary and affiliated companies if this is required for duly performance of our obligations before the Users and provision of Services to you;

• Companies that we plan to merge with or be acquired by (should such a combination occur, we will notify you and will require that the newly combined entity follow these terms with respect to your personal data);

• Law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our policies;

• Our vendors and agents including hosting providers, hired by us to provide Services;

• Payment processors (for the purpose of your transactions performance when using the Application).

 

5.3. What we will not use your personal data for:

 

• We will not provide your personal data to any other Application users or third parties other than described in this Privacy Policy without notifying you first.

• We will not sell or rent your personal data to third parties, other than as described in this Privacy Policy without notifying you first.

 

5.4. Links to third party applications or services:

 

• Our Application may, from time to time, contain links to and from the applicationsof our partner networks, advertisers, etc.

• If you follow a link to any of these applications or services, please note that these applications 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 information, including personal data that may be collected through these applications or services, such as contact and location data. Please check these policies before you submit any information or personal data to these applications or use these services.

• Our Application may also contain services of/from our partners, vendors.

• For the purpose of duly transactions performance in the Application Users might be required to provide their personal and payment processing data (such as name, surname, address, credit card identification data, etc.) to the respective Payment processor, including the consent for processing these data by the payment services in order to carry out the requested transactions. Please note that the respective personal and payment processing data provided by you to a third-party Payment processor shall be collected, stored and processed solely by the respective Payment processor and is not subject to this Privacy Policy. You should read carefully and follow the applicable privacy policies of the relevant Payment processor. We do not store or process any of your payment information.

 

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SECTION 6. HOW WE KEEP YOUR INFORMATION SAFE

 

We protect your information using security standards such as firewalls and data encryption, physical access controls to our premises and information access authorization controls. We also authorize access to your information only for those employees or contractors who require it to fulfill their job or service responsibilities.

 

Please note that transmission of data or information (including communications by e-mail) over the internet or other publicly accessible networks is not one hundred percent secure. Please note that we are not liable for the security of any data you are transmitting over the internet.

 

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SECTION 7. BACKUPS

 

We advise our Users to regularly backup their data. Our Users can choose to manually export the backup file and store it wherever they want or they can optionally make cloud backups. The cloud backups are kept in Users' private cloud space where we have no access.

 

Android Google Drive Backups

Android Users can optionally backup their data using Google Drive. Their backups are stored in their private Google Drive space and count against their quota. We use a secure connection to your Google Account and data is safely stored in a folder where neither we, nor other apps have access. For details, view Google Privacy Policy at https://www.google.com/policies/privacy/.

 

The email and name permissions within the Android are requested in order to display the account details within the Application to inform Users about the account which is being used for the backups. The Application does not keep email addresses and names within the Application. The Application asks Google Sign In for a connected account and displays the account info only when accessing the Backup section.

 

iOS iCloud Backups

iOS Users can optionally backup their data using iCloud or Google Drive. Their backups are stored in their private iCloud or Google Drive space and count against their quota. iCloud secures your information by encrypting it when it's in transit, storing it in iCloud in an encrypted format, and using secure tokens for authentication. For certain sensitive information, Apple uses end-to-end encryption. This means that only you can access your information, and only on devices where you’re signed into iCloud. No one else, not even Apple, can access end-to-end encrypted information. You can find out more about iCloud security and privacy overview at https://support.apple.com/en-us/HT202303.

 

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SECTION 8. HOW WE TRANSFER YOUR INFORMATION

 

We store and process your information using cloud services in various jurisdictions, including the United States of America and UK. As such, the information that we collect from you may be transferred to, and stored in various jurisdictions outside of your country of residence and outside the European Economic Area ("EEA”). The laws on processing such information, including where such information is classed as “personal data”, in these locations may be less stringent than in your country. It may also be processed by staff operating outside of your country or the EEA who work for us, for one of our service providers or one of our business partners. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

 

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SECTION 9. YOUR RIGHTS

 

You may access, review and edit your personal data at any time by contacting our support team. You may be requested by our team to provide the respective confirmation documents in case of your personal data information change.

 

European users have the right under applicable privacy laws to ask us to provide details of the personal data we hold about them or in certain circumstances, may request we delete their personal data.

 

To exercise the abovementioned rights, please contact us in the relevant section of the Application.

 

A request on access, review, provision of details, amendment or deletion of personal data is usually processed within 72 hours from the moment we receive it. However, due to technical reasons delays are possible, and in such case we shall process the respective request within a reasonable term.

 

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SECTION 10. UPDATES OR AMENDMENTS TO THIS POLICY

 

We reserve the right to modify or amend this Privacy Policy at our discretion. Any changes can be viewed in the “Last Updated” field above, so please check the section regularly.

 

If we make any material changes, we will post the new policy in the Application, with a new effective date. 

 

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SECTION 11. CONTACT

 

If you have any questions concerning this Privacy Policy or want to exercise any of your rights as specified herein, please feel free to contact us in the relevant section of the Application.