PRIVACY POLICY

The processing manager is "UNDERBEAK", pty ltd company, incorporated in Australia with Australian Business Number 49 094 099 386.
Protection of your personal data is fundamental to us. This confidentiality policy outlines information pertaining to the manner in which we collect and process this data.

1. REMIT OF THE PERSONAL DATA PROTECTION POLICY

This personal data protection policy is applicable to all of our data applications.

2. WHAT DATA IS COLLECTED?

With your prior consent, we are likely to collect and process the following data in whole or in part when you use our applications.

Identity-related data: for some of our applications, we are likely to collect data from your Facebook account, when you login using Facebook connect: Public profile (surname. forename. age. gender, email address. profile photos. hobbies), email address, friend list
IDFA publicity identifiers (for 105 devices) and GAID (for Android devices)
Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the publicities we display (for instance, time spent on these, potential clicks)
Data pertaining to your geographical position (IP address)

The compulsory or optional character of data to be provided is indicated at the time of being collected.

We are also likely to use cookies which correspond to small files containing letters and figures downloaded onto your device when you access our applications.

3. PURPOSES OF PROCESSING UNDERTAKEN BY UNDERBEAK AND LEGAL BASIS FOR PROCESSING

Data collected by UNDERBEAK is used to:

Populate our applications and allow you to use them free of charge.
Guarantee use and improvement of our applications.
Develop new applications
Propose personalised adverts and ensure that the adverts proposed in the framework of our applications are the most suitable to your requirements.
Communicate with you, notably when you contact us by any means whatsoever.

We collect the data listed hereinabove, in whole or in part, only once we have your express consent for the purposes for which they are to be processed, through a pop-up in our applications.

4. TERM OF DATA STORAGE

UNDERBEAK stores your personal data for the period of time you use our applications.

Beyond this term, data may be rendered anonymous and stored solely for statistical use and will not be exploited, in any nature whatsoever.

5. CATEGORIES OF RECIPIENTS OF DATA COLLECTED

Data collected is for internal use within UNDERBEAK and strictly limited to those teams who are the most suitable for the request made.

We may however share Data collected with our technical service providers for the aforementioned purposes.

We stringently request that our partners always act in compliance with Data protection legislation applicable and grant special attention to confidentiality of this Data.

By application of the applicable regulation, any sub-contractor who may process this personal data for UNDERBEAK undertakes as follows:

To solely process data for the purpose(s) which is/are sub-contracted
To process data in pursuance with UNDERBEAK instructions
Guarantee the security and confidentiality of Data

UNDERBEAK may also disclose/transfer your personal data to third parties in the following particular circumstances:

By virtue of legislation, as part of legal proceedings, a dispute and/or request issued by the public authorities in your country of residence or otherwise
If disclosure is necessary for national security, application of legislation or any other matter of public interest
In the event of restructuring, transfer, merger or sale to the third party concerned

6. DATA TRANSFER

In such instance as your Data is transferred outside of Australia, we ensure that:

The personal data is transferred to countries recognised as offering an equivalent level of protection
Personal data is transferred via certified entities under the Privacy Shield
For personal data transferred outside of countries recognised by the National Data Protection Authority (CNIL) as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and in particular the adoption of template contractual clauses

7. PERSONAL DATA CONCERNING CHILDREN

UNDERBEAK does not knowingly collect any personal data concerning children under 15 years old.

8. YOUR RIGHTS CONCERNING DATA COLLECTED

8.1. Your rights

You have all of the following rights concerning the data we collect:

Right to access your Data

You are entitled to receive confirmation that your personal data is or is not processed and, when processed, you are entitled to access said data. This right also includes that of receiving a copy of data processed

Right to request rectification of your Data if incorrect

You are entitled to request that your data be amended, updated or completed when inaccurate, incorrect, incomplete or obsolete.

Right to request deletion of your Data

You are entitled to request deletion of your data solely on those grounds for which provision is made by applicable regulation and in particular when:

Data is no longer necessary in light of the purposes for which it is collected or processed in any other manner;
You withdraw consent over which processing is based, and there is no legal basis for processing;
You object to processing and there is no overriding legitimate ground for processing;
You consider that your data has been processed illicitly;
Your data should be deleted to respect a legal obligation.

Right to limit processing

You are entitled to request that the processing manager limit the use of your data solely on those grounds for which provision is made by applicable regulation and in particular when:

You object to the accuracy of your Data
You consider that processing is illicit and you object to deletion your data
Data is still required for exercising or defending your rights in court even though UNDERBEAK no longer requires this data

The right to object to processing by withdrawing your consent (with it being reiterated that this withdrawal may not harm the legality of processing based on the consent granted prior to its withdrawal).

The right to benefit from data portability

You are entitled to reclaim your data provided to UNDERBEAK, in a structured format, commonly used and machine-readable, and the right to transfer this data to another processing manager, for instance so as to change service provider.

8.2. Terms for exercising rights

You may exercise the aforementioned rights with a written and detailed request to the following address: support@underbeak.com

Due to the obligation of security and confidentiality in Data processing incumbent upon UNDERBEAK, you are hereby informed that your request will be processed subject that you provide proof of your identity, notably by producing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

UNDERBEAK will determine whether this is admissible or not within one month following receipt of the claim. In such instance as it is deemed admissible, UNDERBEAK will provide all information requested or implement the rights claimed within the aforementioned deadline.

If, given the complexity of the claim or the number of requests received. the aforementioned deadline cannot be respected, UNDERBEAK will notify you prior to expiry of this deadline, of this deadline being pushed back by a maximum of two months following its decision.

UNDERBEAK hereby notifies you that it will be entitled, where applicable, to object to any requests which are dearly abusive (in their number, repetitive nature, or systematic).

9. PERSONAL DATA SECURITY

We take all necessary security measures so as to prevent as far as practically possible any alteration or loss of your data or any unauthorised access thereunto.

In such instance as we should be aware of any illegal access to personal data concerning you and corresponding to processing for which we are responsible, we undertake to notify you of the incident as soon as possible if this fulfills a legal requirement.

10. UPDATING THE PRESENT POLICY

The present policy may be updated at any time, notably pursuant to legal and/or regulatory provisions. We hereby invite you to consult this page regularly.

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