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Privacy Policy

Promise to customers

Privet will never sell your data, we will never sell ads or monetize your data in any way. Privet's sole source of revenue is through the subscription services our customers subscribe to. 

Minimize Data Collection        

Privet uses its resources to prevent other companies from collecting your personal data.

Minimize Data Footprint          

Privet uses its resources to keep your private data out of the hands of companies who put your data privacy and security in jeopardy. We accomplish this by decreasing the volume of your private data that is out in the world.

Privacy Policy

Title 1 - Privet FeaturesSection 1. Privacy Service in the Privet Application

Privet App is a mobile application available on iOS and Android that helps you protect your online privacy.

By using the Privet App, you are asking the Privet App to make changes to your privacy settings and/or personal data. This is called “processing your personal data.” When you open the Privet App for the first time, you will see a pop-up displaying a link to this privacy policy.

 

Before using the Privet App, please read this privacy policy carefully and agree to its terms to continue using the application. If you do not agree with this privacy policy, please do not use the Privet App.

 

A. Functionalities

The Privet App will never change anything in your accounts without your prior authorization. Consequently, we are only processing your data because you have consented to it and/or because we are performing a service you have requested from us.

 

(i) Subscription to a Privet Plan

If you subscribe to a Privet Plan your payment may be handled by Google, Apple or Stripe, depending on factors such as your phone’s make or model, the plan you choose, the country in which you are located, and the features made available to you.

 

We provide these companies access to data required to process the payment for a Privet subscription. Your personal data may be stored by us and/or these payment providers as required by tax regulations and/or payment network requirements (e.g. Visa, Mastercard, etc.) For more information on how Apple, Google or Stripe may use your data, please consult Title 2 on Sub-Processors.

 

(ii) Data Deletion Requests

The Privet App offers you the ability to have Privet contact other companies who sell and store your data to request they remove the data they have stored on you.

Due to the large number of companies that buy, sell, and store your data Privet will contact companies you may have never heard of. If these companies are required by their domestic legisltation to abide by these Data Deletion requests they will remove any data they hae stored on you that doesn't direclty impact the services they currently provide you with. At no point will Privet store any of this data.

 

Section 2. Privet App Analytics

The Privet App collects analytics information to ensure that our product works correctly on different devices and operating systems. This data also helps us improve the quality of our product and make your experience better. This includes data like the type of device you’re using, the operating system, event stamps and error logs.

 

You can opt-out from anonymous Privet App analytics at any time, directly from the Privet App, and we will no longer collect analytic data from your device.

 

We do not track or store any of your personal data with this analytic tool. Instead, to distinguish one user from another in an anonymous way, we use a unique identifier called “deviceID” that is linked to your device and your use of the Privet App.

 

Section 3. Push Notifications

We may send you updates about the Privet App and Privet Privacy by sending you push notifications through the application if you have given us your prior approval to do so.

 

You may opt-out of receiving these notifications at any time by changing the appropriate settings within your Privet App. To send you push notifications, we store and use a serial number which was generated by Apple or Google, depending of the version of the Privet App you are using, best known as a “token”, which is unique to your use of the Privet App in your phone.

We cannot identify you nor localize you through this token but we can know your time zone, the language chosen on your phone and send you messages. This is why we have a strict security policy when collecting, storing and using your token.

 

Section 4. Support

Privet Privacy is by your side to help you control your privacy. Therefore, if you have any questions or concerns regarding the Privet application, this Privacy Policy or your privacy rights, you can contact our support team directly in the Privet App, or by sending an email to: privetcustomerservice@gmail.com.

 

Section 5. Surveys

We sometimes conduct surveys within the Privet App to get feedback on our products and services. When conducting such surveys, we might collect anonymous information such as country or age range to understand demographics of our user base. On some rare occasion, we give you the possibility to provide us your email address on an opt-in basis if you want the opportunity to chat with a team member or if you want to receive updates regarding the Privet App. In such event, we only process your email address for the purpose provided for in the survey, and for as long as strictly necessary. We do not sell it or transfer it to any third-party.

 

You can opt-out from any further communication, rectify, and/or erase your email address directly in any received communication, or by sending us an email to privetcustomerservice@gmail.com.

 

Section 6. Newsletter

You can subscribe to Privet's newsletter at any time by given us your email address in the Privet App or on our dedicated websites. We only send the newsletter to you for the informational purposes you have chosen when you subscribed. You can opt-out whenever you want by clicking the opt-out link directly in the newsletter or by sending us an email to: privetcustomerservice@gmail.com. We will then stop sending you our newsletter, and will delete your email address from our emailing list. We use Mailchimp to send you our newsletter, for more information, please see here.

 

Section 7. Functioning cookies on our websites

We have installed cookies on our websites available at the following URL addresses: www.privet.io to collect your IP address only for strictly necessary purposes to enable our websites to work properly as described below.

We do not have any other cookies on our websites (such as tracking or advertising cookies).

You can refuse the use of cookies at any time by adjusting the settings of your browser (Internet Explorer, Safari, Firefox, Chrome) by selecting the “cookies” option in the “Help” function to obtain information about the location of the cookie folder. Please note that disabling cookies may limit access to certain features or pages of the Privet Privacy websites.

 

Section 8. Privet Privacy’s ads

You might have noticed some ads for Privet Privacy on websites or apps you have been on. In order to understand if you have downloaded the Privet App by clicking on one of our ads, and if so, what exact ad, we collect your IDFA and IP address when you start using the Privet App together with certain events, for legitimate business purposes. Events consist of information on whether you have taken on a Privet subscription plan or not.

Once collected, Your IDFA/IP address and the collected events are immediately sent to our ad campaign partner, Singular, without Privet storing them. This information is shared with ad networks Privet works with to display ads (such as Google Ads, Apple Ads, Twitter Ads and Facebook Ads) to confirm ad campaign attributions. 

Please note that you can opt-out from such data usage at anytime by sending us an email to privetcustomerservice@gmail.com.

 

TITLE 2: Sub-Processors

Third-party services Privet relies on, and what data they might store about you.

 

We only share your personal data with the services we rely on, if strictly necessary to provide you with our privacy and security services.

 

Where we need to share your personal data with our third-party services, we have chosen them with a lot of care, to make sure they take privacy as seriously as we do and that they only use your personal data for the purposes we have instructed them to do. We might also have executed data processing agreement with them to regulate how such service providers use your personal data. This data processing agreement was implemented thanks to the GDPR, CCPA, and the Australian Privacy Principals. In the event where such service providers are limiting their data processing agreements to European, UK, Australian, or Californian users, we are negotiating to extend such protection to all our users wherever located.

 

Section 1. Apple

Apple hosts Privet's iOS app. This section applies to you if you use our iOS version of the Privet App.

 

Subscription information

Apple collects your account information and payment details when you subscribe to a Privet plan. Your personal data is stored by Apple until you delete it, except for your payment data which is kept by Apple for duration imposed by tax regulations in your country. For more information, please visit https://support.apple.com/en-us/HT207233.

 

Face ID and Touch ID

You can use Face ID or Touch ID to unlock the Privet App if you use such version of the application. Privet does not have access to this information, which is only managed by Apple. To learn more about this technology, please visit https://support.apple.com/en-us/HT208108 and https://support.apple.com/en-us/HT204587

App Analytics

Apple provides Privet with analytics: this feature is called App Analytics. Apple does not provides Privet with information that would personally identify you. You can turn off this feature completely within your iPhone settings, also. For more information about how Apple processes your data, please visit https://www.apple.com/legal/privacy/.

 

Section 2. Google Play Console

Android hosts our Android app. This section applies to you if you use our Android version of the Privet App.

 

Subscription information

Google collects your account information and payment details when you take an in-app subscription. Privet does not have access to this information, which is only managed by Google.

 

Your personal data is stored by Google until you delete it, except your payment details information that might be kept by Google for duration imposed by tax regulations in your country.

 

App analytics

Google provides Privet with anonymous analytics with regards to your use of our app (country, device): this feature is called Google Play Console. Google does not provide Privet with information that would personally identify you. You can turn off this feature completely, also. For more information about how Google processes your data, please visit https://policies.google.com/privacy.

 

Section 3. Mailchimp

We may send you our newsletter if you have provided us with your email and agreed to receive it.

To send you our newsletter, we use Mailchimp as our newsletter service provider. Mailchimp provides that it will only process your personal data to provide us with their emailing tools. Your email address will be automatically deleted from Mailchimp if you decide to opt-out from any communication. We do not keep email addresses for marketing purposes for more than a year following the last sent communication. For more information about how Mailchimp processes your data, please visit: https://mailchimp.com/legal/privacy/. You can consult the data processing agreement signed with Mailchimp here https://mailchimp.com/legal/data-processing-addendum/.

Section 4. Freelancers

From time to time, we may use freelancers based in the USA or Europe to help us for specific tasks notably to our support team. These freelancers might process personal data belonging to you under our strict instructions. We chose very carefully the freelancers that work with us, and they all sign a data protection agreement containing security requirements to ensure the safety of your personal data before starting to work for Privet. For more information, please contact us.

 

Section 5. Stripe

Your subscription and payment may be handled by Stripe, depending on factors such as your phone’s make or model, the plan you choose, the country in which you are located, and the features made available to you.

Your personal data, such as your payment method and information required to complete your purchase (such as your billing address), will be secured and stored in Stripe as required by applicable regulations and laws, and payment network requirements (e.g. Visa, Mastercard, etc.). Note that regulations may require Stripe to retain transaction records for a prescribed period of time.

 

For Stripe’s data retention policy, please visit: https://support.stripe.com/questions/data-retention-policy. For information about how Stripe processes your date, please visit: https://stripe.com/privacy

 

TITLE 3 - Other information about your data

 

Section 1. Personal Data transfers EU/UK/Swiss-USA (null until Privet receives certification)

PRIVACY SHIELD UPDATE: ON JULY 16th, 2020, THE EUROPEAN COURT OF JUSTICE HAS DEEMED THE PRIVACY SHIELD NO LONGER AN ADEQUACY DECISION TO MAKE TRANSFERS OF PERSONAL DATA FROM THE EU TO THE USA. WE ARE ACTIVELY WORKING ON THIS TOPIC TO CONTINUE ENSURING THE PROTECTION OF OUR EUROPEAN USERS’ PRIVACY.

Until then, please note that as provided under article 49 of the GDPR, we have the obligation to inform you of the possible risks of the transfer of your personal data to the USA due to the absence of an adequacy decision or other appropriate safeguards since such invalidation. By using the Privet App, you guarantee having been informed of such risks and understanding them.

Since Privet Inc is located in the USA, we might transfer some of your personal information from the European Union, the United Kingdom or Switzerland, to the USA. We comply and have self-certified with the EU/UK-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, the European Economic Area, the United Kingdom and Switzerland to the United States.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will take precedence. You can also learn more about Privacy Shield at www.privacyshield.gov.

As described in the Privacy Shield Principles, Privet is responsible for personal data that it receives and subsequently transfers to third parties. If third parties that process personal data for us do so in a manner that does not comply with the Privacy Shield Principles, we are responsible for such failure, unless we prove that we are not responsible for the event giving rise to the damage.

 

In compliance with the Privacy Shield Principles, Privet commits to resolve complaints about our collection or use of your personal information. EU, British and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should contact Mary J. Hildebrand, CIPP/US, CIPP/E by email at MHildebrand@lowenstein.com.

Privet has further committed to refer unresolved Privacy Shield complaints to ICRD-AAA, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICRD-AAA are provided at no cost to you.

As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Privet is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission

 

Section 2. Extraordinary disclosures

We may be obligated to disclose your personal data if we determine that such disclosure is reasonably necessary and required:

 

(a) to comply with applicable laws or judicial orders;

 

(b) to protect the rights or property of Privet or other users of our services, including in investigating any violation or potential violation of the law, this Privacy Policy, or our TOS.

 

We will always keep in mind that your data should be protected therefore we will always fight unjustified requests and be transparent about them.

 

If Privet or its business or assets are acquired by, or merged into, another company, that company will possess any personal data in our possession at such time and will assume our rights and obligations under this Policy.

 

Section 3. Security of data

We take security very seriously and therefore have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk linked to our processing of all data as described hereabove. To implement such measures, we have taken into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for your rights and freedoms as natural persons.

 

Section 4. CCPA

Even though the CCPA does not apply to Privet’s activity, we have provided you with all necessary information as provided under the CCPA:

  • we update our privacy policy every 12 months;

  • we have posted a conspicuous link to the privacy policy on our website;

  • we have informed you of the list of personal data that Privet might have collected about you over the last 12 months;

  • we have informed you on how to access or delete your personal data, and will not discriminate against you if you exercise your rights under the CCPA;

  • we have informed you that we do not sell your personal data.

 

TITLE 4 – Your Rights

As a matter of principle, you can exercise all your rights free of charge.

 

Section 1. Access/Rectification/Deletion/Portability of your personal data

On a general basis, you can access, rectify, or delete your personal data directly through the Privet App, or through the service providers we are relying on as described above or by contacting the support team directly through our application.

If you are unable to complete your requests through the Privet App or such services, you can send a detailed message explaining your request to us at: privetcustomerservice@gmail.com.

Privet will inform you if it can act on your request or if you need to do it directly in our application, with our support. Privet would also like to inform that the request you send for the exercise of your rights might be kept for follow-up purposes.

• Specification for deletion :

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed ;

  • you withdraw the consent you have previously given ;

  • you object to the processing of your personal data and there is no legal reason for such processing ;

  • the processing of personal data does not comply with the provisions of the applicable legislation and regulations ;

  • your personal data have been collected in relation to the offer of information society services to children under 16 years of age.

 

Please note that the exercise of this right may not be possible when the retention of your personal data is necessary for compliance with statutory or regulatory provisions and in particular for example for the establishment, exercise or defense of legal claims.

 

Section 2. Restriction of processing

You may request restriction of processing of your personal data in the cases provided for by laws and regulations. You can exercise this right directly through the Privet App or by contacting the support team directly through the application.

 

If you are unable to complete your requests through the Privet app or such services, you can send a detailed message explaining your request to us at: privetcustomerservice@gmail.com.

 

Section 3. Post-mortem Guidelines

You have the possibility to give guidelines in relation to the storage, deletion and communication of your personal data after your death to a certified trusted third party in charge of ensuring that the wishes of the deceased are respected in compliance with the conditions laid down in the applicable legislation.

 

You can exercise this right directly through the Privet App or by contacting the support team directly through the application.

If you are unable to complete your requests through the Privet application or such services, you can send a detailed message explaining your request to us at: privetcustomerservice@gmail.com.

 

Section 4. Changes to the privacy policy

Any changes we make to the Privacy Policy in the future will be posted on this page and, when mandatory, notified to you directly in the Privet App.

 

Section 5. Liability and Disclaimers

Limits on liability and disclaimers applicable to our privacy policy are provided under our TOS.

 

Section 6. Information for European users

Pursuant to Article 27 of the General Data Protection Regulation of the European Union, we have appointed ePrivacy GmbH, as our European Representative, which office is located at:

ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany

https://www.eprivacy.eu

We also want to inform you that you are entitled to lodge any complaint with regards to privacy matters in relation with our activity to your local data supervisory authority.

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