1. Introduction
Welcome to Aspecty, a mobile application available on iOS and Android platforms, as well as other devices. The Aspectyapplication is owned by the Estonian company SMTH MORE OÜ. Our company operates under Estonian legislation, including data protection laws, and complies with the regulations of the European Union, including the General Data Protection Regulation (GDPR).
SMTH MORE OÜ is committed to safeguarding your privacy and the security of your data. This Privacy Policy outlines the types of data we collect, how it is used, with whom it may be shared, and the measures we take to protect it. We are dedicated to ensuring transparency in how your personal data is processed and to complying with all applicable legal requirements.
We strongly recommend that you review this Privacy Policy to understand how we protect your information and the rights you have regarding your personal data.
2. Information We Collect
a. Registration Information
When you register for our application (whether it be a free version, paid subscription, or code use), we collect the personal information you voluntarily provide through your device. This information may include your name, email address, and other contact details.
b. Mobile Advertising ID
If you have not disabled this feature, we collect the Mobile Advertising ID provided by your device. This ID is used to show you relevant advertisements and improve your interaction with the app. If you do not want us to collect this ID, you can disable or modify it in your device settings.
c. Local Storage and Similar Technologies
To ensure the functionality of the application and enhance user experience, we use local storage technologies on your device. These technologies include, but are not limited to, data caching, authentication tokens, and other storage methods that help maintain session data and improve application performance. These technologies comply with the GDPR and Estonian Data Protection Law.
d. Usage Data and Analytics
We may use various tracking services to collect information about user behavior within the application. These services may collect data such as user actions within the app, usage frequency, preferences, and other statistics. All data is anonymized and used exclusively to improve the functionality of the application and provide personalized content. You can always opt-out of these services in the app settings. These activities are conducted in compliance with the GDPR and Estonian data protection regulations.
e. Social Media Integration
Our application may include buttons for integration with various social networks, allowing you to share content or recommend our application to other users. If you use these features, data such as your current IP address, browser and device information, the URL of the referring page, and other information provided by the social network may be collected. The processing of such data is also governed by the GDPR and Estonian law.
f. Payment Information
If you use paid features of our application or make in-app purchases, information about your credit card and other financial data will be collected and processed through third-party payment services that comply with PCI DSS standards. We do not store or process payment data directly; all information is protected and processed in accordance with the GDPR and Estonian Data Protection Law.
g. Children's Personal Data
We do not knowingly collect personal data from children under the age of 16 in accordance with GDPR requirements. If you are under 16, please do not register for our application or provide us with your personal data. If we become aware that we have collected data from a child under 16, we will delete that information promptly. If you believe that a child under 16 may have provided us with personal data, please contact us at info@smthmore.co.
3. How We Collect Your Data
We collect your data in the following ways:
Automatically when using the application. This includes collecting data about your device, IP address, browser settings, and other technical data necessary for the operation of the application.
Through local storage and similar technologies, such as data caching and the use of authentication tokens. These technologies help maintain session data and improve the performance of the application.
Through the data you voluntarily provide when using the application, such as registration, newsletter subscription, participation in surveys, and providing feedback.
4. Use of Information
We use the collected data for the following purposes, strictly in accordance with GDPR and Estonian law:
a. Service Provision and Improvement
We use your information to ensure the functionality of our application, as well as to improve and adapt it to your needs. This includes using data to support the application's performance, fix bugs, and enhance the user interface.
b. Personalization of User Experience
Your data may be used to personalize your experience in the application, including recommendations and personalized content. This is especially important to ensure that the services provided to you are as relevant and useful as possible.
c. Communication with Users
We may use your contact information to send notifications about important updates, changes to the terms of use, or to provide information about new application features. Additionally, we may send you marketing messages, but only with your explicit consent, as required by GDPR.
d. Analytics and Research
We use anonymized data to analyze user behavior and conduct research aimed at improving our services. All analytical processes are conducted in accordance with GDPR requirements, ensuring the confidentiality of your data.
e. Legal Compliance
We may use or disclose your information if necessary to comply with legal obligations, court orders, or requests from governmental authorities. This may include instances where disclosure is necessary to protect our rights, enforce the terms of use, or prevent fraud. In such cases, we will act strictly within the legal framework provided by GDPR and Estonian law.
f. Payment Processing
If you make in-app purchases, your payment data is processed through certified payment services that comply with PCI DSS security standards. We do not store or process your credit card information directly, in full compliance with GDPR.
g. Fraud Prevention
Your data may be used to protect against fraudulent activities, ensure the security of your data, and prevent unauthorized access.
5. Data Sharing
We do not share your personal information with third parties, except in the following cases, in compliance with GDPR and Estonian legislation:
a. Service Providers
We may share your information with trusted third parties who assist us in providing services such as hosting, data analysis, customer support, marketing, and payment processing. These third parties are required to maintain the confidentiality of your data and to use it solely for the services we request. All service providers are carefully selected and are obligated to act in accordance with GDPR.
b. Legal Requirements
We may disclose your information if required by law, court order, or request from government authorities. This may include cases where disclosure is necessary to protect our rights, ensure compliance with the terms of use, or prevent fraud. In such cases, we will act strictly within the legal norms provided by GDPR and Estonian law.
c. Data Transfer Outside the European Union
If we transfer your data outside the European Union, we ensure that appropriate data protection measures are in place, in compliance with GDPR requirements. This may include signing standard contractual clauses approved by the European Commission or ensuring that the data is transferred to countries recognized by the EU as providing an adequate level of personal data protection.
d. Corporate Transactions
In the event of a merger, acquisition, or sale of all or part of our assets, your data may be transferred to a third party as part of such a transaction. We will notify you of any such changes in data management and provide you with the opportunity to opt-out of further data transfer.
e. User Consent
We may share your data with third parties in cases where you have given explicit consent. For example, if you participate in joint marketing campaigns or other initiatives that require data sharing with partners. In such cases, we will always request your consent separately, ensuring transparency and control over your data.
6. Data Protection
SMTH MORE OÜ places great importance on protecting your personal information. We take all necessary measures to ensure the security of the data you provide to us, to prevent unauthorized access, use, or disclosure.
Technical Measures:
We use modern technological solutions to protect your data. An important part of our protection strategy is limiting access to data through authentication mechanisms, including verifying user credentials. This ensures that only authorized users have access to your data. Additionally, we conduct regular monitoring of activity within our application to detect and prevent suspicious actions.
Organizational Measures:
Access to your data is limited to a small number of employees who have been trained in data privacy and security practices. All SMTH MORE OÜ employees are required to follow internal policies and procedures for data protection.
Regular Audits:
We regularly conduct audits and checks of our security system to ensure compliance with our data protection standards and legal requirements.
User Responsibility:
We recommend that you use strong passwords and update them periodically to protect your account. You are responsible for the security of your account credentials and should take measures to protect your information.
We strive to minimize risks and ensure a high level of data protection for our users. If you have any questions about our security measures or if you detect a potential security threat, please contact us at info@smthmore.co.
7. User Rights
In accordance with the General Data Protection Regulation (GDPR) and Estonian law, you have the following rights regarding your personal data:
Right to Access Information
You have the right to request information about your personal data processed by us at any time, free of charge. You may request details about the processing purposes, categories of personal data, categories of recipients to whom your data has been disclosed, the planned retention period, the right to rectification, deletion, limitation of processing, or objection, the right to lodge a complaint, the sources of the data if they were not collected directly from you, and the existence of automated decision-making, including profiling, along with meaningful information about the specifics.
Right to Rectification
You have the right to request the immediate correction of any incorrect or incomplete personal data stored by us. If you believe that your data contains errors, you may request its correction.
Right to Erasure ("Right to be Forgotten")
You have the right to request the deletion of your personal data stored by us, except in cases where data processing is required for the exercise of the right to freedom of expression and information, compliance with legal obligations, reasons of public interest, or the establishment, exercise, or defense of legal claims.
Right to Restrict Processing
You have the right to request the restriction of the processing of your personal data if:
You contest the accuracy of the data;
The processing is unlawful, but you oppose its deletion;
The data is no longer needed by us, but you require it for the establishment, exercise, or defense of legal claims;
You have objected to processing pursuant to Art. 21 GDPR, pending the verification of whether our legitimate grounds for processing override yours.
Right to Data Portability
You have the right to receive your personal data that you provided to us in a structured, commonly used, and machine-readable format, or to request that it be transferred to another data controller.
Right to Object
If your personal data is processed based on legitimate interests pursuant to Article 6(1)(f) of the GDPR, you have the right to object to the processing of your personal data pursuant to Article 21 GDPR, provided that there are grounds relating to your particular situation, or if the objection is against direct marketing. In the latter case, you have a general right to object, which we will honor without the need to specify a particular situation.
If you wish to exercise your right to object, please send an email to info@smthmore.co.
8. Cookies and Similar Technologies
Our application Aspecty uses technologies similar to cookies to store data on your device. These technologies help us ensure the proper functioning of the application, personalize content, and enhance your user experience.
For more details on what data we collect and how you can manage your settings, please refer to sections 2 and 3 of this Privacy Policy.
9. Changes to the Privacy Policy
SMTH MORE OÜ reserves the right to periodically update or modify this Privacy Policy to reflect changes in our Aspecty application, as well as to comply with legal and regulatory requirements. Any changes will be published in the updated version of this Privacy Policy within the application.
Effective Date of Changes:
In the event of significant changes to the Privacy Policy, we will notify you through the application or by email (if you have provided us with your contact information) within a reasonable period before the changes take effect. This will give you an opportunity to review the new terms and, if necessary, take action.
We recommend that you periodically review this Privacy Policy to stay informed of any changes. Your continued use of the application after the changes have been made will be considered your acceptance of the new Privacy Policy.
If you have any questions about changes to our Privacy Policy, please contact us at info@smthmore.co.
10. Contact Information
If you have any questions or comments regarding this Privacy Policy, or any concerns related to the processing of your personal data, please contact us:
SMTH MORE OÜ
Address: Kesklinna linnaosa,Veskiposti tn 2-1002, 10138, Tallinn, Estonia
Email: info@smthmore.co
We are ready to answer your questions and assist you in exercising your rights regarding your personal data. Please do not hesitate to contact us with any inquiries related to privacy and data protection.