Privacy Notice

Last updated: March 05, 2024

Intro 

This privacy notice will inform you how we look after, collect, process, and use your personal data when you use our App and tell you about your legal rights.

About us

Hashtag Inovatsii EOOD is the controller and responsible for your data ("we", "us", or "our").

Name

Hashtag Inovatsii EOOD

Legal Address

Alabin №58 office 4.2, Sofia, Bulgaria 

Email

 traykovaevgeniya@gmail.com – for general questions

traykovaevgeniya@gmail.com – for privacy questions

Please note! We do not knowingly process the personal data of users under the age of 16. If you are such a user or the legal representative of such a user, please contact us.

By accessing or registering the App, the user agrees to the privacy notice and consents to collecting, processing, transferring, and using your personal data.

Before using the App, you must read and accept this privacy notice. If you don’t accept and agree to this privacy notice, you must immediately stop using our App.

Sources of data

Depending on your actions, we receive your data when you use and interact with the App.

You can change your personal data by exercising your right to rectification and contact us about it. Please note that the same lawful basis and storage terms apply to the changed data.

We may also receive data from third parties. It depends on your settings and the features you use.

Lawful bases

For processing your personal data, we rely on the following lawful bases:

Types of data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect (automatically or with your consent), use, store, and transfer different kinds of personal data about you, which we have grouped as follows:

Reasons for Processing

Types of data

 Lawful bases

For marketing and analytical purposes. To provide, improve, and develop the application.

Device Data. Includes model, OS version, and language. Unique device identifiers (including IDFA, GAID).

Performance of a contract with you.

Your consent.

Necessary for our legitimate interests (to keep our records updated and to study how customers use our app)

For marketing and analytical purposes. To provide, improve, and develop the application

Location data. Includes internet protocol (IP) address, location, country, state, city, zip code, and timezone.

Performance of a contract with you.

Your consent.

Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).

For marketing and analytical purposes. To provide, improve, and develop the app.

Information about how you use our App and user activity within it.

Performance of a contract with you.

Your consent.

It is necessary for our legitimate interests (to keep our records updated and to study how customers use our App).

This is for the purposes of user login in the App and connection with you.

Contact info. Includes your email address.

Performance of a contract with you.

Your consent.

To use the app's functions and calculate calorie intake.

Personal info. Weight, height, gender, age.

Performance of a contract with you.

Your consent.

To use the app's functions and calculate calorie intake.

Health and Fitness info. Your level of physical activity. User health and activity data from Apple HealthKit (Only for IOS operation system).

Performance of a contract with you.

Your consent.

To provide access to the application, identify the user, and track the subscription period.

Data on subscription fees.

Performance of a contract with you.

Your consent.

We don’t collect personal data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). We don't collect any information about criminal convictions and offences.

We also undertake to collect only such amounts and types of personal data strictly required for the purposes mentioned in this privacy notice section (data minimisation principle).

We will ask for your separate explicit consent for any new processing purpose. To the extent necessary for those purposes, we take all reasonable steps to ensure that personal data is reliable, accurate, complete, and current for its intended use.

Third-party services and disclosures of your data

We share your Personal Data with our service providers, strictly limited to cases and purposes stipulated in this privacy notice.

We’ll not use the information gained through your use of our app and other frameworks for advertising or similar services or sell it to advertising platforms, data brokers, or information resellers.

We require all third parties to respect the security of your personal data and treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes.

We will not process personal data in a way incompatible with the purposes for which it has been collected or subsequently authorized by you by Section "Types of data we collect" of this privacy notice or collect any personal data that is not required for the mentioned purposes.

We disclose potentially personally identifying information (i.e., personal data) among our employees, contractors, and affiliated or other third-party organizations that (i) need to know that information in order to process it on our behalf or to provide services available at Company, and (ii) that have agreed not to disclose it to others.

We share your data with the parties below for purposes listen in Section "Types of data we collect".

! External Third Parties: Google LLC, Meta Platforms, Inc., Apple Inc., Amplitude Inc., Velia.net Internetdienste GmbH, Firebase, Inc., Microsoft Corporation. 

These parties help us with the storage of Personal Data, analyse or keep your data, and show relevant information about the App to us when you use the app to understand how you use the App, engage with particular features, and what you like or dislike the most to generate statistical reports.

Cross-border transfer of personal data. 

Some employees, contractors, and affiliated or third-party organizations may be located within or outside the USA, EU, or the European Economic Area (EEA). By using our App, you consent to transfer such information to them.

Changes to the privacy notice

We reserve the right to and may change this privacy notice occasionally. If we make any material changes, we will notify you through our App or email or by presenting you with a new version of this privacy notice for you to accept if we, for example, add new processing activities or collect additional personal data from you.

Your continued use of the App after the effective date of an updated version of the privacy notice will indicate your acceptance of the privacy notice as modified.

Opt-out options.

You can withdraw your consent or opt out, whatever applies in your case, from sharing your Personal Data under this subsection anytime by using one of the following options:

Obtaining data from third parties

When a user buys a subscription, we receive transaction data, ID subscriptions, subscription terms, and App statistics from the Apple App Store and Google Play.

The App Store and Google Play data processing policy further regulates the collection, processing, and transmission of data on purchase via the Apple App Store or Google Play.

Banking information

When you pay for a subscription to our App, you share your banking information with the Apple App Store or Google Play. This relationship is further regulated between the user and privacy notices in the Apple App Store and Google Play.

We do not collect or process your bank information when buying a subscription.

Data security

We have implemented appropriate security measures to prevent your data from being accidentally lost, used, or accessed unauthorizedly, altered, or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data based on our instructions 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 of a breach where we are legally required to do so.

We also use technical data encryption tools like SSL protocols to secure your data.

Data retention

How long will you use my personal data?

We will only retain your data for as long as necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.

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 unauthorized use or disclosure of your data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

We store your data while you use our App.

In some circumstances, you can ask us to delete your data. To send an email to our address: traykovaevgeniya@gmail.com.

In some circumstances, we may anonymise your 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.

We require all third parties to respect the security of your personal data and treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and under our instructions.

We do not use user data for sale (or any other commercial activity) to other companies. User data is used solely to ensure the functionality of the app.

Your legal rights

European Economic Area residents

As a data subject, you have the right to interact with its data directly or through a request to us. This section describes these rights and how you can exercise them:

Right

Description

Right to access

You can request an explanation of the processing of your personal data.

Right to rectification

You can change the data if it is inaccurate or incomplete.

Right to erasure

You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law.

Right to restrict the processing

You may partially or completely prohibit us from processing your personal data.

Right to data portability

You can request all the data you provided to us and request to transfer data to another controller.

Right to object

You may object to the processing of your personal data.

Right to withdraw consent

You can withdraw your consent at any time.

Right to file a complaint

If your request was not satisfied, you could file a complaint to the regulatory body.

To exercise your rights, contact us. If your request is not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here.

UK residents enjoy the same rights but may lodge a complaint at the other Authority in the UK – Information Commissioner’s Office.

You can contact them at 0303 123 1113 or go online at www.ico.org.uk/concerns.

United States residents

You, as data subjects, have some special privacy rights. To use them, please contact us at traykovaevgeniya@gmail.com.

Please note! Depending on the state and legislative requirements, we have from 30 to 60 days to exercise your request, with the right to postpone it for 30 days more.

If your complaint is not satisfied, you can file a complaint with the Federal Trade Commission.

Your rights vary depending on the laws that apply to you but may include:

Right

Description

Area

Right to access

You can request an explanation of the processing of your personal data.

  • California;
  • Colorado;
  • Connecticut;
  • Indiana;
  • Iowa;
  • Montana;
  • Tennessee;
  • Texas;
  • Utah;
  • Virginia.

Right to correct

You can change the data if it needs to be more accurate or complete.

  • California;
  • Colorado;
  • Connecticut;
  • Indiana;
  • Montana;
  • Tennessee;
  • Texas;
  • Virginia.

Right to delete

You can request to delete your personal data from our systems.

  • California;
  • Colorado;
  • Connecticut;
  • Indiana;
  • Iowa;
  • Montana;
  • Tennessee;
  • Texas;
  • Utah;
  • Virginia.

Right to portability

You can request all the data you provided to us and request to transfer data to another controller.

  • California;
  • Colorado;
  • Connecticut;
  • Indiana;
  • Iowa;
  • Montana;
  • Tennessee;
  • Texas;
  • Utah;
  • Virginia.

Right to opt out of sales

The right to opt out of the sale of personal data to third parties.

  • California;
  • Colorado;
  • Connecticut;
  • Indiana;
  • Iowa;
  • Montana;
  • Tennessee;
  • Texas;
  • Utah;
  • Virginia.

Right to opt out of certain purposes

The right to opt-out of processing for profiling/targeted advertising purposes.

  • Colorado;
  • Connecticut;
  • Indiana;
  • Montana;
  • Tennessee;
  • Texas;
  • Utah;
  • Virginia.

Right to opt out of the processing of sensitive data

The right to opt-out of processing of sensitive data.

  • California.

Right to opt in for sensitive data processing

The right to opt in before processing sensitive data.

  • Colorado;
  • Connecticut;
  • Indiana;
  • Montana;
  • Tennessee;
  • Texas;
  • Virginia.

Right against automated decision-making

A prohibition against a business making decisions about a consumer based solely on an automated process without human input

  • California;
  • Colorado;
  • Connecticut;
  • Indiana;
  • Iowa;
  • Montana;
  • Tennessee;
  • Texas;
  • Virginia.

Private right of action

The right to seek civil damages from a controller for statute violations.

  • Californi.

Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is missing from the list, please contact us.

Do not sell my personal information

California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by the CCPA.

We do not sell your personal information to anyone nor use your data as a business model.

However, we support CCPA by allowing California residents to opt out of any future sale of their personal information. Please contact us if you would like to record your preference that we will not sell your data in the future.

Canada residents

As data subjects, you have privacy rights prescribed by Canada’s federal and provincial privacy laws.

If you want additional information, please contact us by filling a request.

If your complaint is not satisfied, you can file a complaint to the Office of the Privacy Commissioner of Canada.

Glossary

In this notice, the following terms shall have the following meanings:

Lawful basis. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

You can obtain further information about how we assess our legitimate interests against any potential impact on you regarding specific activities by contacting us at traykovaevgeniya@gmail.com.

Performance of Contract. This means processing your data where necessary for the performance of a contract to which you are a party or taking steps at your request before entering into such a contract.

Complying with a legal or regulatory obligation. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.