MLITE PRIVACY POLICY

Last updated: 14.05.2024

TABLE OF CONTENTS

1. 1. CATEGORIES OF PERSONAL DATA WE COLLECT

   a. Data you give us. You provide us with information about yourself when you register for and/or use the Service, namely email address. Also, we can collect and use images, which you voluntary upload via the App.

   
   

   b. Data provided by third parties. When you use sign in with Apple or Google to register an account in the App, we get personal data from your Apple ID or Google account. This data may include, in particular, your name and verified email address.

   
   
   c. Data we collect automatically:

   1. Data about how you found us. We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
   2. Device and Location data. We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, country and address, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID.
   3. Advertising IDs.We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device).
   4. Transaction data. When you make payments through the Service, you need to provide financial account data, such as, included but not limited to, your credit/debit card number, expiration date of credit/debit card, your e-mail to our third-party service provider Stripe (Find more in Stripe’s Privacy Policy). We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including:
      date, time and amount of the transaction, the type of payment method used.
   5. Contacts data. While using the Service, you may provide us with third-party personal data such as phone number, device and location data, contacts data, any personal data that can be indicated in text messages, SMS. You hereby authorize us to serve as a data processor to process these third-party personal data on your behalf. Please see Section DATA PROCESSING ON YOUR BEHALF: WE AS A DATA PROCESSOR for the details.
   
   

   d. Third-party data. While using the Service, you may provide us with third-party personal data such as phone number, device and location data, contacts data, any personal data that can be indicated in text messages, SMS. You hereby authorize us to serve as a data processor to process these third-party personal data on your behalf. Please see Section DATA PROCESSING ON YOUR BEHALF: WE AS A DATA PROCESSOR for the details.

   
   
   e. Cookies. Cookies are files that store the details of mLite users and / or Site visitors usage at the time of access to homepages on computer and inform such details to mLite.

   a. Installation and operation of automatic collection systems and users’ right of rejection.mLite uses cookies to store and retrieve mLite users' and / or Site visitors' information as needed, so as to provide personalized and customized services to individual mLite users and / or Site visitors. mLite may through cookies identify mLite users' and / or Site visitors' preferred contents on homepages, change its homepages based on members preferences and measure the level of use of homepages.

   1. - Purpose of using cookies: Analyze access frequency and visit hours of mLite users and / or Site visitors, identify and track their tastes and interests, and check participation in various events and number of visits, etc. thereby providing targeted marketing and personalized services.
   2. - A mLite users and / or Site visitors has the right to choose whether to install cookies. The mLite users and / or Site visitors may allow cookies, configure cookies or refuse cookies by setting web browser options. Please click here (Cookie Policy) for the details of mLite’s cookie policy.

2. 2. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

   We process your personal data:

   1. a. To provide our Service.This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. To host personal data and enable our App to operate and be distributed we use servers in Germany and Netherlands. We adopted all necessary security measures for protection of your Personal Data according to the best practices of security, protection and confidentiality. If we transfer your Personal data to third party service providers, we will compel each third party service provider to adopt necessary security measures for protection of your Personal Data according to our data protection agreement.
   2. b. To customize your experience. We process your personal data, in particular, such as your characteristics and preferences, to adjust the content of the Service and provide content tailored to your personal preferences.
   3. c. To manage your account and provide you with customer support. We process your personal data, in particular, such as your characteristics and preferences, to adjust the content of the Service and provide content tailored to your personal preferences.
   4. d. To communicate with you regarding your use of our Service. We communicate with you, for example, by push notifications. These may include emails. To opt out of receiving push notifications, you need to change the settings on your device. To opt out of receiving emails, you need to reply to the email – opt out, we will stop sending emails.
   5. e. To research and analyze your use of the Service. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use data for statistical analysis purposes, to test and improve our offers.
      1. To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Find more in Appsflyer’sPrivacy Policy.

      2. To analyze how visitors use the Service and to measure the effectiveness of some ads we use Google Analytics (Firebase), a web & app analysis program of Google. On Google Analytics we get, in particular, information on the data you enter on our Site and/ or App and users’ interactions within the Site and / or App. Google allows you to influence the collection and processing of the information generated by Google, in particular, by installing a browser plug-in, available here. Find more in Google’s Privacy Policy.

      3. To analyze how visitors use the Service and to measure the effectiveness of some ads we use Amplitude Analytics, an app analysis program of Amplitude, Inc. On Amplitude Analytics we get, in particular, information on the data you enter on our app and users’ interactions within the app. Find more in Amplitude’s Privacy Notice.

      4. To receive user's country giving IP address (Locate Online Visitors) we use MaxMind. MaxMind provides IP intelligence through the GeoIP brand of MaxMind, Inc. Find more inMaxMind’s Privacy Policy.

      5. To understand our customers and make better decisions with precise subscription revenue data (Mobile Subscription Analytics) we use Qonversion. Qonversion provides the data platform for mobile apps to grow in-app subscription revenue of Qonversion, Inc. Find more inQonversion’s Privacy Policy.

      6. We use Hotjar of Hotjar Ltd., which visually represents where you as a user click, move, and scroll on our App, including, but not limited to: full recordings of each visit, including the clicks, mouse movements, u-turns, and rage clicks. Find more inHotjar’s Privacy Policy.
   6. f. To send you marketing communications. We may process your personal data for our marketing campaigns. We may add your email address to our marketing list, provided we receive consent or otherwise establish legal basis for sending you marketing communications. As a result, you will receive information about our products, such as for example, special offers. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails. We may also show you advertisements in our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device.
   7. g. To process your payments. We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for our Service and we will be notified that the payment has been made and will provide you with. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
      Important Notice: Please be advised that for the security and protection of all users, it is strictly prohibited to transmit your complete payment details, including card number, CVV, and expiration date, through live chat or email, including our [email protected] email address. In the event that such information is transmitted, we explicitly disclaim all liability, and you accept full responsibility for any consequences arising from this action.
   8. i. To comply with legal obligations. We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

3. 3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

   In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA. This section applies only to EEA-based users.We process your personal data, in particular, under the following legal bases:

   Legal Basis	Purpose
   Consent	To send you marketing communications
   To perform our contract with you	To provide our Service (in accordance with our Terms of Use), to customize your experience, to manage your account and provide you with customer support, to communicate with you regarding your use of our Service, to process your payments
   Our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data	to research and analyze your use of the Service, to communicate with you regarding your use of our Service, to enforce our Terms of Use and to prevent and combat fraud
   Legal obligation	to comply with legal obligations.

4. 4. WITH WHOM WE SHARE YOUR PERSONAL DATA

   We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA of this Privacy Policy. The types of third parties we share information with include, in particular:

   mLite does not use the collected personal information for any purpose other than the purpose for which personal information is collected or provide such information to a third party, unless such use or transfer is permissible under the Personal Information Protection Act or other applicable laws and regulations.

   If third party transfer of personal information is necessary, mLite may provide personal information to a third party with separate consent of the subject of personal information. mLite currently provides personal information to third parties with consent as follows.

   1. Recipient: AppsFlyer
      Purpose of Transfer: AppsFlyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). AppsFlyer also provides us with different analytics tools that enable us to research and analyze your use of the Service.
      Categories subject to Transfer: mLite users.
      Retention Period: AppsFlyer will not retain: (i) End User Data for more than twenty-four months except where otherwise directed by Customers or required or allowed by law; and (ii) Registration Information, Log Data or Platform Data for more time than is needed to serve the legitimate business need for which it was collected. Find more in AppsFlyer’s Privacy Policy.
   2. Recipient: Google Analytics (Firebase)
      Purpose of Transfer: To analyze how visitors use the Service and to measure the
      Categories subject to Transfer: mLite users and / or Site visitors.
      Retention Period: Google retain the data it collects for different periods of time depending on what it is, how Google uses it, and how We configure our settings. Find more in Google’s Privacy Policy.
   3. Recipient: Amplitude Analytics
      Purpose of Transfer: To analyze how visitors use the Service and to measure the effectiveness of some ads.
      Categories subject to Transfer: mLite users and / or Site visitors.
      Retention Period: Personal Data that Amplitude processes on behalf of its Customers as a processor is retained for the period of time specified in the agreement between Amplitude and its Customers, unless Amplitude is required to retain the Personal Data for a longer period of time to comply with its legal obligations (for example, if we are required to retain your personal information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Find more in Amplitude’s Privacy Notice.
   4. Recipient: MaxMind
      Purpose of Transfer: To receive user's country giving IP address (Locate Online Visitors).
      Categories subject to Transfer: mLite users.
      Retention Period: MaxMind stores information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of its legitimate interests, including as necessary to comply with its legal obligations, resolve disputes, prevent fraud, and enforce its agreements. Find more in MaxMind’s Privacy Policy.
   5. Recipient: Qonversion
      Purpose of Transfer: To understand our customers and make better decisions with precise subscription revenue data (Mobile Subscription Analytics).
      Categories subject to Transfer: mLite users.
      Retention Period: Qonversion stores information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of its legitimate interests, including as necessary to comply with its legal obligations, resolve disputes, prevent fraud, and enforce its agreements. Find more in Qonversion’s Privacy Policy.
   6. Recipient: Hotjar
      Purpose of Transfer: Hotjar visually represents where you as a user click, move, and scroll on our App, including, but not limited to: full recordings of each visit, including the clicks, mouse movements, u-turns, and rage clicks.
      Categories subject to Transfer: mLite users.
      Retention Period: Personal Data will be retained for as long as is necessary for the purpose(s) for which Hotjar originally collected it or to provide its software, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, and enforce its agreement. Hotjar may also retain information as required by applicable law. Find more in Hotjar’s Privacy Policy.
   7. Recipient: Stripe
      Purpose of Transfer: Payment processing (payment processor).
      Retention Period: Stripe retains personal data as long as it is providing the services to mLite or our users (as applicable) or for a period during which Stripe reasonably anticipate providing the services. Even after it stop providing services directly to mLite or a business user with which mLite are doing business, and even if mLite closes its Stripe account or complete a transaction with a business user, Stripe retains personal data in order to comply with its legal and regulatory obligations. Stripe may also retain it to allow for fraud monitoring, detection and prevention activities. Stripe also keeps personal data to comply with its tax, accounting, and financial reporting obligations, where it is required to retain the data by its contractual commitments to its financial partners, and where data retention is mandated by the payment methods mLite used. In cases where Stripe keeps personal data, it do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Find more in Stripe’s Privacy Policy.
   8. Recipient: Hetzner
      Purpose of Transfer: Management and maintenance of server that stores personal information.
      Categories subject to Transfer: mLite users.
      Retention Period: Hetzner will retain personal data it processes for as long as needed in accordance with applicable laws and regulations. Find more in Hetzner’s Privacy Policy.
   9. Recipient: Servers.com
      Purpose of Transfer: Management and maintenance of server that stores personal information.
      Categories subject to Transfer: mLite users.
      Retention Period: Servers.com will retain personal data it processes for as long as needed in accordance with applicable laws and regulations. Find more in Servers.com’s Privacy Policy
   Law enforcement agencies and other public authorities.We may use and disclose personal data to enforce our Terms of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

5. 5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

   To be in control of your personal data, you have the following rights:

   1. Accessing / reviewing / updating / correcting your personal data. You have the right to review, edit, or change the personal data that you had previously provided to us in the profile section of the App. If you would like to receive a copy of data we process, please send us a data access request.
   2. Deleting your personal data. You can request erasure of your personal data, as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
   3. Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof. Additional information for EEA-based users.If you are based in the EEA, you have the following rights in addition to the above:
   4. The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
   5. The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above. The data will be made available to you in the .json file or other file format.
   The rights under Paragraphs above may be exercised by e-mail (please send a request to[email protected]) to mLite and mLite will take necessary prompt measures therefor.
   A subject of personal information must not infringe upon personal information or privacy of himself/herself or any third party in violation of the relevant laws.

6. 6. INTERNATIONAL DATA TRANSFERS

   We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards. In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

   
   

   AppsFlyer

   Country to which personal information is transferred: USA
   Contact detail: Attn: Legal Team/Data Protection Officer, 14 Maskit St. Herzliya, Israel 4673314 / The representative within the EU of AppsFlyer is AppsFlyer Germany GmbH Kurfürstendamm 11, c/o WeWork, 10719 Berlin, Germany (contact [email protected]; +49-30-3119-9129)

   Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network right away

   Categories of personal information transferred: ATT, WIFI, Operator, Carrier, Language. Android ID, IMEI, IDFA, Advertising ID, IDFV, Amazon Fire ID, Device Model, Device Type, Device Category, Platform, OS Version, User Agent, Device Download Time, Is LAT, OAID, Device Location, Region, Country Code, State, City, Postal Code, DMA

   Purpose of use of personal information by the person receiving personal information:AppsFlyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). AppsFlyer also provides us with different analytics tools that enable us to research and analyze your use of the Service

   Period of retention and use of personal information by the person receiving personal information:AppsFlyer will not retain: (i) End User Data for more than twenty-four months except where otherwise directed by Customers or required or allowed by law; and (ii) Registration Information, Log Data or Platform Data for more time than is needed to serve the legitimate business need for which it was collected. Find more in AppsFlyer’s Privacy Policy

   
   

   Google Analytics (Firebase)

   Country to which personal information is transferred: USA
   Contact detail: Attn: Legal Team/Data Protection Officer, 14 Maskit St. Herzliya, Israel 4673314 / The representative within the EU of AppsFlyer is AppsFlyer Germany GmbH Kurfürstendamm 11, c/o WeWork, 10719 Berlin, Germany (contact [email protected]; +49-30-3119-9129)
   Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network right away
   Purpose of use of personal information by the person receiving personal information: AppsFlyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). AppsFlyer also provides us with different analytics tools that enable us to research and analyze your use of the Service
   Period of retention and use of personal information by the person receiving personal information:AppsFlyer will not retain: (i) End User Data for more than twenty-four months except where otherwise directed by Customers or required or allowed by law; and (ii) Registration Information, Log Data or Platform Data for more time than is needed to serve the legitimate business need for which it was collected. Find more in AppsFlyer’s Privacy Policy
   

   Amplitude Analytics

   Country to which personal information is transferred: USA
   Contact detail: Attn: Data Protection, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States of America, email [email protected]
   Time and method of transfer of personal information: Same as above Categories of personal information transferred: ID self generated, Geo, Region, City, Ip, Language, Device id, Device type, Device Brand, App Analytics - crashes monitoring, Age, OS, Platform
   Purpose of use of personal information by the person receiving personal information: To analyze how visitors use the Service and to measure the effectiveness of some ads
   Period of retention and use of personal information by the person receiving personal information:Google retain the data it collects for different periods of time depending on what it is, how Google uses it, and how We configure our settings. Find more in Google’s Privacy Policy
   

   Qonversion

   Country to which personal information is transferred: DigitalOcean's data centers in the USA in the following locations: New York City, San Francisco
   Contact detail: Qonversion Inc., 1160 Battery Street East, Suites 100, San Francisco, 94111 / email: [email protected]
   Time and method of transfer of personal information: Same as above Categories of personal information transferred: User ID self generated, Geo, Region, City, Ip, Language, Device id, Device type, Device Brand, Age, OS,Platform
   Purpose of use of personal information by the person receiving personal information: To understand our customers and make better decisions with precise subscription revenue data (Mobile Subscription Analytics)
   Period of retention and use of personal information by the person receiving personal information:Qonversion stores information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of its legitimate interests, including as necessary to comply with its legal obligations, resolve disputes, prevent fraud, and enforce its agreements. Find more in Qonversion’s Privacy Policy.
   

   Hotjar

   Country to which personal information is transferred: Ireland, European Union (EU) to the Amazon Web Services infrastructure, eu-west-1 data centers
   Contact detail: Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta, Europe / tel. +1 (855) 464-6788 / email [email protected]
   Time and method of transfer of personal information: Same as above
   Categories of personal information transferred: Solution to user's screen recording while in App. Hotjar records user's screen while they are in App and sends the respective data to us for analytical purposes
   Purpose of use of personal information by the person receiving personal information: Hotjar visually represents where you as a user click, move, and scroll on our App, including, but not limited to: full recordings of each visit, including the clicks, mouse movements, u-turns, and rage clicks
   Period of retention and use of personal information by the person receiving personal information:Personal Data will be retained for as long as is necessary for the purpose(s) for which Hotjar originally collected it or to provide its software, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, and enforce its agreement. Hotjar may also retain information as required by applicable law. Find more in Hotjar’s Privacy Policy
   

   Stripe

   Country to which personal information is transferred: USA
   Contact detail: 354 Oyster Point Boulevard. South San Francisco, California, 94080, USA. Attention: Stripe Legal / email [email protected], [email protected]
   Time and method of transfer of personal information: Same as above
   Categories of personal information transferred: financial account data, such as, included but not limited to, your credit/debit card number, expiration date of credit/debit card, e-mail
   Purpose of use of personal information by the person receiving personal information: Payment processing (payment processor)
   Period of retention and use of personal information by the person receiving personal information:Stripe retains personal data as long as it is providing the services to mLite or our users (as applicable) or for a period during which Stripe reasonably anticipate providing the services. Even after it stop providing services directly to mLite or a business user with which mLite are doing business, and even if mLite closes its Stripe account or complete a transaction with a business user, Stripe retains personal data in order to comply with its legal and regulatory obligations. Stripe may also retain it to allow for fraud monitoring, detection and prevention activities. Stripe also keeps personal data to comply with its tax, accounting, and financial reporting obligations, where it is required to retain the data by its contractual commitments to its financial partners, and where data retention is mandated by the payment methods mLite used. In cases where Stripe keeps personal data, it do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Find more in Stripe’s Privacy Policy
   

   Hetzner

   Country to which personal information is transferred: Germany
   Contact detail: Industriestr. 25, 91710 Gunzenhausen, Germany/ email [email protected]
   Time and method of transfer of personal information: Same as above
   Categories of personal information transferred: All personal data that mLite processes
   Purpose of use of personal information by the person receiving personal information: Management and maintenance of server that stores personal information
   Period of retention and use of personal information by the person receiving personal information:Hetzner will retain personal data it processes for as long as needed in accordance with applicable laws and regulations. Find more in Hetzner’s Privacy Policy
   

   Servers.com

   Country to which personal information is transferred: Netherlands
   Contact detail: Keienbergweg 22, 1101GB, Amsterdam, Netherlands / email [email protected]
   Time and method of transfer of personal information: Same as above
   Categories of personal information transferred: All personal data that mLite processes
   Purpose of use of personal information by the person receiving personal information: Management and maintenance of server that stores personal information
   Period of retention and use of personal information by the person receiving personal information:Servers.com will retain personal data it processes for as long as needed in accordance with applicable laws and regulations. Find more in Servers.com’s Privacy Policy
   

7. 7. DATA RETENTION

   We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. 8. DATA SECURITY

   We have adopted technical and organizational measures to preserve and protect your personal data from unauthorized use or access and from being altered, lost or misused, taking into account the technological state of art, the features of the information stored and the risks to which information is exposed. Although we have exercised high levels of care in providing secure transmission of information between the App and our servers and in storing that information on our systems, no method of transmission over the Internet, or of electronic storage, is 100% secure. As such, we cannot ensure or otherwise guarantee the security of information transmitted to us over the Internet.

9. 9. CALIFORNIA PRIVACY RIGHTS

   This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

   For more details about the personal information we have collected, including the categories of sources, please see CATEGORIES OF PERSONAL DATA WE COLLECT above. We collect this information for purposes described in FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA of this Privacy Policy. We may also share your information with certain categories of third parties as indicated in WITH WHOM WE SHARE YOUR PERSONAL DATA. Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

   California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.

   Access rights under California’s Shine the Light law. California also provides its residents with additional access rights. Under Shine the Light law, the residents may ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute. To obtain this information from us, please send an email message to [email protected], which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

10. 10. CHILDREN’S PRIVACY

    The Children's Online Privacy Protection Act ("COPPA") requires us to inform parents and legal guardians about how we collect, use, and disclose personal information from children under the age of 13, which is described in this Privacy Policy as well. We do not knowingly sell any products to children; however, we may collect children’s personal data on your behalf as a parent and legal guardian. We encourage parents and legal guardians to monitor their children’s Internet usage. You are solely responsible for the tracked information accessed by you or any third party you have permitted to use the App and you agree to the Disclaimer of Warranties of the Terms of Use governing the use of the Site and the App.

11. 11. PERSONAL DATA CONTROLLER AND PERSONAL DATA PROCESSOR

    Data protection laws in certain jurisdictions differentiate between “controller” and “processor” of Personal Data. If you are visiting our Site, using the App and the Service, the Data Controller is the IPL GROUP PTY LTD. In situations in which Personal Data is processed by IPL GROUP PTY LTD on behalf of You, in particular when you provide us with the personal data of third parties while connecting the device, or using location feature via SMS, etc., Data Controller is You and IPL GROUP PTY LTD is the Data Processor.

12. 12. DATA PROCESSING ON YOUR BEHALF: WE AS A DATA PROCESSOR

    1. a. Target Device Data.We start collecting data from a target device associated with the account, which may include personal data relating to you, to a target device user(s) or to third parties (“Target Device Data”, including information about a target device, phone number, contacts, messages and SMS, geolocation, sound around the child's device). In accordance with applicable privacy law, to the extent that it applies to us, you are the Data Controller of this Target Device Data and you appoint us as a Data Processor of such data for the purpose of providing the Service.

       Sound around the child's device. You as a parent can choose to listen live to your child's device's surroundings or choose to record these surroundings for 15 seconds. You can save it in the App and download from the App to any data storage.

       For users from USA: Please note, that this feature is available only in US states, where the one-party consent for surroundings recording is applied. In other US states the Sound around the child’s device feature is prohibited due to local laws and requirements.

       For users from other countries: It is your responsibility to comply with the laws of your country due to Sound around the child’s device features usage. In some countries you have to get a consent from third-party (individual, which is staying near your kid) for recording surroundings with such individual’s participation (conversation, talks, etc.). Please, get an advice of your lawyer, how you can legally use the Sound around the child’s device feature in the country of your designation.

    2. b. Your use of Target Device Data. As Data Controller, you warrant that you have the appropriate authority, or have obtained a valid consent from third party as may be required by data privacy laws, to collect and process the Target Device Data and you agree to process and use the Target Device Data in accordance with this Privacy Policy, the Terms and applicable law, and only for the explicit purposes of the Service. You will protect the confidentiality of any accessible Target Device Data and prevent access by or disclosure to any unauthorized third person. You will inform us within 24 hours about any problem arising in relation with management of your account and/or Target Device Data
    3. c. Data Processor Obligations. To the extent that we are Data Processor on your behalf, we shall (a) implement appropriate technical and organizational measures to safeguard any Target Device Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to Target Device Data only to those employees who need to know it to enable the Processor to perform the Services; (c) only process the Target Device Data as specified by this Privacy Policy and in accordance with your instructions, and (d) will not use the Target Device Data for any purposes other than those related to the performance of the Service or pursuant to your written instructions. Upon the expiry or termination of this agreement by way of de-registration, or upon your request, we will cease any and all use of the Target Device Data and will destroy or return it to you except as provided above with respect to backed-up data and termination. We will not disclose Target Device Data to any third party without your prior written consent or pursuant to court or administrative order.
    4. d. Warranties. You are solely responsible for use of the account and the processing of personal data associated with your account, which includes, among others, collecting, storing and analyzing personal data from a target device. You warrant, as the one responsible for Target Device Data that we process on your behalf as Data Processor, that (a) you have informed any user(s) that are 13 years old or more regarding your usage of the Service, and have obtained consent from such user(s) for this kind of activity, as provided in our Privacy Policy, and (b) you comply with all applicable legislation with respect to data privacy, including children’s data privacy. You agree to fully comply with this Privacy Policy.
    5. e. Indemnity. You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of Target Device Data and other third-party personal data submitted to our systems during the course of use and provision of the Service.

13. 13. DESTRUCTION OF PERSONAL INFORMATION

    mLite will destroy personal information without delay at the expiration of the retention period, the achievement of the purpose or other reasons for which such personal information is no longer necessary.

    Notwithstanding the expiration of the retention period consented by the subject of personal information or the achievement of the purpose, in case where such personal information must be continued to be retained or used in accordance with other laws, such personal information will be transferred to a separate database or retained at a different place.

    mLite’s procedure and method of destroying personal information is as follows.

    Destruction Procedure: mLite will select personal information which has a cause for discard and discard such personal information with approval of its personal information protection manager.
    Destruction Method: mLite will destroy personal information printed on paper by shredding or incineration. For any personal information stored in electronic file format, mLite will delete such personal information by using technical method that will not allow data recovery.

14. 14. CHANGES TO THIS PRIVACY POLICY

    We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

15. 15. CONTACT US

    If you have any questions about this Privacy Policy, please contact us in one of the following ways: E-mail us at: [email protected] Send mails to: IPL GROUP PTY LTD, Suite 1, 215 Albany Street N, Gosford NSW 2250, AUSTRALIA