PRIVACY POLICY

Updated and Effective as of March 29, 2024

1. GENERAL

Thank you for choosing to be part of our community at Vebinsait, LLC (collectively, “we”, “us”, or “our”)! We are a company registered in the Republic of Belarus. We also determine the purposes and the means of the processing of your personal data and choose services and tools for its processing (“controller”). This privacy policy explains to you what personal information we may collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important.

In this privacy policy, the following definitions are used:

«Services» refers to our Apps, Websites, and any related services or properties we control;

«App» refers to applications, and other products produced by us on any and all platforms;
«Websites» refers to websites and other online properties we control;

«Personal Data» is used when referring to personal data that relates to you as an identified or identifiable individual;

«Anonymous data» does not include data where the identity has been removed;

«User, consumer» is any third party that accesses the App and is not either employed by Vebinsait, LLC or otherwise providing services to Vebinsait, LLC.

We have the right to update this Privacy Policy from time to time so please be sure to check regularly.

Please read this Policy carefully and do not hesitate to contact us if you have any questions at appsupport@w-i.by. Where applicable, if you do not provide us the relevant Personal Data, you may not be able to use our Services completely. You should not use the Services if you do not agree with this Policy, our Terms of Use and any other agreement that governs your use of the Services.

2. PROCESSING PERSONAL DATA

When you use our Services, we can collect, use, receive, process, transfer and share some of your Personal Data for different legitimate purposes. You will find below explanations regarding what Personal Data we may collect, the reasons why we may collect this data and the legal bases relied on in each case.

We collect personal data to ensure the Service provided, analyze your behavior during the usage of our Service, add new features to our Service, and provide our third-party service providers with information crucial to their services.

Providing Service includes enabling you to use the Service seamlessly and preventing or addressing Service errors or technical issues. As a result of such processing, we will use your email, for example, to send you the purchased product or to render services ordered through our Website. To host personal data and enable our Website to operate and be distributed, we use Amazon Web Services, a hosting and backend service provided by Amazon. We use Firebase Performance Monitoring, a monitoring Service provided by Google. Please visit Google’s Privacy Policy and Privacy and Security in Firebase to learn more. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.

To provide the Services, we may utilize your Location Data, Information about your contacts, Motion & Fitness Data only if you have provided consent for their use. Location Data may be used in the background mode of the App when the App is closed or not in use if you have consented to this. You may manage privacy settings for this data at any time in your device settings.

We may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In such cases we may use anonymous information without further notice to you since such information is not considered as Personal Data and cannot be connected with you.

3. THIRD-PARTY PROCESSING PERSONAL DATA

We may share your information with third-party companies to perform certain services, including but not limited to hosting services, payment processing, analytics, and customer service, and to assist us in our marketing efforts. We share your Personal Data with certain third parties as part of our operation of the Service, whether shared by us or gathered directly by third parties through SDKs integrated into the Service. This data sharing enables us to provide you with the Service optimally, such as serving you personalized, relevant advertisements within the Service. We hereby undertake not to disclose or transfer the User’s Personal data to any third parties, except Processors mentioned in this paragraph, without receipt of individual consent of the User. The following companies are the Processors of the Personal Data of the Services (In case you want to learn more about the services and privacy options, please consult their websites and privacy policies):

The links above indicate data retention periods for other Processors (other than us).

Our Services allow in-app purchases. In-app purchases are not mandatory and it is up to you whether to pay for accessing such functionality or not. You should know that we don’t process payments directly, payments processed via Apple App Store (Apple Inc., https://www.apple.com/legal/privacy/en-ww/) and through the Google Play Store (Google LLC, https://policies.google.com/privacy). We don’t collect or store payment data, details or payments-related personal data. Payment processing takes place through a payment system, integrated into the app store, appropriate for your platform.

We work in the international space and provide our Services to our Users around the world. We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located outside Belarus and choose to provide information to us, please note that we transfer the data, including Personal Data, to Belarus and process it there. This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Also, it is important to know, If we are bound to disclose your personal data by a judicial order or by a governmental or regulatory authority, we will comply and share the personal data with that body.

4. HOW LONG WE KEEP PERSONAL INFORMATION

We will keep your Personal Information for the length of time required to provide you with the Service and for the reasons described in this privacy policy, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide. In all cases, We does not retain such data for more than 3 years. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account. Data retention periods for other Processors are indicated by the links above.

5. PERSONAL DATA PROTECTION

The security of your information is fundamental to us. We have implemented industry standard security measures, which include the encryption to protect your personal information, including all information you input into your habit data or share in Services, and this information is not available to third parties.

6.  USER’S DATA PROTECTION RIGHTS

We attach great importance to user privacy and would like to explain your data protection rights. 

(i) The withdrawal right. It's important to remember that if we process your data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal is made by the mere notification of us via its Support service, i.e., by emailing appsupport@w-i.by with the topic «Consent withdrawal» or in the Settings menu of the application.

(ii) The right to be informed. The right to know what Personal Data we hold and how and why we handle your Personal Data. You can ask us for a copy of your Personal Data. If you would like to exercise your right of access, please contact us as described below and let us know what information, in particular, you would like to receive.

(iii) The right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt out, you will still receive advertising but not direct or target interest. On Apple, you can opt out by going to Settings > Privacy > Advertising and turning on "Limit Ad Tracking." On Android, you can opt out by going to Settings > Google Services> Ads and turning on choosing "Opt out of Ads Personalization."

(iv) The right to request an update or correction (rectify) to any of your Personal Data that is out of date, incomplete or incorrect (according to Article 16 of the GDPR). In certain circumstances, you have the right to ask us to delete the Personal Data we hold about you.

(v) The right to delete your Personal data. (Right to be forgotten). You have the right to request that we delete certain of your Personal data. There are situations where we are unable to delete your data, for example, when: it's still necessary to process the data for the purpose we collected it for; our interest in using the data overrides your interest in having it deleted (for instance, we need the data to protect service from fraud); we have a legal obligation to keep the data or require the data to establish, exercise or defend legal claims. For example, 

(vi) The right to object. You have the right to object to our processing of your personal data under certain conditions: we are processing your personal data on the legal basis of legitimate interest or processing your personal data for interest-based advertising. Object to us processing your personal data at any time on grounds relating to your particular situation Object to your personal data being processed for direct marketing purposes.

(vii) The right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence. You can do this if: your personal data is inaccurate; our processing is unlawful; we do not need your information for a specific purpose; you object to processing, and we are assessing your objection request.

(viii) The right to portability of your personal data. In some circumstances, you may have the right to request that the data you provided to us be provided so that you can transfer this to another data controller.

(ix) The right to complain to a data protection authority about our collection and use of your personal information. Don't hesitate to contact your local data protection authority for more information. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. 

(x) The right to Data portability. You have the right to Request a copy of your personal data in electronic format and transmit that personal data for use in another party's service.

(xi) The right to request access to the personal information we collect from you, change it or delete it in some circumstances. You have the right to ask for copies of your personal data. To request to review, update, or delete your personal information, please submit a request. We will respond to your request within 30 business days. The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional documents are provided on a reimbursement basis.

In this case, please send an email to appsupport@w-i.by.

If you are based in the EEA, you have the following rights in addition to the above: The right to complain to the supervisory authority. We would love for you to contact us directly so that we can address your concerns. Nevertheless, you can complain to a competent data protection supervisory authority, particularly in the EU Member State where you reside, work, or where the alleged infringement has occurred.

The right to data portability. If you wish to receive personal data in a machine-readable format, you can send a respective request to appsupport@w-i.by.

7. OUR POLICY TOWARDS CHILDREN

Our Services usually have a minimum age requirement of users and are not directed to children, and we do not knowingly collect Personal Data relating to children. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission. We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age. If you become aware that your child has provided us with Personal information without your consent, please contact us and we will take the required steps to delete such information.

8.  SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

Here is the additional information about how we collect, use, disclose and otherwise process the personal data of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with CCPA, and any terms defined in the CCPA have the same meaning when used in this notice. California law requires us to disclose the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

As a California resident, you have the rights listed below:

• The User can request information about how we have collected and used your personal information during the past 12 months, including the categories: The categories of information we have collected about you, the types of sources from which the data was collected, the business or commercial purpose for collecting your information the categories of third parties with whom we have shared your information, and the specific pieces of data we have collected about you;
• The User may request a copy of the personal information we have collected about you in the last 12 months. According to California's "Shine the Light" law, California resident users also have the right to request from us, once a year and free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes during the previous calendar year and the nature of the personal information disclosed to those parties. If you are eligible, please use the contact information below to make such a request;
• The User can ask us to delete the personal data we have collected from you. We may need certain types of information to provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services;
• The User has the right to be Free from Discrimination. We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data;
• The User has the right to opt out of the sale of personal information defined in a way that may include transferring data to third parties to personalize ads for you. Please note that the CCPA defines the term "sale" very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation. Depending upon the circumstances, the term "sale" could include a company providing a resident's data to another entity to assist the company with targeted advertising. We do not sell to third parties, and within the last 12 months have not sold any of your information. If you opt out of the 'sale' of your information, we will not sell your data, including to our advertising partners, but you may continue to receive ads from our Services, which may not be as tailored to your interests;
• The User has the right to complete your transaction;
• The User has the right to provide you with a good or service;
• The User has the right to perform a contract between you and us;
• The User has the right to protect your security and prosecute those responsible for breaching it;
• The User has the right to fix our system in the case of a bug;
• The User has the right to protect the free speech rights of you or other users;
• The User has the right to comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• The User has the right to engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
• The User has the right to comply with a legal obligation;
• The User has the right to make other internal and lawful uses of the information compatible with the context in which you provided it;
• Other Rights. The User can request certain information about our disclosure of your information to third parties for their direct marketing purposes during the preceding calendar year (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year. You also have the right not to be discriminated against for exercising the above-mentioned rights.

The User may exercise your California privacy rights described above by emailing us at appsupport@w-i.by. We must confirm your identity (e.g., first name, last name, account name, email address, state of residence, Etc.) and California residency to process your requests to exercise your information, access, or deletion rights. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. We will inform you of the reason and extension period in writing if we require more time.

The California Consumer Privacy Act (“CCPA”) provides California residents with the additional rights listed here. See the “Exercising Your California Privacy Rights” subsection below to exercise these rights.

Social sharing features

User has the right to know and see what information we have collected about you over the past 12 months, including:

• The categories of information we have collected about you;
• The types of sources from which the information is collected;
• The business or commercial purpose for collecting your information;
• The categories of third parties with whom we have shared your information;
• The specific pieces of data we have collected about you.

Right to Delete

The User has the right to request that we delete the information we have collected from you (and direct our service providers to do the same). There are several exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

• Complete your transaction;
• Provide you a good or service;
• Perform a contract between you and us;
• Protect your security and prosecute those responsible for breaching it;
• Fix our system in the case of a bug;
• Protect the free speech rights of you or other users;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adhere to all other applicable ethics and privacy laws;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

Right to Opt out

The User has the right to “opt out” or direct us to stop “selling” or otherwise sharing your information with third parties in exchange for monetary or other valuable consideration. To submit an opt-out request, please follow the instruction under the ‘Opt-out of targeted advertising’ paragraph above to configure the Privacy Setting in any of our apps or by checking your device’s privacy settings.

Other Rights

Users can request certain information about our disclosure of your information to third parties for their direct marketing purposes during the preceding calendar year (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year. You also have the right not to be discriminated against for exercising the above-mentioned rights.

Exercising Your California Privacy Rights

To request access to or delete your personal information, opt out, or exercise any other rights under California law, please email us at appsupport@w-i.by.

9.  MISCELLANEOUS

Conditions of the present PRIVACY POLICY may be unilaterally changed by us if required under the applicable laws or in other relevant cases with obligatory notification of the Users. The new version of the PRIVACY POLICY enters into force and is subject to observance by the User after the User has expressly agreed to its applicability. If the User does not agree to the relevance of the new version of the PRIVACY POLICY, the User will discontinue the usage of the Service and will not be allowed to use its account without the provision of unambiguous consent to the applicability of the new version of the PRIVACY POLICY.

10. CONTACT DETAILS OF THE VEBINSAIT LLC

If you have any questions or comments about this policy, you may contact us:

via email at: appsupport@w-i.by.

via post to:

Vebinsait LLC

Ponomarenko str. 34, 5g

Belarus, Minsk 220015