PRIVACY POLICY
Updated and Effective as of September 28, 2022
TABLE OF CONTENTS
1.General.
2. Personal Data (types, purposes, legal basis).
3. Ways of using personal information.
4. Third-party processing personal data.
5. Store personal information.
6. Personal data protection.
7. User’s rights.
8. Age required.
9. Specific provisions applicable under California privacy law.
10. Contact details
1.
GENERAL
Thank you for choosing to be part of
our community!
This privacy policy describes how our
organization ALTERBELAS UAB is the legal entity incorporated in accordance with
the laws of the Republic of Lithuania under the registration number 304065849
with the following address of registration: Šeimyniškių g. 5a, Vilnius, Lithuania
(collectively, “we”, “us”, or “our”) collects, uses, stores, transfers and
discloses personal information from our Users in connection with our Services.
One way to protect your privacy is to learn how will be used personal
information before you give it out. We attach great importance to your privacy
right and truthfully explaining why and how we use your information.
We hope you take some time to read
through it carefully, as it is important.
For the purpose of the General Data Protection
Regulation 2016/679 and any implementing legislation (the "GDPR"), ALTERBELAS
UAB will be the data controller responsible for any personal data we process.
In this privacy policy, the following
definitions are used:
«Services» refers to our Apps,
Websites, and any related services or properties we control;
«Apps» refers to games,
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 use our Services.
We have the right to update this
Privacy Policy from time to time so please be sure to check regularly.
We will notify you of any material changes by posting the new Privacy Policy on
the primary access points to the Services or as otherwise required by
applicable law.
Please read this Policy carefully and
do not hesitate to contact us if you have any questions at info@alterbelas.com.
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.
How to contact us:
Name: ALTERBELAS UAB
Address: Šeimyniškių g. 5a, Vilnius, Lithuania
E-mail: info@alterbelas.com
1. PERSONAL DATA (TYPES,
PURPOSES, LEGAL BASIS)
2.1. 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. Please, be notice that the types of
information that we may collect depend on how you use the Services and interact
with us.
|
Personal Data |
Purposes |
Legal Basis |
|
User-provided information (In certain
cases, we may require certain Registration Information, and in other cases we
may simply ask you voluntarily provide such Registration Information.) |
||
|
Registration Information (your name
(or nickname); login/name/e-mail address, password, age, gender); Location information (IP address;
Time zone; Information about your mobile service provider). |
To register for the Services (to
create an account) – only if its applicable to App. |
Contract* (art. 6(1)(b) of the GDPR) |
|
To provide and deliver the Services,
to enable to track your activity, to show information the app and your
progress |
||
|
Your name, e-mail, content of your
question or request, telephone number |
To communicate with us (for example:
to answer your question and requests). |
Legitimate interest* ((art. 6(1)(f) of
GDPR) |
|
User generated content (only if user
voluntarily provide it): chat data, pictures (photos), texts,
information that you provide in communications with our support team and
others. |
To provide all features of the
Services. |
Contract (art. 6(1)(b) of the GDPR) |
|
Name, e-mail, date of birth, details
of your purchase and payment history |
For billing (invoicing), account
management and other administrative purposes, if applicable |
Contract (art. 6(1)(b) of the GDPR) |
|
Information about your feelings and
emotional situation, mental well-being, and related activities, including
personal life. |
To provide features of the Services,
make recommendation for you. Please, be kindly noticed, that we
may ask your permission to connect to Apple HealthKit and Google Fit, to
enable us to import Personal Data about your health and activities into the
App. This imported data may include calories burned, heart rate, and other
data about your health. When you choose to have this data imported you are
subject to the Google Fit and Apple HealthKit privacy policies and practices. |
Consent* (art. 6(1)(a) of GDPR) |
|
Automatically collected information |
||
|
Device Info: type and model,
internet service provider, two-character country code, subdivision of country
(e.g., state), city, two-character language code, operating system, model
number, device type (phone, tablet), operating system and version number
(ex.: ios 7.1.3, android), hardware type, connection type (for example, WiFi,
3G, 4G), network service provider, device motion parameters and carrier.
|
To analyze, operate, and improve our
Services, to customize our Services, to support the existing functions of the
Services, to conduct research and create reports for internal use; To understand you and your
preferences to enhance your experience and enjoyment using our Services; We store Advertising ID to track the
success of our advertising and marketing programs; To store your App Data and App
progress; To connect to our Services; To comply with legal obligations and
law enforcement requests. |
Legitimate interest to improve our
service (art. 6(1)(f) of GDPR) |
|
To provide you with feedback and
information about your progress. To provide you Services |
Contract (art. 6(1)(b) of the GDPR) |
|
|
We may send push notifications to the
User to send you app updates, high scores and other service-related
notifications that may be of importance to you (You can disable this anytime
in your phone settings); To send you information and marketing
communications about our services such as tips, offers, and newsletters
through emails and push notifications. |
Consent* (art. 6(1)(a) of GDPR) |
|
|
Any kinds of information |
||
|
If you sign into the Services with
Facebook Connect (Instagram) or Google Connect or Apple we will collect
information that is visible via your Facebook or Google account such as: (1)
your first and last name, (2) Facebook ID/Google ID/Apple ID (3) Profile
Picture/URL, city level location |
Alternative way to register (only for
voluntarily users desires) |
Contract (art. 6(1)(b) of the GDPR) |
|
Analytics information: we integrate
certain analytics software, a third-party analytics provider in some of our
Apps. (user ID, in-Apps activity data, advertising ID, IP address, location) |
To help us optimise our Apps features
and events to each User. To allow us to track performance of
our marketing campaigns |
Legitimate interest (art. 6(1)(f) of
GDPR) |
|
Any information that
may be required by law |
To comply with our
legal obligations, including requests from public authorities. |
The legal basis* (art. 6(1)(c) of the
GDPR) |
*We generally process your personal
data on the following legal bases:
Contract. You have
entered a contract with us and we need to use some of your personal data to
provide services you have requested or take steps that you request prior to
providing services. For example, we cannot create an account for you if you do
not provide required information like your email address. If you do not provide
information indicated as required or mandatory within our service, it will not
be available to you.
Legal obligations. We may have to
process or share your personal data to comply with legal obligations, such as
to comply with a subpoena or legal process.
Legitimate interests. We process your
personal data for purposes that constitute our legitimate interests, such as
fraud prevention and safety; protecting our, your or others’ property rights;
exercising or defending legal claims; investigating violations of and enforcing
our Terms of Use; analyzing and improving our services; and marketing and
advertising.
Consent. In some cases,
we may process your personal data based on your consent, such as where we
request access to data on your mobile device through the prompts in your
device’s operating system. You have the right to withdraw your consent anytime
in the manner indicated at the time consent is requested with no impact on the
validity and lawfulness of collection or processing based on the consent made
before its withdrawal.
2.2. 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,
https://www.apple.com/legal/privacy/en-ww/) and through the Google Play Store
(Google, https://policies.google.com/privacy). Payment processing takes place
through a payment system, integrated into the app store, appropriate for your
platform. We may receive the billing and payment information that you provide
when your purchase is processed by someone else (like, Apple or Google, or
PayPal, Stripe) such as when you purchase subscription. If you purchase the
subscriptions in our apps, our third-party payment processor will collect the
billing and financial information it needs to process your charges. This may
include your postal address, e-mail address and financial information. We don’t
collect or store payment data, details or payments-related personal data.
However, our’s payment processors may share information with us related to your
purchases. We may use this information for purposes as described in this
Privacy Policy.
2.3. The app requires your permission
to access your microphone recordings and your photo and video library when you
use the app to activate voice command and to enable you to share your
achievements on your social media accounts. However, we do not collect or have
access to such data.
2.4. 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.
1. WAYS OF USING
PERSONAL INFORMATION
Purpose of this Privacy Policy is
fulfillment of the provisions of the Terms of Service (“Contract”) concluded
between the User and ALTERBELAS UAB. We collect user’s personal data when user
starts using our Services. For example, we may use the Personal Data in the
following ways:
(i) To provide User Service. Our main aim is
to perform our contractual obligation towards User and make our Service
available to User. We use information that you submit and information that is
processed automatically to provide you with all requested services.
(ii) Account setup and administration: We use
Registration information and information about your device to set up and
administer your account, provide technical and customer support and training,
verify your identity, and send important account, subscription, and Service
information.
(iii) Personalization: We use Personal
Data to personalize your experience with our Services. Some of our Services
will ask you to share your geolocation so we can customize your experience and
increase the accuracy of the Service. If you agree to share your geolocation
with us, you will be able to turn it off at any time by going to the privacy
settings on your mobile device or online. For example, we may ask for age
verification if we have reasonable doubts regarding your age.
(iv) Providing you with interest-based
(behavioural) advertising or other targeted content. We may use
information that is processed automatically for marketing purposes (to show ads
that may be of interest to you based on your preferences). We provide
personalized content and information to you, which can include online ads or
other forms of marketing. To make choices about Interest-Based Ads from
participating third parties, including to opt-out of receiving behaviorally
targeted advertisements from participating organizations, please visit the
Digital Advertising Alliance or Network Advertising Initiative consumer opt-out
pages, which are located
at http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices.
Users in the European Union should visit the European Interactive Digital
Advertising Alliance’s user information
website https://www.youronlinechoices.eu/.
(v) To communicate with you. We use the
information we have to communicate with you through newsletters, i.e. to send
you marketing notifications, receive your feedback about our App experience,
and let you know about our policies and terms. We also use your information to
respond to you when you contact us.
(vi) Research and development: We use Personal
Data for internal research and development purposes and to improve and test the
features and functions of our Services. We use information that is processed
automatically to better understand user behaviour and trends, detect potential
outages and technical issues, to operate, protect, improve, and optimize our
App.
(vii) Legal obligations: We may be
required to use and retain Personal Data for legal and compliance reasons, such
as the prevention, detection, or investigation of a crime; loss prevention; or
fraud.
(viii) Send you push
notifications, related information, including confirmations and reminders (if
you choose to allow that function)— user can choose to stop disable these
at any time, by opting out or changing your browser or device settings.
(ix) We may use Automatically
Collected information and Cookies information to maintain and improve
our Services, including to do the following things: (a) automatically update
the applications on your system; (b) remember your information so that you will
not have to re-enter it during your visit or the next time you access our
Services; (c) provide customized third-party advertisements, content and
information, unless it will include instructions on how to opt out of receiving
these advertisements, content and information in the future; (d) monitor the
effectiveness of third-party marketing campaigns; (e) monitor aggregate site
usage metrics such as total number of visitors and pages accessed.
1.
THIRD-PARTY PROCESSING PERSONAL DATA
We may share your information to
third-party companies to perform certain services, including but not limited to
hosting services, payment processing, analytics, 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 in the optimal
way, such as serving you personalized, relevant advertisements within the
Service. We hereby undertake not to conduct any disclosure or transfer of the
User’s personal data to any third parties, except Processors, mentioned in this
paragraph, without receipt of personal consent of the User. The following
companies are the Processors of the Personal Data of the Services of ALTERBELAS
UAB (In case you want to learn more about the services and privacy options
please consult their websites and privacy policies):
|
Processor |
Purpose |
Policy and opt-out |
|
Ad Partners: usually collect data
via their own tools (Software Development Kits or “SDK”) |
||
|
AppLovin Corp |
Advertising
service. Personal Data collected: Cookies and Usage Data. You may opt-out
of certain features through your mobile device settings, such as your device
advertising settings or by following the instructions provided in their
Privacy Policy. You may visit www.aboutads.info/choices or www.youronlinechoices.eu
(for individuals in the EU) to learn more about interest-based advertising
and how to opt-out of this form of advertising on your web browser by
companies participating in the Digital Advertising Alliance (“DAA”)
self-regulatory program. |
https://www.applovin.com/privacy/ |
|
AdColony, Inc |
https://www.adcolony.com/privacy-policy/ |
|
|
Сhartboost |
https://answers.chartboost.com/en-us/articles/200780269 |
|
|
IronSource Mobile Ltd. |
https://ironsource.mobi/privacypolicy.html |
|
|
Unity Technologies |
https://unity3d.com/legal/privacy-policy |
|
|
Analytic companies: provide us with
tools and technologies that allow us to better understand how users interact
with our services, usually collect data via their own SDKs |
||
|
Appsflyer and its integrated partners |
Mobile attribution and analytics.
Personal Data collected: Cookies and Usage Data. AppsFlyer, a mobile
marketing platform, helps App-Developers, Brands and Ad-Agencies attribute
installs to campaigns and optimize their users’ acquisition funnel. Personal
Data collected: Device Info, Identity Data. |
https://www.appsflyer.com/legal/privacy-policy/ |
|
Amplitude, Inc. |
Analytics service. Personal Data
collected: Cookies and Usage Data. |
https://amplitude.com/privacy |
|
Other partners |
||
|
Apple, Inc. |
To collect and process payments for
subscription to the App. Personal Data collected: Payment and banking
information and Usage Data. |
https://support.apple.com/en-us/HT210584 |
|
Amazon Web Services, Inc. |
Hosting and backend service Personal Data collected: various
types of Data as specified in the privacy policy of the service. |
https://aws.amazon.com/privacy/ |
|
Hetzner Online GmbH |
Internet hosting. Personal Data
collected: Cookies and Usage Data |
https://www.hetzner.com/rechtliches/datenschutz/ |
|
Facebook Ireland Ltd. |
Our Services measures conversions
using visitor action pixels from Facebook. This allows an analysis of the
effectiveness of Facebook advertisements for statistical and market research
purposes and their future optimization. Facebook Analytics is an analytics
tool provided by Facebook, Inc. (US) that may collect or receive information
from our Services. You can manage your personalized ad preferences in
relation to Facebook directly from your Facebook account. Personal Data
collected: Cookies, unique device identifiers for advertising (Google
Advertiser ID or IDFA, for example) and Usage Data. |
https://www.facebook.com/policy.php |
|
Google Inc. |
To collect and process payments for
subscription to the App; AdMob Google Inc. is an advertising service.
Personal Data collected: Cookies, unique device identifiers for advertising
(Google Advertiser ID or IDFA, for example) and Usage Data. |
https://policies.google.com/terms?hl=ru ,
https://firebase.google.com/terms/analytics/ |
|
Stripe |
To collect and process payments for
subscription to the App |
https://stripe.com/en-gb-us/privacy |
|
Competent Authorities |
To comply with a legal obligation, process or requests. 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. |
|
1.
STORE 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, ALTERBELAS UAB
does not retain such data for more than 5 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. Except for any legal
obligation that sets a longer data retention period, at the end of these
periods, the processed personal data will be deleted or anonymized.
1.
PERSONAL DATA PROTECTION
6.1. Personal data may be processed by
both automated and non-automated means, and may be stored at our premises and
on our service providers’ servers. We understand that unfortunately, the transmission
of Information via the internet is not completely secure. We do all our best to
maintain the privacy and integrity of your Information. 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. However, transmissions over the Internet are never 100% secure, and
you should not provide any personal data if you want to avoid any risk. We will
also not use information received through your use of the HealthKit and Google
Fit framework for advertising or similar services, or sell it. Please
understand that you can help keep your information secure by choosing and
protecting your password appropriately, not sharing your password and
preventing others from using your mobile device.
6.2. 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. You acknowledge and agree
that The locations of servers for the services include:
(1) Lithuania and Germany (The European
Union) - the servers located in European Union which automatically process your
personal data and obtain the access to your personal data for the purposes of
manual processing;
Your data will be processed on our
servers which may not be located in your country of residence and can be
accessed by our support, engineering around the world. No matter where our
servers are located, we will make great efforts to take the appropriate
safeguards to guarantee your rights in conformity with this Privacy Policy and
any applicable laws. 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.
6.3. We implement
technical and organizational measures in an effort to protect Personal Data
from loss, theft, misuse and unauthorized access, disclosure, alteration and
destruction, taking into account the nature of the Personal Data that we
process and risks associated with special categories of Personal Data we
collect. These measures include Pseudonymization and tokenization of certain
categories of your Personal Data.
1.
USER’S RIGHTS
We attach great importance to user’s
privacy and would like to explain your data protection rights.
(i) The right to withdrawal. 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 the ALTERBELAS UAB
via its Support service, i.e. by sending an e-mail to the address info@alterbelas.com
with the topic «Consent withdrawal» or in the Settings menu of the application.
(ii) The right to know what
Personal Data we hold, 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 it you will still receive advertising, but not direct or
target interest. On Apple you can opt-out this 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 which is
out of date, incomplete or incorrect (according to Article 16 of the GDPR). In
certain specific circumstances you have the right to ask us to delete your
Personal Data which we are holding 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.
(vi) The right to object. You have the right to
object to ours processing of your personal data, under certain conditions.
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 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.
(viii) The right to portability
of your personal data. In some circumstances, you may have the right
to request that data which you have provided to us is provided to you, so 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. For more information, please contact your local
data protection authority. 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 the right to 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 that
information, or delete it in some circumstances. You have the right to request
us 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 copies
are provided on a reimbursement basis.
You may send the
request aimed at exercising your rights provided herein to our email or to our
business address: Šeimyniškių g. 5a, Vilnius, Lithuania. If you make a request,
we have one month to respond to you.
8. AGE REQUIRED
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. The residents of EEA or the UK 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.
9. SPECIFIC PROVISIONS
APPLICABLE UNDER CALIFORNIA PRIVACY LAW
This is additional information about
how we collect, use, disclose and otherwise process personal information 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
information about 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:
|
Category |
Examples |
Collected |
|
A. Identifiers. |
A real name, alias, postal address,
unique personal identifier, online identifier, Internet Protocol address,
email address, account name, Social Security number. |
YES |
|
B. Personal information categories
listed in the California Customer Records statute (Cal. Civ. Code §
1798.80(e)). |
A name, signature, Social Security
number, physical characteristics or description, address, telephone number,
passport number, driver’s license or state identification card number,
insurance policy number, education, employment, employment history, bank
account number, credit card number, debit card number, or any other financial
information, medical information, or health insurance information. Some personal information included in
this category may overlap with other categories. |
NO |
|
C. Protected classification characteristics
under California or federal law. |
Race, color, ancestry, national
origin, citizenship, religion or creed, marital status, medical condition,
physical or mental disability, sex (including gender, gender identity, gender
expression, pregnancy or childbirth and related medical conditions), sexual
orientation, veteran or military status, genetic information (including
familial genetic information), driver’s license number, passport number, or
other similar identifiers. |
NO |
|
D. Commercial information. |
Records of personal property,
products or services purchased, obtained, or considered, or other purchasing
or consuming histories or tendencies. |
NO |
|
E. Biometric information. |
Genetic, physiological, behavioral,
and biological characteristics, or activity patterns used to extract a
template or other identifier or identifying information, such as
fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,
gait, or other physical patterns, and sleep, health, or exercise data (Hair
color, eye color, fingerprints, height, retina scans, facial recognition,
voice, and other biometric data). |
NO |
|
F. Internet or other similar network
activity. |
Browsing history, search history,
information on a consumer’s interaction with a website, application, or
advertisement. |
YES |
|
G. Geolocation data. |
Physical location or movements. |
Only general information about
country and city (NOT GPS) |
|
H. Sensory data. |
Audio, electronic, visual, thermal,
olfactory, or similar information. |
NO |
|
I. Professional or employment-related
information. |
Current or past job history or
performance evaluations. |
NO |
|
J. Non-public education information
(per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g,
34 C.F.R. Part 99)). |
Education records directly related to
a student maintained by an educational institution or party acting on its
behalf, such as grades, transcripts, class lists, student schedules, student
identification codes, student financial information, or student disciplinary
records. |
NO |
|
K. Inferences drawn from other
personal information. |
Profile reflecting a person’s
preferences, characteristics, psychological trends, predispositions,
behavior, attitudes, intelligence, abilities, and aptitudes. |
NO |
We do not rent, sell, or share Personal
Information with nonaffiliated companies for their direct marketing uses as
contemplated by California’s “Shine the Light” law (Civil Code § 1798.83),
unless we have your permission. We do share personal information with
the Processors of the Personal Data of the Services of ALTERBELAS UAB mentioned
in paragraph 4.
As a California resident, you have the rights listed below:
You may exercise your California
privacy rights described above by emailing us. We will need to 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. If we
require more time, we will inform you of the reason and extension period in
writing.
10. CONTACT DETAILS OF THE ALTERBELAS UAB:
If you have any questions or comments
about this policy, you may contact us:
via email at: info@alterbelas.com.
The Company name: ALTERBELAS UAB
Address: Šeimyniškių g. 5a, Vilnius, Lithuania