Article 1: Introduction
At Aditum Consulting Services B.V. ("us", "we", "our" or "Company") we value your privacy and the importance of safeguarding your data. Use and access to the App and the service are subject to this privacy policy ("Privacy Policy") which users and visitors should review. This policy explains the personal data and the purpose of collecting it, the content of the personal data to be collected, the method of collecting it, the method of storing it, how to process it, how to destroy it, and the owner's rights in relation to it, and how to exercise these rights when you use our mobile application ("App").
The App is available on the App Store and Google Play Store and is intended for use by an international audience.
Please read the Privacy Policy carefully before using or accessing the Service or the App. By using our App, you agree to the collection and use of information in accordance with this Privacy Policy.
Article 2: What is Personal Data?
In this Policy, "Personal Data" refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or de-identified information that is maintained in a form that is not capable of being associated with or reasonably linked to an individual.
Article 3: Information Collection and Use
Types of Data Collected
Personal Data
We may collect the following information:
- Email address
- Username or transaction ID
- Usage data
Non-Personal Data
Definition and Scope
For the purposes of this Privacy Policy, "Non-Personal Data" shall refer to data that, by itself, does not permit direct association with any specific individual. We may collect Non-Personal Data, including but not limited to Usage Data, during your interaction with the App.
Types of Non-Personal Data and Methods of Collection
a) Usage Data: Automatically generated information, which may be collected passively through various technologies such as cookies, log files, and similar data-gathering mechanisms, may include but is not limited to:
- Internet Protocol Address (IP Address): A numerical label assigned to your device participating in a computer network that uses the Internet Protocol for communication.
- Browser Type: Information about the web browser software you are using to interact with the App, including version and language settings.
- Diagnostic Data: This could encompass data necessary for the diagnosis of operational problems, the optimization of operational functionalities, and the conduct of performance analytics to improve the App's overall efficacy.
b) Aggregated Data: We may also gather aggregated data, which is statistical information that is not associated with any single user account and is used for analytical purposes.
Purpose of Collection
Non-Personal Data is utilized for various purposes, including but not limited to:
- Enhancing your user experience by optimizing our App functionalities.
- Conducting internal operations such as debugging, data analysis, and research to improve the App's performance.
- Generating analytical insights to assist in marketing strategies.
- Ensuring the security and integrity of the App and its data.
Disclosure to Third Parties
Non-Personal Data may be shared with third-party service providers for the purpose of improving our App, facilitating our internal operations, and complying with our legal obligations. Such third-party service providers are contractually bound to adhere to appropriate data protection standards and may not use the data for unauthorized purposes.
Article 4: Use of Collected Data
Purpose and Legitimate Interests
We collect and process data for the following purposes, predicated upon legitimate business interests, consent provided by you, or compliance with legal obligations:
- a) Service Provision and Maintenance: To facilitate the provision of the App's features, ensure its operational functionality, and implement necessary updates and enhancements.
- b) User Experience Optimization: To analyze user engagement and preferences in order to improve the design, functionality, and content of the App.
- c) Fraud Detection and Prevention: To monitor for irregular activity and secure the integrity of user data and transactions by employing necessary safeguards against fraudulent or unauthorized access.
- d) Regulatory Compliance: To meet legal and regulatory requirements, including but not limited to, data protection laws and financial transaction regulations.
Data Sharing and Third-Party Disclosures
Prohibition on Sale, Trade, or Rent of Personal Data
We do not sell, trade, or rent your personal data to third parties for their independent use without your explicit consent.
Data Processing Partners
We may engage third-party service providers, agents, or contractors ("Data Processors") to process data on our behalf for specific purposes, including but not limited to, data analysis, service optimization, and other related operational activities. These third-party entities are contractually obligated to adhere to relevant data protection and privacy laws, and to implement adequate security measures to ensure the confidentiality and integrity of your data.
Scope of Data Sharing
Data sharing with third-party entities will only occur in ways that are consistent with the purposes outlined in this Privacy Policy. Such sharing will adhere to applicable data protection laws and will be subject to contractual safeguards.
Liability for Data Processors
We undertake all reasonable efforts to ensure that our Data Processors are compliant with data protection laws. However, we shall not be held liable for any unlawful actions, omissions, or data breaches committed by these third-party entities that occur outside the scope of their contractual obligations to us.
Article 5: Your Rights to Your Personal Data
Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations.
These rights may include:
- Right to Access. You have the right to request a copy of the personal data we are processing about you.
- Right to Rectification. You have the right to have incomplete or inaccurate personal data that we process about you rectified.
- Right to be Forgotten (right to erasure). You have the right to request that we delete personal data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Right to Restriction of Processing. You have the right to restrict our processing of your personal data where you believe such data to be inaccurate; our processing is unlawful; or if we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish us to delete it.
- Right to Portability. You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you or the third party that subscribes to our services.
- Right to Objection. Where the legal justification for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
- Right Not to Be Discriminated. You have the right not to be denied service or have an altered experience based on having executed any of your rights.
Withdrawing Consent
If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge, such as where you wish to unsubscribe from marketing messages that you receive from us. If you wish to withdraw your consent, please contact us using the information found at the bottom of this page.
How to Exercise Your Rights
You can make a request to exercise any of these rights in relation to your personal data by sending the request to our privacy team by using the contact details below. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.
Article 6: Data Security
The security of your data is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its security.
Data Retention
We will only retain your personal data for as long as necessary for the purpose for which that data was collected and to the extent required by applicable law. When we no longer need personal data, we will remove it from our systems and/or take steps to anonymize it.
Article 7: Children's Privacy
We take the privacy of children very seriously. As a general rule, our App is not intended for use by children under the age of 15. We do not knowingly collect personal information from children under 15. If you are a parent or guardian and believe that your child under the age of 15 may have provided personal information to us, you can contact us for the purposes of ensuring this information is removed from our databases.
Article 8: Changes to This Privacy Policy
We may modify this Policy at any time. If we make changes to this Policy then we will post an updated version of this Policy on our App. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the App (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of a modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Article 9: Complaints
If you have a complaint about this policy or any element of your personal information that we hold then please contact us below. If you are not satisfied, then you have the right to lodge a complaint with the local data protection authority.
Article 10: Contact Us
To request a copy for your information, unsubscribe from our email list, request for your data to be deleted, or ask a question about your data privacy, please contact us at: