PRIVACY POLICY 1. Introduction We know that you are concerned about how we use and disclose personal data, and we are committed to complying with data protection and privacy laws that apply to us. This Privacy Policy tells you about the ways in which we protect your privacy and personal data we process about you. Tiskol d.o.o. and its affiliates (”Tiskol”, ”we”, ”us”, ”our”) is committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Service and any other documents referred to in it) applies to www.tiskol.hr (the ”Site”), all Tiskol owned mobile apps and other services, products and apps provided by Tiskol (collectively the ”Service”) and is intended to help you better understand how we collect any personal data from you or how you provide it to us, what rights do you have, how the data will be used, stored and disclosed by us, whether you are end user of our Service (”Registered User”) or whether you are just visiting our website. In this Privacy Policy the term ”personal data” means information that relates to an identified or identifiable natural person. ”Sensitive personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data and the processing of data concerning health, sex life or sexual orientation. We wish to remind you that Privacy Policy applies to personal data that we process when you use the Service. It does not apply to any links to third parties’ websites and/or services, such as third-party applications, that you may encounter when you use the Service. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for privacy polices of any third parties. By using the Service, you consent to the terms of this Privacy Policy and the collection, use and transfer of your personal data for processing in and outside Croatia, in accordance with privacy practices described in therein. Where and as required for sensitive personal information we will ask your explicit consent as described in this Privacy Policy. 2. Information We Collect From You (I) Data You Provide to the Service We collect information that is necessary for the use and for adequate performance of the Service. The following informations may be collected from our users, in connection with registration or their use of the Service (each such user a ”Registered User”). Those information may, in certain circumstances, constitute personal data. E-mail address First/Last Name Method of payment Billing address Payment information Password Your communications within our applications Information related to general health, such as audio recordings, activity goals and other health goals. Moreover, if you contact us or participate in a survey, contest or promotion, we collect the information you submit such as your name, contact information and message of the correspondence. If you use Facebook Connect to login, we collect the information you have made available in your public profile as well as your email address and a list of your friends. Information relating to health, such as information on menstrual cycles, may constitute sensitive personal data. We may process sensitive personal data in order to provide the Service to you and to the extent necessary or appropriate for compliance with relevant legal or contractual obligations. If the information we collect is health data or another special category of personal data subject to the European Union’s General Data Protection Regulation, we ask for your explicit consent to process that kind of data. You are not obliged to give your explicit consent and if you choose not to provide it certain features of the Service may not work properly or be fully unavailable. You can withdraw your consent at any time. By using the Service and voluntarily providing us with personal data you are consenting to the processing of provided personal data in accordance with this Privacy Policy. If you provide personal data to the Service you acknowledge and agree that such personal data may be transferred to the servers of the authorized third parties we collaborate with and are referred to herein, located in and outside Croatia. You may choose to provide other information to help improve your experience or enable certain features of the Service. Data recorded on your device may be transferred from your device to cloud storage space we use. Tiskol may store such information itself or such information may be included in databases maintained by Tiskol affiliates and service providers, such as Google Cloud Platform. If the stored data constitute sensitive personal data we will ask for your explicit conset as described in this Privacy Policy. If you purchase our products on App Store, you provide your payment information, including your name, credit or debit card number, card expiration date, CVV code and billing address. We do not store this payment information. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms. (II) Data Collected Automatically The Service may automatically collect the following information from you that in certain circumstances may constitute personal data: Service use event data such as which links or buttons you have clicked and the pages you have viewed; Purchase transaction data; The type of device you are using; Unique mobile device ID such as Apple IDFA; The IP address from which you access the Service; Depending on your device settings, location data; The name and version of the device operating system; and Applications installed in a mobile device. Google Analytics for Firebase, a web analytics service provided by Google, Inc., is an element of the Service. By using SDK, Google Analytics for Firebase collects and stores data such as time of visit, pages visited, time spent using the Service, your activities on the Service etc. For more information on how Google uses collected information please visit www.google.com/policies/privacy/partners/. Moreover, we use a service entitled Facebook Audience Insights, analytics tool provided by Facebook, Inc.. Facebook Insight analyzes, tracks, and distributes data collected in and through the Facebook pages of the Service for analytics and marketing purposes. For more information on how Facebook Audience Insights works please go to https://www.facebook.com/business/learn/facebook-audience-insights. 3. The Purposes for Which We Use The Data We use the data you provide for the following purposes: To set up and maintain your registration with the Service; To communicate with you; To prevent and investigate fraud and other misuses; To protect our rights and/or our property; To operate and improve our products and services; To manage the Service; To provide features available in the Service; To develop, improve, and protect the Service; For market research; To audit and analyse the Service; and To ensure the technical functionality and security of the Service. We use the data collected automatically for the following purposes: To improve customer service; To personalise user experience; To run a promotion, contest, survey or other feature of the Service; To manage the Service; To provide features available in the Service; To personalise the Service; To develop, improve and protect the Service; For market research; To audit and analyse the Service; and To ensure the technical functionality and security of the Service. 4. How We Disclose Data We do not sell, lease, rent or otherwise disclose the personal data relating to our users to third parties unless otherwise stated below or described at the time of consent. The personal data collected in the Service may be disclosed in the following manner: a) Personal data you provide to the Service: We may disclose personal data you provide to the Service with the following categories of third parties: To service providers, such as payment processors and data storage service providers, which enable us to provide the Service to you; To public authorities, such as law enforcement or governmental authorities or authorised third parties, if and to the extent we are legally required or permitted to do so by law or if we need to protect our rights or the rights of third parties and if such disclosure is reasonably necessary; To our subsidiaries and affiliate or a subsequent owner, co-owner or operator of the Service and their advisor in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, bankruptcy or other insolvency proceeding, or other corporate reorganisation, in accordance with this Privacy Policy. b) Data collected automatically: The data collected automatically in the Service may be disclosed to the following categories of third parties: To service providers, such as data and marketing analysis companies; To public authorities, such as law enforcement or governmental authorities or authorised third parties, if and to the extent we are legally required or permitted to do so by law or if we need to protect our rights or the rights of third parties; and To our subsidiaries and affiliates or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or other corporate reorganisation, in accordance with this Privacy Policy. Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the direct identification of individual users. 5. How You Choose To Share Your Data You may choose to share personal data about you from the Service with friends, family, or health professionals. You may also direct us to share personal data about you with other parties. For example, you might authorise us to link your Tiskol account with a third-party app such as Facebook, send status updates to your social media account, or direct us to share personal data about you with other third parties at your request. Please note that once you direct us to share personal data about you with such third parties, the use of personal data about you by the third party is no longer governed by our Privacy Policy. You can use the Service, for example visit websites, without providing any personal data. If you choose not to provide any personal information your usage of the Service may be limited or impossible. 6. Your Rights You have the following rights with respect to the personal data we hold about you: The right to know what personal data we hold about you: if you would like to know what personal data we hold about you please contact us at info@tiskol.hr. We seek to promptly respond to your inquiry, respecting the legal deadlines when applicable. The right to have incomplete, incorrect, outdated or unnecessary personal data corrected, deleted or updated: The easiest way to correct, delete or update the personal data you have provided to the Service is to log in to the Service and enter the necessary changes in the profile settings of the Service. If you have additional questions regarding the correction, deletion or updating of the personal data we hold about you, please contact us at info@tiskol.hr. The right to opt out of receiving electronic direct marketing communications from us: All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us please contact us at info@Tiskol.hr. If you live in the European Union you have legal rights as set out in the General Data Protection Regulation (”GDPR”) such as you can object to our processing of your information based on your legitimate interests or you can request restriction on our processing of your data in certain circumstances. You also have the right to lodge a complaint with your local data protection authority. If you have any additional questions and need assistance regarding your rights under the GDPR please contact us at info@tiskol.hr. Your request will be taken into account in accordance with applicable law. 7. Data Retention and Data Security We keep your account information as long as your account exists because we need it to manage your account and provide the Service. We will keep your personal data if necessary to comply with our legal obligations. Other information, such as data received by syncing your device with the application, we keep until you use your account settings or tools to delete the data or your account as we need this information to secure you your individual statistics. We take reasonable measures to protect personal data about you from unauthorised access or against loss, misuse and unauthorised access, disclosure, alteration or destruction by third parties by using a combination of technical, administrative and physical means. Despite these efforts to store personal data collected in and through the Service in a secure operating environment that is not available to the public we cannot guarantee the security of personal data during its transmission or its storage on our systems as no method of transmitting or storing data is completely secure. Further, while we attempt to ensure the integrity and security of personal data, we cannot guaratnee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against loss, misuse or alteration by third parties. 8. International Transfer of Personal Data Some elements of the Service may be hosted on servers located in countries outside your home country, such as in the European Union (”EU”) or in the United States (”U.S.”). The laws applicable to the protection of personal data in such countries may be different from those applicable in your home country. By registering with the Service, you consent to personal data about you being transferred outside your home country. Persons located in the EU have certain rights under European law with respect to your personal data, as listed in the General Data Protection Regulation. If you wish to exercise your rights please contact us via email at info@tiskol.hr. Tiskol commits to resolve complaints about our collection or use of personal data about you. You can direct any questions about the use or disclosure of personal data about you to us at info@tiskol.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data about you within 30 days of receiving your complaint. 9. Children’s Privacy You must be at least sixteen (16) years of age to register to and use the Service. This Service is not directed to children under the age of thirteen (13). We do not intend to collect personal data from children under the age of thirteen (13). Parents and legal guardians who believe that their child has provided us with personal data through the Service and wishes that submitted data is deleted please contact us at info@tiskol.hr. 10. Changes to the Privacy Policy From time to time we may change this Privacy Policy to harmonise it with changes in our privacy practices or for legal, regulatory or operational reasons. You can tell when changes have been made to the Privacy Policy by referring to the Last Updated legend on top of this page. If we materially change the ways in which we use and disclose personal data, we will post a notice in the Service and send an e-mail to our Registered Users. Your continued use of the Service following any changes to this Privacy Policy constitutes your acceptance of any such change made. 11. Questions or Concerns? Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Service, or the protection of the personal data we hold about you, please contact us via e-mail at info@tiskol.hr or by mail at : Tiskol d.o.o. Slavka Batusica 7 10090 Zagreb Croatia