PRIVACY POLICY

We are committed to respecting your data privacy and providing transparency about our data practices. This Privacy Policy (this “Privacy Policy”) explains how Codabrasoft LLC (“Company” or “we” or “us”) collects, stores, uses, transfers and discloses Personal Data from our users (“you”) in connection with the Company mobile application and related services (collectively, the “App”).

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified when you register), through the App, or by presenting you with a new version of this Privacy Policy for you to accept, if we, for example, add new processing activities or collect some additional Personal Data from you.

Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to Privacy Policy to continue using the App. We encourage you to periodically review our website for the latest information on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately and delete it if you do not agree to the terms of this Privacy Policy.

Personal data and information we collect about you

We collect the following Personal Data and information from you:

Contact Information such as name, email address, mailing address, phone number.

Preferences Information you provide such as product or content interests, or communication or marketing preferences.

Usage activity about how you interact with us such as purchase history, what content you viewed, and which areas of our site you visited.

Fitness, Health or Medical information such as prescription information, your weight, height, different symptoms, nutrition, consumption of water.

Device and Usage Information that may include information specific to your mobile device (e.g., make, model, operating system, advertising identifier and similar information); information about your use of features, functions, or notifications on the device; and signal strength relating to WiFi or Bluetooth functionality, temperature, battery level, and similar technical data.

Location Information that allows us to periodically determine your location, including your location relative to and within third party merchant locations

Demographic information such as age and gender

Information about your mobile device such as your mobile device id (similar to a website IP address), device type, and mobile service carrier.

We may collect this Personal data and information even if you are not logged in to the application. For iOS users: You should be able to adjust the settings on your iOS mobile device to prevent our collection of Location Information by disabling the location services feature on your device. For Android users: You should be able to adjust your settings on your Android mobile device to prevent our collection of Location Information be disabling Bluetooth and Location.
You will also have an option to permit us to import into the App data from third-party services such as Apple HealthKit and Google Fit, among others. Such imported information may include: sports activities, weight, calories burnt, heartbeat rate, number of steps/distance travelled, and other information about your health.
Permitting us to access third party information can help you to maximize your App experience, and we will handle any such third-party information in full accordance with this Privacy Policy.
If the information covered by this Section is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent information covered by this Section is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as “Personal Data”. We use pseudonymization for particular types of Personal Data. Please bear in mind that provisions of Section 3 do not apply to pseudonymized Personal Data.
YOUR CONSENT FOR PROCESSING OF YOUR PERSONAL DATA. By installing the App and creating a profile in the App, (or by explicitly accepting this Privacy Policy and explicitly consenting to the processing of your Personal Data) you explicitly consent that:
I. WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND THROUGH THE ACCOUNT CREATION PROCESS SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS YOU PROVIDED TO US.
II. PERSONAL DATA YOU PROVIDE TO US THROUGH THE ACCOUNT CREATION PROCESS OR USE OF THE APP INCLUDES PERSONAL DATA YOU ENTER INTO THE APP, SUCH AS YOUR ACCOUNT DATA (E.G. YOUR NAME AND EMAIL ADDRESS), AND YOUR HEALTH DATA (E.G. BODY MEASUREMENTS, PHYSICAL ACTIVITY AND OTHERS). DEPENDING ON THE DATA YOU PROVIDE, IT MAY ALSO CONTAIN INFORMATION ABOUT YOUR GENERAL HEALTH (E.G. WEIGHT, BODY TEMPERATURE, AND OTHERS).
III. WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES, EXCEPT IF IT IS REQUIRED TO PROVIDE THE SERVICE TO YOU (E.G. TECHNICAL SERVICE PROVIDERS), UNLESS WE HAVE ASKED FOR YOUR EXPLICIT CONSENT.

How we use your personal data and informaton
We may use your information, including your Personal Data, and by accepting this Privacy Policy you provide us your explicit consent, for the following purposes:
• to analyze, operate, maintain and improve the App and marketing activities, to add new features and services to the App;
• to assess your needs to determine suitable products or services;
• to send product updates or warranty information;
• to respond to your comments, questions and requests and provide customer service;
• to send you push notifications, both internal and external. IF YOU DO NOT WANT TO RECEIVE THESE NOTIFICATIONS, YOU CAN MANAGE YOUR PREFERENCE EITHER THROUGH YOUR DEVICE OR APP SETTINGS DEPENDING ON YOUR DEVICE TYPE. YOU CAN ALSO CONTACT US AT info@codabrasoft.com
• to send you marketing communications;
• to improve our App and marketing efforts to conduct research and analysis, including for scientific and academic research purposes; and
• for any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.
Choice/Opt-Out. You may opt-out of receiving our newsletter or marketing emails from us by following the unsubscribe instructions included in each newsletter or marketing email or you can contact us at info@codabrasoft.com
Social Networks. We enable you to create a profile, and share information such as messages, photos, and videos with others within your network. We cannot control the actions of others with whom you may choose to share your pages and information. Also, we cannot guarantee that the content you post on our App will not be viewed by others outside your network.
Any information (including Personal Data) you share in any online community area or online discussion is by design open to the public and is not private, unless provided differently in the App settings. You should think carefully before posting any Personal Data in any public forum. What you post can be seen, disclosed to, or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines.
If you mistakenly post Personal Data in our community areas and would like it removed, you can send us an email as listed below to request that we remove it. In some cases, we may not be able to remove your Personal Data, e.g. for technical reasons.
Information Obtained from Third Parties. Unless it is directly prohibited under applicable law in certain jurisdiction, we purchase marketing data about our customers from third parties and combine it with Personal Data we already have about you, to create more tailored advertising and products. Such data never includes any of your personal data that is considered to be ‘sensitive’ or falls under category of ‘special categories of personal data’ under applicable law. We will only use that information for the specific reason for which it was provided to us. By accepting this Privacy Policy, you provide your consent for such processing activities.

Your rights
Modification, correction, and erasure. You are able to modify, correct, erase and update your Personal Data in the App account settings or, if that is impossible, by writing us at info@codabrasoft.com.
Access. You have a right to access your Personal Data you insert into the App and ask us about what king of Personal Data we have about you. You can do this by using the app settings or by writing to info@codabrasoft.com.
EU residents. Individuals residing in the countries of the European Union have certain statutory rights in relation to their personal data introduced by the General Data Protection Regulation (the “GDPR”). Subject to any exemptions provided by law, you may have the right to request access to Personal data (including in a structured and portable form), as well as to seek to update, delete or correct Personal data:
a. Rectification of Personal Data and Restriction of Processing. You are responsible for ensuring the accuracy of your Personal Data that you submit to the App. Inaccurate information will affect your experience when using the App Web Sites and tools and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is inaccurate, you have right to contact us and ask us to correct such Personal Data by contacting us at info@codabrasoft.com. You shall also have the right to request restriction of processing of your Personal Data, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.
b. Access to your Personal Data and Data Portability. The App gives you the ability to access and update Personal Data within the App and your account settings. You shall have the right to request information about whether we have any Personal Data about you, to access your Personal data (including in a structured and portable form) by using your app settings or by simply writing us at info@codabrasoft.com.
c. Erasure of your Personal Data. If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent or object to the processing of your Personal Data, or in cases where the processing of your Personal Data does not otherwise comply with the GDPR, you have right to contact us and ask us to erase such Personal Data as described above. You can use simply write us info@codabrasoft.com. Please be aware that erasing some Personal Data inserted by you may affect your possibility to use the App and its features. Erasure of some Personal Data may also take some time due to technical reasons.
d. Right to object processing of your Personal Data. You can object processing your Personal Data and stop us from processing your Personal data you can simply write us at info@codabrasoft.com. Please be aware that erasing some Personal Data inserted by you may affect your possibility to utilize the App and its features.
e. Notification requirements. We commit to notify you within reasonable period of time and your data protection authority within the timeframe specified in applicable law (72 hours) about any personal data breaches in the App.
f. Data Protection Authorities.Subject to GDPR, you also have the right to (i) restrict our use of Personal Data and (ii) lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with GDPR.
Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.
Following the provisions of GDPR we might also require you to prove your identity (for example, by requesting an ID or any other proof of identity) in order for you to invoke the mentioned rights, specifically if you exercise them in respect to special categories of Personal Data like data about health. This is made to ensure that no rights of third parties are violated by your request, and the rights described in this section are exercised by an actual Personal Data subject or an authorized person.

Sharing your personal data and information
Sharing with third parties. We will share your Personal Data and information with third parties only in the ways that are described in this Privacy Policy.
We may disclose your Personal Data:
• as required by law, such as to comply with a subpoena, or similar legal process.
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
• to any other third party with your prior explicit consent to do so.
We share the information we collect with third-party business partners who commit to comply with applicable laws concerning their usage of your Personal Data (for example, GDPR for the EU residents). Our third-party business partners may share your Personal Data with their own third-party business partners, granted they have appropriate data protection safeguards in place, and use the information either for themselves or on behalf of their own business partners to:
• Operate and improve their services;
• Provide you with advertisements and information for products and services in this app or on other apps or websites based on variables such as your location, and assess your level of engagement with them; and
• Carry out other purposes that are disclosed to you and to which you consent.
Depending on a service you use, we may share some of your Personal Data and information with third-party business partners who perform analytical and other tasks for us (in some jurisdictions such parties may qualify for being a ‘processor’ under applicable laws). These are the third-party services with whom, among others, we may share some of your Personal Data and information:
1. Appsflyer. Appsflyer is a mobile marketing platform. We may share certain non-identifiable information about you and some Personal Data (but never any data related to health) in order to carry out marketing activities and provide you better and more targeted service. Learn more about Appsflyer: https://www.appsflyer.com
2. MoPub. Mopub is a subsidiary of Twitter, Inc. and a monetization platform. We may share non-identifiable information about you and some Personal Data (but never any data related to health) in order to carry out marketing and adds activities. Learn more about MoPub: https://www.mopub.com
3. Facebook. We use Facebook as our advertising partner to display advertising in our App or to manage our advertising on other sites. Normally, Facebook collects only non-personally identifiable information about your activities on this App and other apps to provide you targeted advertising based upon your interests. Learn more about Facebook advertising policy: https://m.facebook.com/ads/ad_choices
4. Fabric. We use Fabric, an analytics company and a Google subsidiary, to better understand your use of the App. For example, Fabric may use device identifiers that are stored on your mobile device and allow us to analyze your use of the App in order to improve our App features. Read more about Fabric here: https://get.fabric.io
5. Crashlytics.Crashlytics, a Google business division, provides us crash reporting solution that we use in order to track when the App crashes or works improperly on your device. Crashlytics may collect certain device identifiers in order to understand on what devices and under which circumstances the App does not work or crashes. See more about Crashlytics here:https://try.crashlytics.com/reports/
6. Appsee. Appsee is s a mobile app analytics platform that provides us tools that enable us to track and optimize the UX in the App through the use of some device identifiers. See more here: https://www.appsee.com

7. Flurry.Flurry is a Yahoo! Subsidiary and analytical platform that we use in order to analyze different use trends in our App. We may share certain non-identifiable information about you and some Personal Data (but never any data related to health) with Flurry. See more: https://developer.yahoo.com/flurry/legal-privacy/tos.html
   8. Zendesk.We use Zendesk as an intermediary for user support services. Zendesk may collect some of your Personal data (like contact information) in order to connect us with you.
8. Twitter.We use Twitter as our advertising partner to display advertising in Twitter. Normally, Twitter collects only non-personally identifiable information about your activities on this App and other apps to provide you targeted advertising based upon your interests.
   10.Firebase.Firebase is an analytics product from Google, Inc. that allows us to track crashes of the App, monitor events in the App, provide us stats regarding the use of the App. Firebase may collect certain device identifiers in order to understand on what devices and under which circumstances particular incidents and events happen. See more on Firebase:https://firebase.google.com/
   Our third-party partners are either EU-based or certified under EU-US Privacy Shield Framework that ensures that European data protection requirement are met. The privacy policy of these services can be found on their respective websites. Be informed that some third-party service providers may have their servers located in the United States.
   BY USING THE APP, YOU CONSENT THAT WE MAY USE COOKIES AND THIRD-PARTY SERVICES AND COLLECT YOUR USAGE (INCLUDING FOR PROCESSING BY THIRD-PARTY SERVICE PROVIDERS) AND SOME PERSONAL DATA UNDER A UNIQUE IDENTIFIER, FOR THE PURPOSES OF TRACKING, ANALYSIS, AND IMPROVEMENT OF THE APP. BY USING OUR SERVICE, YOU EXPLICITLY CONSENT TO THE USE AND PROCESSING OF YOUR DATA COLLECTED AS DESCRIBED ABOVE.
   Aggregated Information. We may also share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you. For example, we may share, including, without limitation, in articles, blog posts and scientific publications, general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users.

Data security
Security of your Personal Data is important to us. When you provide your Personal data that is considered to be sensitive or falls under “categories of special data” under applicable laws to us, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it.
Among others, we utilize the following security measures to protect your Personal Data:
a. Pseudominization and tokenization of certain categories of your Personal Data;
b. Protection of data integrity;
c. Encryption of your Personal Data in transit and in rest;
d. Systematic vulnerability scanning and penetration testing;
e. Organizational and legal measures. For example, our employees have different levels of access to your Personal Data, and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
f. Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and other internationally accepted data protection principles. We also commit to undertake privacy audit in case of Company’s merger or takeover.
Bear in mind that no method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our App, you can contact us at info@codabrasoft.com

Retention and storage of your personal data
We will retain your Personal Data for as long as the application is installed on your mobile device or as needed to provide you service. If you remove the application, we will remove your Personal Data and use copies of your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at info@codabrasoft.com
We use servers located in the European Union (Germany) to transfer, process, and store your Personal Data

Children’s privacy

General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 16 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 16. If you are aware of anyone under 16 using the App, please contact us at info@codabrasoft.com and we will take required steps to delete such information and (or) delete their account.

Data protection officer
To communicate with our Data Protection Officer, please email at info@codabrasoft.com

Contacting us
General contact details. If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at: 
Yury Zhalnerkevich

Codabrasoft LLC

68 Harrison Ave Ste 601
Boston MA 02111
yzhalnerkevich@codabrasoft.com

Email: info@codabrasoft.com