OurVibes

Privacy Policy

This Privacy Policy applies to OurVibes, our iOS and Android mobile application (our “App”). In the below policy, we inform you about the scope of the processing of your Personal Data. If you are using our website, please also refer to our website Privacy and Cookie Policy.

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General Information

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  a) What law applies?

In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the UK`s Data Protection Act (“DPA”) and the EU counterpart the General Data Protection Regulation (“GDPR”).

 

  b) What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address and device ID.

 

  c) What is Special Category Data?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.

 

  d) What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

 

  e) Responsible for data processing

The responsible party within the meaning of the DPA and the GDPR is OurVibes LTD of 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ (“OurVibes”, “we”, “us” or “our”).

 

If you have any questions or if you wish to exercise your rights, please feel free to email support@ourvibesapp.com, or write to us at the above address

 

  f) The Legal Bases for processing Personal Data

In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfilment of a contract / pre-contractual measures, c) the data is necessary for the fulfilment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

 

Processing of Automatically Collected Data

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  a) Downloading the App

The App can be downloaded from the "Google Playstore'' a service offered by Google LLC,, or the Apple "App Store" a service of Apple Inc. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

 

  b) Installing the App

As far as we are aware, Google collects and processes the following data: Licence check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which personal data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.

 

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.

 

  c) Device information

Google and Apple may collect information from and about the device(s) you use to access the App, including hardware and software information such as IP address, device ID and type, device-specific and App settings and properties, App crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass and Payment Data and Billing confirmations.

 

  d) Authorizations and Access

We may request permission to store your App data including your Internet Connection and Network, Camera,. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our App may not function as intended.

 

  e) Firebase

The App uses components of the Firebase App of Google LLC. By integrating Google services, Google may collect and process information (including personal data). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google actually collects and processes. However, Google states that, among other things, the following information (including personal data) may be processed in principle: Log data (in particular the IP address, Location-based information, Unique application numbers, Cookies and similar technologies for information on the types of cookies used by Google, please visit https://policies.google.com/technologies/types.  

 

  f) Google Analytics for Firebase

The App uses the web analytics service Google Analytics for Firebase, which uses tracking technologies to track your use of the App. Google Analytics is a web analytics service provided by Google LLC. In this respect, information is generated about, among other things, the number of users and their sessions, the session duration, the operating system used by the users, their device model, the region from which the app is accessed, the first start of the app, the app execution and any app updates.

 

In order to provide the relevant data for analysis, Firebase Analytics uses the mobile device's advertising ID, an app instance ID (a randomly generated number that identifies a single app installation), and the IP address, which is shortened (IP masking) before being processed on Google's servers (which may be located outside the EU/EEA) to generate the usage analysis. You can object to the use of Firebase Analytics at any time by disabling the sending of usage statistics in your device settings.

 

The information thus generated about your use of the app is transmitted to a Google server and stored there. It cannot be ruled out that data will be transmitted to the USA and that government agencies may be able to access this data.

 

Furthermore, it cannot be ruled out that this data will be processed by Google for its own purposes, such as profiling user behaviour, or linking the data with other data, such as with an existing Google account. We have no influence on these data processing operations.

 

Data processing by us

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  a) Contacting us

Personal Data is processed depending on the contact method. In addition to your name and email address, IP address or telephone number, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is processed for the purpose of dealing with your request and the legal basis is your consent. The use of your IP address takes place exclusively in the context of law enforcement and security measures in compliance with our legal requirements.

 

  b) Account Registration

If you register, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form (Email Address, and chosen Password). The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this storage is our legitimate interest and to fulfil our contractual obligations.

 

Alternatively, you are able to sign up using the convenience login and sign up from Google LLC or Facebook. For convenience login and sign up, you will be asked to provide your basic information (i.e., name, email address, and display picture) linked to your account. When registering via our convenience function, you agree to the relevant terms and conditions and consent to certain data from your respective profile being transferred to us. In both cases, the legal basis for the processing is your consent. You may withdraw your consent by deleting your account by contacting us.

 

  c) When using our services

We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations.

 

Some of the data you choose to provide may be considered non-Personal Data and/or “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.

 

Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.

 

Unless otherwise specified the purposes of processing are contractual performance and service, contact requests and communication, office and organisational procedures, administration, and response to requests, visit action evaluation. The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent.

 

You may withdraw your consent and request us to stop using and/or disclosing your personal and special category data by submitting your request to us in writing.

 

  d) Sharing with others

Of course, we also process the content you publish and share with others, as necessary for the operation of the services. In addition to the information, you may provide us directly, we receive information about you from others. Users may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.

 

We also share some users’ information with service providers and partners who assist us in operating the services. You share information with other users when you voluntarily disclose information on the service. Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent.

 

General Principles

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  a) Minors

Persons under the age of 18 should not transmit any Personal Data to us without the consent of their parents or legal guardians. We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

 

​  b) Automated decision-making

Automated decision-making including profiling does not take place.

 

  c) Do Not Sell

We do not sell your Personal Data.

 

  d) Sharing

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions. In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if OurVibes (or a part of OurVibes) is sold to or merged with another company; or if we have reason to believe that disclosure is necessary to protect OurVibes.

 

  e) International Transfer

Our main operations are based in the UK and your Personal Data is generally processed, stored and used in global data centres of Google (Firebase). We take steps to ensure there is an appropriate level of security, so your personal information is protected in the same way as if it was being used within Hungary. Where we need to transfer your data outside the UK and EEA, we will use approved standard contractual clauses in contracts for the transfer of personal data to third countries.

 

  f) Data Security

Our data processing is subject to the principle that we only process the Personal Data that is necessary for the use of our services. In doing so, we take great care to ensure that your privacy and the confidentiality of all Personal Data are always guaranteed.

 

Nonetheless, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

 

Your Rights and Privileges

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  a) Privacy rights

You can exercise the following rights:

 

• Right to information

• Right to rectification

• Right to deletion

• Right to data portability

• Right of objection

• Right to withdraw consent

• Right to complain to a supervisory authority

• Right not to be subject to a decision based solely on automated processing.

 

If you wish to exercise any of your rights, please contact us.

 

  b) Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

 

  c) Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

 

  d) Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

 

  e) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner's Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk

 

Changes

We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

 

Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using support@ourvibesapp.com.

 

Effective Date

Saturday, 29th of July, 2023