PRIVACY POLICY 

Beat Feis App Limited (“Beat”) is committed to protecting the privacy of users of this App (the “App”) and will do everything in its power to ensure that users’ Personal Data is treated with respect to their fundamental rights and freedoms as well as personal dignity, with particular reference to confidentiality. 

We have prepared this Privacy Policy in order to briefly explain how we will collect, use, share and secure your Personal Data. It also describes your choices regarding use, access and correction of your Personal Data. 

We may require users to provide certain personal information and details in order to provide our services, and we would, therefore, like to explain the procedures and ways in which we handle data supplied to us. This Privacy Policy will also provide you with full information so that you are able to consent to the processing of your Personal Data in an explicit and informed manner, where appropriate. 

In general, any information and data which you provide, or which is otherwise gathered by us in the context of the App, will be used by BEAT in compliance with Regulation (EU) 2016/679 (“GDPR”). This means, in particular, that any Personal Data processing carried out by BEAT will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality. 

Data Controller 

The Data Controller regarding all Personal Data processing operations carried out through the App is BEAT, with registered offices at 80 Kirk Street, Strathaven, ML106BA United Kingdom. Support@feis.app  

To get in touch with BEAT for any information regarding how we process Personal Data, including a list of our data processors, please contact us using the contact form in the Contact section of the App. 

What information do we collect from you? 

As you use the App and, in particular, as you provide information in order to access the App’s services, BEAT may collect and process information related to you as an individual and which allows you to be identified, either directly or together with additional information (“Personal Data”). This information can be collected by BEAT both when you choose to provide it (e.g. when you register to use the App) or simply by analyzing your behavior on the App. 

Data voluntarily provided by users 

When creating an account on the App, you will be asked to provide certain Personal Data such as contact details (e.g. your name and email address) and marketing preferences, for the purposes listed below. 

Where the App allows you to register through your personal profile in social media (Social Login) with your prior and revocable consent, we may access the same limited information included in such profile, related to your name, age, location, likes, interests, contacts and images. 

Browsing data 

The App’s operation, as is standard with any App on the Internet, involves the use of computer systems and software procedures, which collect information about the App’s users as part of their routine operation, whose transmission is automatic when using Internet communication protocols. Although BEAT does not collect this information in order to associate it to specific users, it is still possible that, by their nature and through processing and association with further data held by third parties, such data may permit us to identify a user, either directly via that information or by using other information collected. As such, this information must also be considered Personal Data. 

This information may include several parameters related to your operating system and IT environment, including your IP address, location (country), the URI (Uniform Resource Identifier) addresses of resources you request on the App, the time of requests made, information about your activities on our App (for instance, the pages you visit, the goods you view), the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), details on the device (for instance, your computer, tablet or smartphone) which you use to access our App and so on, by means of cookies and other technologies which allow this tracking. 

Such data shall only be used by BEAT for anonymous, statistical purposes about the use of the App, without associating them to any identifier of the users, to ensure its correct operation and identify any faults and/or abuse of the App. This data may also be used for the purposes of investigating liabilities in the event of information crimes committed against the App. 

Processing activities 

The processing of data shall be made by such procedures, technical and electronic means, which are suitable to protect the confidentiality and security of data and consists of collection, recording, organization, storage, consultation, elaboration, alteration, selection, retrieval, alignment, use, combination, block, communication, dissemination, erasure, and destruction of data, including a combination of two or more of such activities. 

Why do we process this information? Purposes of processing and legal grounds 

BEAT intends to use your Personal Data, collected through the App, for the following purposes: 

To provide answers or services you request, including allowing the creation of an account, to receive information from BEAT and sending you alerts by means of push notifications; to verify your identity and assist you, in case you lose or forget your login/password details for any of  registration services; to allow you to create and maintain a registered user profile, to process your subscription, to contact you when necessary and respond to your requests and enquiries, including emails; to send you newsletters you have subscribed to as a service (containing only informative content)(“Service Provision”). 

No consent is required for the processing of data for the purposes since such processing is necessary to provide the services requested and, therefore, for the performance of an agreement to which you are a party or for the implementation of measures requested by you prior to entering into an agreement (GDPR art. 6,1b). It is not mandatory for you to give BEAT your Personal Data for these purposes; however, if you do not, BEAT will not be able to provide any services to you.  

For marketing, promotional and publicity purposes, including to carry out direct marketing, as well as to carry out studies, research, market statistics or surveys, via e-mail, SMS, push notifications, pop-up banners, instant messaging, phone calls by an operator, BEAT’s official social media pages, regarding BEAT’s products and services (“Marketing”), and to send you offers, promotions or other information about our goods and services. Processing for these purposes is based on your consent. It is never mandatory for you to give consent to BEAT for the use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from BEAT). Any consent given may also be withdrawn at a later stage.  
To create your user profile (individual and/or aggregate profiles) on our App, by collecting and analyzing information on the preferences you select and choices you make on the App as well as on your general activities on the App, through the use of profiling cookies (“Profiling”). This information will be used to personalize the Services provided through the App, where possible, to suit your preferences and choices, as well as to serve you with information and advertisements which may be relevant to you and your interests, to propose customized offers that may be of your interest, to give you information about other Apps/services which BEAT believes you may be interested in. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias.  Processing for this purpose is based on your consent, collected by means of the cookie pop-up banner and/or a specific tick box. It is never mandatory for you to give consent to BEAT for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalization of your user experience regarding the App). Any consent given may also be withdrawn at a later stage, either by modifying your device settings or contacting BEAT at the address mentioned above.  
For compliance with laws which impose upon BEAT the collection and/or further processing of certain kinds of Personal Data, including regulations on contests in case users participate to contests or prizes on our App (“Compliance”). When you provide any Personal Data to BEAT, BEAT must process it in accordance with the applicable laws, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations. No consent is required for the processing of data for this purpose since such processing is necessary to comply with a legal obligation (GDPR, art. 6, 1a). 
To prevent and detect any misuse of the App, or any fraudulent activities carried out through the App (“Misuse/Fraud”). Processing for this purpose is necessary to pursue BEAT’s legitimate interests in preventing and detecting fraudulent activities or misuse of the App (for potentially criminal purposes). 
To analyze and improve our service provision, enhance the App, evaluate the effectiveness of BEAT’s marketing activities and services, perform statistical and demographics analyses on BEAT’s corporate clients and registered users (“Analytics”). Processing for this purpose is necessary to pursue BEAT’s legitimate interests in the development and administration of the App and to improve the services provided on the App. 

Users shall not be required to provide Personal Data to browse public pages of the App. The provision of Personal Data for the purposes mentioned above is optional, however, failure to provide required data (indicated as such in the registration form, as applicable) may prevent users from completing registration and, therefore accessing the related services. 

Who will be able to access your Personal Data? 

In the framework of its activity and for the purposes specified above, your Personal Data may be shared with the following entities (“Recipients”): 

Duly appointed data processors, providing specific processing or accessory services (e.g.  storing data, sending out messages for us, web hosting, contests’ management, consumer service, IT services regarding the App operation, emailing) on BEAT’s behalf and under its instructions, whose data protection maturity has been checked by BEAT before entering into the required data processing agreement. The full updated list of appointed as data processors is available by contacting us; 
Selected individuals authorized by BEAT to process Personal Data needed to carry out activities strictly related to the provision of the services through the App (e.g. technical maintenance of network equipment and electronic communications networks), who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of BEAT); 
Public entities, bodies or authorities, in accordance with the applicable law or binding orders of those entities, bodies or authorities. We may also disclose your Personal Data when we believe in good faith that disclosure is necessary to protect your safety or the safety of others, investigate fraud, or respond to a government request. 

Personal data shall not be disclosed nor transferred to third parties, except in the event of extraordinary corporate transactions, when Personal Data may be assigned or contributed to third party purchasers/lessees or assigns.   

Data Transfer 

BEAT shares your personal data globally with other companies in order to carry out the activities specified in this Policy. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence. 

Personal data collected within the European Union may, for example, be transferred to and processed by third parties located in a country outside of the European Union. In such instances BEAT shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.  

Children 

In order to comply with laws protecting children’s online privacy, BEAT does not knowingly collect any Personal Data from children under 16. BEAT takes children’s privacy seriously. As such, we would recommend that a parent or guardian assist and guide any children under 16 which may intend to browse the App or access the services provided by BEAT. Children under age 16 should not use BEAT’s App or services. In the event that BEAT learns that it has inadvertently collected Personal Data from a child under the age of 16, BEAT will promptly delete such information. 

If parents/guardians would like to prevent a minor from accessing the App, programs are easily available which enable control over access to the Internet or specific Apps. 

Security of Personal Data 

All Personal Data collected and processed through the App will be stored and processed so as to minimize the risk of destruction, loss (including accidental loss), unauthorized access/use or incompatible use with the initial purpose of collection. This is achieved by the technical and organizational security measures put in place by BEAT. 

Retention of Personal Data 

Generally, BEAT will keep your Personal Data only for as long as strictly necessary, according to the reason for which it was collected: 

Personal Data processed for Service Provision will be kept by BEAT for the period deemed strictly necessary to fulfil such purposes. Information will, however, be kept for longer if we need it to address any claims regarding the services or to protect BEAT’s interests related to potential liability related to the Service Provision. 
Personal Data processed for Marketing and Profiling will be kept by BEAT from the moment you give consent until the latter is withdrawn. Where it is not withdrawn, consent will be asked to be renewed at fixed intervals of 24 months. Once consent is withdrawn (or not given, following a renewal request), Personal Data will no longer be used for these purposes, although it may still be kept by BEAT as it may be necessary to protect BEAT’s interests related to potential liability related to this processing. Personal Data processed for Soft Spam will be kept by BEAT from the moment where it is provided by you to BEAT until you object to this processing. Once you have objected, Personal Data will no longer be used for these purposes, although it may still be kept by BEAT, in particular as may be necessary to protect BEAT’s interests related to potential liability related to this processing. 
Personal Data processed for Compliance will be kept by BEAT for the period required by the specific legal obligations for which the Personal Data was processed. 
Personal Data processed for preventing Misuse/Fraud and Analytics will be kept by BEAT for as long as deemed strictly necessary to fulfil the purposes for which it was collected. 

After such periods, all data shall be deleted or anonymized, except that data we are required by law to keep for a longer period. 

What are your rights? How can you exercise them? 

As a data subject, you are entitled to exercise the following rights, at any time: 

Right of Access - the right to be informed of and request access to the personal data we process about you; 
Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete; 
Right to Erasure - the right to request that we delete your personal data; 
Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data; 
Right to Object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; 
the right to object to your personal data being processed for direct marketing purposes; 
Right to Data Portability - 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; and 
Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. 
Opt out of interest-based advertising. We partner with a third party to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here [a]or if located in the European Union click here[b]. Please note you will continue to receive generic ads. 

Please note that most of the Personal Data you provide to BEAT can be changed at any time, including your e-mail preferences, by accessing, where applicable, your user profile created on the App. 

When requesting services via the App, you may have selected one or more means of communication via which Personal Data processing for Marketing purposes may be carried out (e.g.email, mail, social media). You may withdraw your consent to this processing for all selected means of communication by means of your user profile created on the App, where applicable. You can also withdraw consent for Marketing (for communications received via e-mail) by selecting the appropriate link included at the bottom of every marketing message. 

Consent for Profiling carried out by cookies may be withdrawn at any time. Where consent for Profiling was given via a specific tick box, you may withdraw this consent by changing your preferences, at any time, within your user profile created on the App, where applicable. 

At any time, you shall be entitled to exercise the rights established by the law in force, by addressing the relevant request to our Privacy expert at our registered address, as detailed above, or by using the contact form which can be found under the Contact section of the App.   

Finally, you are entitled to file complaints with to your local EU Data Protection Authority or to the data protection authority of the United Kingdom, the Information Commissioner’s Office (ICO) at https://ico.org.uk/, or Republic of Ireland Data Protection Commission at https://www.dataprotection.ie/docs/Home/4.htm if you believe that we have handled your information in an unlawful manner. 

Amendments 

This Privacy Policy entered into force on 10th January 2019. 

BEAT reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g. as a result of changes in applicable law. If BEAT makes any material changes we will notify you by means of a notice on this App prior to the change becoming effective. BEAT therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how BEAT collects and uses Personal Data.