Privacy policy

Effective date 16.04.2019

 

This Privacy Policy explains what personal data is collected when you (you or User) use the Mmme mobile application provided by FORTIS COMMUNICATIONS INC (we) on any website or platform (Service), and how such personal data will be processed and shared.

 

Please read this Privacy Policy carefully before using our Service.  This Privacy Policy may be updated from time to time and in this case, we will notify you about it. The provision of our Services is regulated by Terms of Service that is available here FORTIS COMMUNICATIONS INC .

 

BY USING THE SERVICE, YOU CONFIRM AND ASSERT THAT (A) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY AND (B) YOUR USE OF SERVICE COMPLY WITH REQUIREMENTS OF THE TERMS OF SERVICE.

 

If you disagree with this assertions and promises, you must (a) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android); (b) contact us and request deletion of your data; (c) delete the Mmme application and/or any Mmme related widgets from your devices;

 

DEFINITIONS:

 

“Personal data” means is any data that could potentially be used to identify a particular natural person.

 

GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

 

EEA” means all current member states to the European Union and the European Economic Area.

 

Process” or “Processing”, in respect of Personal data, means collection, storage, and disclose to third parties.

 

  1. GENERAL
    • The Mmme acknowledges the privacy of Users and makes efforts to protect them against any unlawful processing of Personal data.
    • The Mmme applies all necessary relevant technical and organizational measures to protect User’s Personal data in accordance with the effective legislation. The Processing includes protection against unauthorized or illegal Processing and against accidental loss, destruction or damage while applying suitable technical and/or organizational measures
    • Although Mmme will take diligent efforts to ensure safe storage and Processing of Personal data, Mmme cannot guarantee it to be 100% secure and risk-free. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
    • U
    • The User acknowledge and agree that any video, images, audio files, texts (collectively – Content) uploaded User’s profile becomes publicly available to other Users connected, and can be collected and used by others. The User’s name may also be displayed to other Users.

 

  1. CATEGORIES OF PERSONAL DATA COLLECTED
    • Data provided by User. When registering for and/or using the Service User provide Mmme with full name, age, gender, marital status, e-mail and mobile phone number. User may also upload Content, which in some cases, may be considered as Personal data.
    • Data collected automatically:
      • Advertising ID’s Mmme collect User’s Apple Identifier for advertising (“IDFA”) or Google Advertising ID (“AAID”), depending on the operating system of User’s device. User can typically reset these numbers through the settings of User’s device’s operating system. Mmme does not control this.
      • Device and Location data. Mmme collect data from User’s mobile device. Examples of such data include: device settings, model of a device, hardware ID, operating system type, language settings, IP address, time zone, Internet service provider, mobile carrier.
      • Usage data. Mmme record how User interact with Service. For example, Mmme log User’s taps on certain areas of the interface, the features, and content User interact with, how often User use the Mmme, how long User is in the Mmme and User’s subscription orders. Mmme also record the advertising in Mmme with which User interact (and links to which those advertising lead).
      • Reference data. Mmme collect data about User’s referring to Mmme or URL. It may be the application or place on the internet where User were when were tapped on Mmme’s advertisement.

 

  1. PURPOSES FOR COLLECTION OF PERSONAL DATA
    • Provision of Service. Mmme collect Personal data to provide Service to its User’s. It includes enabling User to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
    • Management of accounts and provision of customer support. Mmme process User’s Personal data to respond to User’s requests for technical support, Service information or to any other communication that User initiate. This includes accessing User’s account to address technical support requests. Mmme may send User notifications or emails about the performance of Service, security, payment transactions, notices regarding Terms of Service or this Privacy Policy. Mmme may use Personal data to restore User account when it is needed.
    • To enforce our Terms of Service and to prevent and combat fraud. Mmme use Personal data to enforce agreements and contractual commitments, to detect, prevent, and combat fraud. Mmme may share User’s information with others, including law enforcement agencies (in particular, if a dispute arises in connection with Terms of Service).
    • Communication regarding use of Service. Mmme may communicate with User’s by push notifications or e-mails. Such communicating may include messages and reminders encouraging User to use Mmme. User may receive a push notification regarding publishing of new content by connected Users. User may opt out of receiving push notifications by changing the settings on the mobile device. Mmme may collect data concerning the date and time when the message was viewed by User, as well as when User interacted with it, such as by clicking on links included in the message.
    • Custormisation of User’s experience.
    • Sending of marketing communications. Mmme process User’s Personal data for marketing purposes. User may receive information about products, such as for example, special offers. Mmme may also show advertisements and send push notifications for marketing purposes. To opt out of receiving push notifications, User need to change the settings on device.
    • Personalization of marketing. Mmme use User’s Personal data to tailor advertising and possibly show them to User at the relevant time. User may opt out or influence personalized advertising by editing following settings on the one’s mobile device.

Android device: Open the Google Settings tap “Ads” and enable “Opt out of interest-based ads”. User can reset advertising identifier in the same section.

Google Ads is an advertisings delivery service provided by Google. It allows Mmme to tailor the advertisings in a way that they will appear. For example, show advertisings to Users who have not purchased a subscription. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

iOS device: Go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. Also, User can reset advertising identifier in the same section.

  • Analyzing and researching of use of the Service. Mmme perform researching and analyzing to plan, design, innovate, maintain, improve, analyze operations, and to modernize Mmme. This data is also used to test and improve offers and for statistical analysis purposes. It allows bettering understanding of what features Users like more, what categories of Users use Mmme. Mmme use Google Analytics to help analyze how Users use it. Google Analytics for mobile apps provides a platform to measure user interactions. This tool allowing Mmme to better understand and optimize User’s engagement with application.
  • To comply with legal obligations. Mmme may Process, use, or share User’s Personal data when the law requires it, in particular, if a law enforcement agency or court requests particular User’s Personal data by available legal means.

 

  1. LEGAL BASIS FOR PROCESSING OF PERSONAL DATA (Applies only to EEA-based Users)
    • This section explains what legal basis used my Mmme for each particular purpose of processing. For more information on a particular purpose, please refer to Section This section applies only to EEA-based Users. Mmme process EEA-based User’s Personal data under the following legal bases:
      • to perform our contract with User;
      • Under this legal basis Mmme:
    • Provide Service (in accordance with Terms of Service);
    • Customize User’s experience;
    • Communicate with User regarding User’s use of Service;
    • Manage User account and provide User with customer support;
    • Communicate with User regarding User’s use of Service
      • for other legitimate interests, unless those interests are overridden by User’s interests or fundamental rights and freedoms that require protection of personal data. Mmme rely on legitimate interests:
    • to communicate with User regarding User’s use of Service This includes, for example, sending push notifications reminding to exercise at appropriate times. The legitimate interest Mmme rely on for this purpose is interest to encourage User to use Service more often.
    • to research and analyze User’s use of the Service. Mmme legitimate interest for this purpose is interest in improving Service so that Mmme understand Users’ preferences and able to provide User with a better experience.
    • to send marketing communications

The legitimate interest Mmme rely on for this processing is interest to promote Service in a measured and appropriate way.

  • to personalize advertising

The legitimate interest Mmme rely on for this processing is interest to promote Service in a reasonably targeted way.

  • to enforce Terms of Service and to prevent and combat fraud

Legitimate interests for this purpose are enforcing Mmme’s legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms of Service.

  • to comply with legal obligations.

 

  1. SHARE OF PERSONAL DATA
    • Mmme share information with third parties that helping operate, provide, improve, integrate, customize, support, and market Service. Mmme may share some portion of Personal data, in particular, for purposes indicated in Section 2 of this Privacy Policy. The types of third parties Mmme share information with include, in particular:
      • Service providers

Mmme share Personal data with third parties that Mmme hire to provide services or perform business functions on Mmme’s behalf, based on instructions. Mmme share User’s personal information with the following types of service providers:

  • measurement partners
  • marketing partners (in particular email delivery services)
    • Law enforcement agencies and other public authorities. Mmme may use and disclose Personal data to enforce Terms of Service, to protect Mmme’s rights, privacy, safety, or property, and/or that of Mmme’s affiliates, Users or others. Mmme may use and disclose Personal data when respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

 

  1. EXERSICING OF PRIVACY RIGHTS
    • To be in control of personal data, User have the following rights:
      • Accessing / reviewing / updating / correcting Personal data. User may review, edit, or change the personal data that the one had previously provided to Mmme in the profile section.
      • Deleting your personal data. User can request erasure of Personal data by sending an email at [email protected] . When User requested deletion of Personal data, Mmme will use reasonable efforts to honor such request. Any request will be answered within 1 month as of its filing. In some cases, Mmme may be legally required to keep some portion of the Personal data for a certain time. In such event, Mmme will fulfill deletion request after obligations completed.
    • Additional information for EEA-based Users
      • Users who based in the EEA have the following rights in addition to the above:
    • Right to rectification. User has the right to request to rectify, without undue delay, any incorrect data pertaining to the respective User.
    • Right to limitation of processing. User can limit the use of Personal data collected.
    • Right of access. User may request a copy of personal data collected during use of the Mmme at [email protected] .
    • Objecting to or restricting the use of Personal data. User can ask to stop using all or some portion of Personal data or limit use thereof by requesting its erasure as described above or sending a request at [email protected] .
    • The right to lodge a complaint with supervisory User have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where User reside, work or where the alleged infringement has taken place.
    • The right to data portability. User can receive Personal data in a machine-readable format by send respective request at [email protected] .
      • Exercise the rights. To exercising their right to access User have the right to request from Mmme at any time:
    • Confirmation as to whether data related to them are processed by Mmme, the purpose of the processing, the data category and recipients of such data or the categories of recipients’ data is disclosed to;
    • Information as to the logic of any automated processing of Mmme pertaining to natural persons, at least in the case of automated decisions under the provisions of the GDPR.

Upon request the Mmme provides the information free of charge. However, Mmme may charge a reasonable fee if request is clearly unfounded, repetitive or excessive. Alternatively, Mmme may refuse to comply with User’s request in these circumstances.

  • Upon filing of a request by an authorised person, the notarised power of attorney must be attached to the request.
  • In case of death of the natural person, his / her rights are exercised by his / her heirs and the certificate of heirs shall be attached to the request. The heritage should be confirmed by respective certificate, issued in the death person’s jurisdiction.
  • Mmme shall review and pronounce on the request within 1 month as of its filing. This period may be extended by further two months, if necessary, for example, if User’s request is particularly complex or User have made a number of requests. Mmme shall inform the User as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When the User files a request by electronic means, the information is provided electronically, if possible, unless the User has requested otherwise.
  • Mmme provides an answer to the requesting person taking into account their preferred form for the provision of the information (orally or in writing – as a hard copy of electronically).
  • Where data do not exist or their provision is forbidden by law, access of the requesting party to such data is refused.
  • If the requesting party is not satisfied with the response received and / or believes that their rights related to Personal data protection were violated, they are entitled to exercise their right to

 

  1. AGE LIMITATION
    • Mmme do not knowingly process personal data from persons under 13 years of age. If you learn that anyone younger than 13 has provided us with personal data, please contact us at [email protected]

 

  1. INTERNATIONAL DATA TRANSFERS
    • Mmme may transfer and maintain on servers or databases some of User’s Personal data outside the European Economic Area (EEA) including in Canada or the United States of America.
    • The countries to which User’s Personal data transferred may not have the same data protection laws as User’s jurisdiction. For this purpose, Mmme take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure adequate protection of Personal data.

 

  1. CHANGES TO THIS PRIVACY POLICY

8.1. We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by, other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

 

  1. CALIFORNIA PRIVACY RIGHTS
    • California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes.
    • If User is a California resident, Mmme will provide the requested information to respective User email address. To obtain this information from lease User may send an email message to [email protected] , which includes “Request for California Privacy Information” on the subject line and state of residence. Notice: not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in response.

 

  1. DATA RETENTION
    • Mmme will store Personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy and Terms of Service, which includes (but is not limited to) the period during which User have an account. Mmme will also retain and use Personal data as necessary to comply with legal obligations, resolve disputes, and enforce agreements.

 

  1. DATA CONTROLLER
    • FORTIS COMMUNICATIONS INC, a company registered in the Canada (with registered office at 33 KINNEY GATE, Maple, ON, L6A2S5, CANADA) will be the controller of User’s Personal data. For any questions, concerning account or Personal data please contact us at [email protected] .