# Privacy Policy

Data Collector

Insynergi Oy - Y-tunnus 3141141-9, Linnavuorentie 28 C, 00950 Helsinki

Owner contact email: <info@insynergi.fi>

FULL POLICY

Data Controller

Insynergi Oy – Igor Ivanov, Linnavuorentie 28 C, 00950 Helsinki&#x20;

Owner contact email: <info@insynergi.fi>

Types of data collected

Among the Personal Data collected by this Application, either independently or through third parties, there are: email; first name; last name.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.

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Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.

The platform allows following user types to sign up – Worker/Supplier/Business Manager, Customers;

Worker / Supplier / Business Manager -&#x20;

Mandatory data that we collect: First Name, Last Name, Email, Contact Number, Position, App Language, Device Type, Device Id, Device Token, IP address

Optional information that the customer provides and we collect - Date of birth, Company ID for only (Worker OR Business Manager) type users, Image

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Information we collect from Customers

Mandatory data that we collect: First Name, Last Name, Email, Contact Number, Position, App Language, Device Type, Device Id, Device Token, IP, Choose between Client Company (Company ID) or Create own UnLogo company

To Create own UnLogo Company - Company Code, Company Name, Company type

Optional - Date of birth, Image

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Unless otherwise specified, all data requested by this application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.

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Users who have doubts about which data are mandatory are encouraged to contact the owner.

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Any use of Cookies – this application does not store or use any cookie.

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3rd party API – this application is using the following 3rd party service providers for various transactional and operational reasons necessary to run the app smoothly and also to provider an enhanced user experience. The user is advised to refer to the privacy policy of these 3rd party service providers respectively although we have covered here in this policy what data are we passing to them and what they are returning to us or what that data is used for. However, how they are processing his data is beyond our control and hence the user is advised to refer to their respective policy pages.

* Google Location API, service provided by Google Ireland Ltd.\
  User’s IP address is shared with Google Location API by this application, and in return the geo-location tagging is provided – this helps the application identify the geographical location of the user. Please refer to Google’s privacy policy to understand how they handle and process this data on their part.
* Google Maps, service provided by Google Ireland Ltd.\
  Used in connection with the Google Location API, the same information is provided, processed and returned. Please refer to Google’s privacy policy to understand how they handle and process this data on their part.
* Google Translation\
  This API is used to translate our web pages and app screens in different languages. We use both the technology provided by this API as well as human translators for this purpose. Google has access to any indexed and searchable data as available or as provided by us, but they will not store the data according to their policy for the translation purpose. Please refer to Google Translate’s privacy policy to understand how they handle and process this data on their part.
* Open Weather API

This API is used to get local weather information for the user. We pass the IP address of the user for this API to return the weather data and values. No other information is shared. Please refer to Open Weather’s privacy policy to understand how they handle and process this data on their part.

* Twilio SMS API\
  This API is used to send one-time password (OTP) text message to the recipient. The user’s contact information is not traded for any other purpose by us. Please refer to Twilio.com’s privacy policy to understand how they handle and process this data on their part.
* Stripe API – With web hooks, we are using this API to process your payments along with recurring future payments if you opt for one. This API is only used when a payment is processed. We do not store any of your bank or credit card related information on our servers, they are securely processed by Stripe and their partners. Please refer to Stripe.com’s privacy policy on how they handle and process this data.\
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The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

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Method and place of processing of the collected data

Processing methods

The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

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The processing is carried out using IT and / or telephone tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of third party technical services, postal couriers) may have access to the Data. Hosting providers, IT companies, communication agencies may also be appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

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Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

* the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
* the processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;
* the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
* the processing is necessary for the execution of a task of public interest or for the exercise of public authority vested in the Data Controller;
* the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

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Place

The Data is processed at the Data Controller's operating offices, where the servers are located and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.

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The User's Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

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The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.\
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The User can check if one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or requesting information from the Data Controller by contacting him at the details indicated opening.

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Retention period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

* Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
* Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User's consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.\
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At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

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Purpose of the processing of collected data

The User's Data are collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or executive actions, protect their rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Contacting the User.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the "Details on the processing of Personal Data" section.

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Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

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Contact the user

Mailing list or newsletter (this Application)

By registering with the mailing list or newsletter, the User's email address is automatically added to a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Application may be transmitted. The User's email address may also be added to this list as a result of registering with this Application or after making a purchase.

Personal Data processed: surname; e-mail; first name.

Rights of the User

Users can exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

* Withdraw consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.
* Oppose the processing of their data. The user can oppose the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
* Access their data. The user has the right to obtain information on the data processed by the owner, on certain aspects of the processing and to receive a copy of the data processed.
* Verify and request rectification. The User can verify the correctness of his / her Data and request its updating or correction.
* Obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any other purpose than their conservation.
* Obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
* Receive their data or have them transferred to another owner. The User has the right to receive his / her Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its unhindered transfer to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures connected to it.
* Propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

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Details on the right to object

When Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons connected to their particular situation.

Users are reminded that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

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How to exercise your rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

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Further information on the treatment

Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Application or related Services by the User.\
The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance

For needs related to operation and maintenance, this Application and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to "Do Not Track" requests

This Application does not support "Do Not Track" requests.\
To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the extremes of contact the user has. Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom.\
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If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

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Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data

This is information collected automatically through this Application (including from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, to the parameters relating to the operating system and the IT environment of the User.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Interested

The natural person to whom the Personal Data refers.

Data Processor (or Manager)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool through which the Personal Data of Users are collected and processed.

Service

The service provided by this application as defined in the relative terms (if available) on this site / application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

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Legal references

This privacy statement is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement only concerns this Application.

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