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    Privacy notice

    ENEBA MOBILE APP PRIVACY POLICY

     

    Version 1.2, last amended 2021-08-23

     

    UAB Helis play (“ENEBA”, or “us”) respects and strives to protect the privacy of our ENEBA mobile app (the "App") users. This Privacy Policy (the "Policy") explains how we process the personal data and other information of App users – ENEBA users who use the App to visit ENEBA Platform (the "Users" or "you") when using the App in accordance with the ENEBA Terms and conditions (the "Terms").

     

    We reserve the right to update or change the Policy at any time. You can always access the latest version of the Policy using the App, and we will notify you personally if the Policy is being changed significantly. To ensure that Users are kept as informed as possible about the processing of their personal data, we recommend that you review the Policy periodically and take note of any changes.

     

    PERSONAL DATA AND LEGAL GROUNDS OF PROCESSING

     

    Legal grounds

     

    Eneba collects and processes your personal data listed in the Policy on the following legal grounds:

    • Agreement (“the Agreement”) concluded between ENEBA and the User when creating account (“User Account”) on ENEBA platform www.eneba.com 
    • Your separate consents (permissions) for: 
      • sending mobile device operating system messages (push notifications)
      • access to mobile device video camera
      • access to mobile storage data, including pictures and video files (gallery)
    • Legal obligation to which ENEBA is subject
    • ENEBA’s legitimate interest (e. g. to collect statistical information, to prevent illegal or unlawful activity on the App, fraud prevention, to ensure proper functioning of the App and similar)

     

    To the extent and under the conditions provided by applicable law, processing of the same personal data may be subject to one or more of the above legal bases.

     

    For more information on collection of User data, including your name, e-mail address, phone number and physical address, please make sure to familiarize yourself with ENEBA Privacy Notice.

     

    To function properly, the App must have access to certain information on your device and certain features of your device. When you download and install the App on your phone or tablet, the App will access the following device data: mobile device operating system and mobile device model code. If you object to App’s access to such data, do not download or install the App on your mobile device.

     

    Using the App

     

    You will be able to log in to the App via User Account, created when registering on Eneba platform or within the App. You will also be able to use the App without creating / logging in to your User Account, however, some functionalities may be limited.

     

    Personal data collected through the use of the App

     

    When using the App, unique identifiers (User Account, your mobile device ID) will be collected and linked to your identity and processed for purposes indicated in this Policy. 

     

    If you grant / consent and / or have such permissions / consent set on your mobile device, the App may have access to your camera, mobile device storage, etc. If you have given your separate consent to the submission of notifications, we will be able to provide you with push notifications in the App (for more information, see the section "Notifications").

     

    We request the following permission:

    • Access to camera. Access to camera is required to enable the User to scan QR codes of Order packages, which is necessary for the performance of the Agreement and provision of courier delivery services. Access to camera is also required to allow the User to take and upload photos of delivered packages, damaged packages, returned packages and to provide other evidence related to provision of courier delivery services;
    • Access to the storage on your mobile device. Access to the storage of the mobile device is required when User opts to upload photo evidence (as described above) instead of taking pictures directly with the App.

     

    If you do not want the App to access above data, please review your device settings and make any necessary changes to restrict access or revoke your permissions. However, some of the permissions are required to post items on the ENEBA Platform (“Platform”), and you may not be able to create listings with pictures / photos if those permissions are revoked.

     

    Statistical information collected through the use of App

     

    When using the App, various statistical information will be collected by various trackers we have implemented in the App. We use the following trackers:

     

    These trackers will collect analytical data which includes your actions (search history, product interactions such as clicks, browsing of listings and similar) in the App as well as the marketing channel which lead you to install the App. You may opt-out of such tracking at any time by changing your tracking preferences. (you may opt-out of both tracking for statistical purposes and tracking for marketing purposes). 

     

    Diagnostic data collected through the use of App

     

    When using the App, various diagnostic data will be collected related to the performance of the App will be collected. Such data includes:

    • Crash data;
    • Performance data;
    • Other diagnostic data.

     

    This will be used for App functionality and analytic purposes. This data will not be linked to your User Account in any way and will not be used to track you.

     

    PURPOSES OF THE PROCESSING

     

    We shall use the collected and generated personal data for the following purposes:

    • to enable you to access the Platform via your mobile device;
    • to ensure that Platform functions correctly on your mobile device and you have access to services provided by ENEBA;
    • to resolve disputes and problems arising from the use of the App;
    • to ensure proper management of the App and operation, improvement and development of all its functions;
    • to conduct statistical research and analysis related to performance of the Platform, use of the App, effectiveness of ENEBA marketing channels;
    • monitor and analyze your use of the App and find ways to make it more convenient for you;
    • provide you with information about changes and updates to the App;
    • monitor the use of the App in order to prevent possible abuse, illegal use, fraud;
    • to comply with the legal requirements and legal obligations applicable to us;
    • to perform other actions necessary to ensure the proper functioning of the App.

     

    NOTIFICATIONS

     

    If you have given your separate consent to the submission of notifications, we will be able to provide you with notifications in the App (push-up notifications). You will find these notifications very useful for the use of the Platform. There will be two types of notifications: information about your transactions (“Transactional notifications”) and promotional notifications about upcoming deals, promotions and similar information (“Marketing notifications”). Transactional notifications will include notifications:

    • when your item is sold;
    • when the sale is confirmed by the buyer;
    • when a dispute is received;
    • when there was an update about the dispute;
    • when the purchased item is shipped;
    • when the item is delivered;
    • when the purchase is cancelled.

     

    Marketing notifications will include information about upcoming deals, promotions, discounts. These deals, promotions, discounts may be personalized specifically for you.

     

    You may change your device settings and not grant us permission to send you push-up notifications. Additionally, you may opt-out of Marketing notifications by changing the App settings.

     

    RETENTION OF DATA

     

    Aggregated App User data (e.g., App User age group, region, other data from Users' Google or Apple accounts (this data is provided by the Google Play or App Store platform operators - Google and / or Apple) will be stored for as long as the App is available to users. 

     

    Statistical data collected through trackers shall not be kept for longer than is necessary and in any case not longer than the User Account is active.

     

    User Account data, purchase information will be stored in accordance with ENEBA Privacy Notice.

     

    RECIPIENTS OF DATA

     

    We may transfer your data for processing to third parties – data processors who assist us in managing and developing the App. Such data processors may include App developers, developers, mobile app and application marketplaces, database administration service providers, data center, hosting and cloud service providers, market research or business analysis service providers, telecommunications service providers, other service providers, etc. In each case, we provide the data processor with only as much data as is necessary to execute a specific order or provide a specific service. The data processors may process your personal data only in accordance with our instructions and they must always ensure the security of your data in accordance with applicable law.

     

    The data may also be provided to the competent authorities or law enforcement authorities, in cases and procedures provided for by law, such as the police or supervisory authorities, but only upon request and only when required by applicable law or in cases and procedures provided for by law, to assert, provide and defend legal claims to ensure our rights, the safety of our customers, employees and resources.

     

    Please note that some data may be available to companies outside the European Economic Area, such as the in U.S. (Google, Apple etc.). The Company will ensure that personal data is transferred only if there are sufficient grounds provided for in the GDPR and other applicable legislation - such transfer may be necessary for the conclusion and performance of the contract, may be based on standard contractual clauses approved by the European Commission or may be based on other grounds, conditions or exceptions provided for in the GDPR. The Company will take reasonable steps to ensure that these third parties process personal data in accordance with GDPR and other mandatory legal requirements, ensuring the security of your personal data. For more information on what data is transferred outside the European Economic Area and on what basis, as well as other related questions, you can contact us by e-mail:privacy@eneba.com. 

     

    YOUR RIGHTS

     

    As a data subject, you have the following rights related to personal data subject to the requirements and conditions prescribed by applicable legal acts:

    • The right of access to your personal data;
    • The right to request the rectification of your personal data;
    • The right to request the deletion of personal data or to restrict the processing of personal data;
    • The right to portability of personal data;
    • The right to object to the processing of your personal data (when your personal data is processed on the basis of legitimate interests);
    • The right to withdraw consent at any time (when your personal data is processed on the basis of consent);
    • The right to lodge a complaint with the State Data Protection Inspectorate (for more information, visit www.vdai.lrv.lt). 

     

    Requests for the exercise of the above rights (including the withdrawal of your consent or disagreement with the use of your data), as well as complaints, notifications or requests may be submitted to us via e-mail:privacy@eneba.com. All data subject requests are executed and exercised subject to the conditions, limitations and exceptions provided for in applicable legal acts. 

     

    You can exercise some of your rights yourself in the App or on your mobile device:

    • change your consents / permissions in the App;
    • change settings, options in the operating system settings of the mobile device;
    • get acquainted with Order history using the App;
    • submit your questions, complaints, requests, opinion.

     

    You may terminate your use of the App at any time by deleting the App from your mobile device. In this case, we will stop collecting data related to your use of the App. However, we will also be forced to terminate the Agreement.

     

    HOW TO CONTACT US

     

    You can contact us with any data processing questions following ways:

     

    FINAL PROVISIONS

     

    If we change this Policy, we will post an updated and current version of it on the App, Google Play Store and App Store and, if necessary, notify you of the changes in other ways.