DATA USAGE MANAGER - PRIVACY POLICY
[Last Updated: November 2, 2021]
INTRODUCTION
This privacy policy ("Privacy Policy") governs the data collection practices used by Flavr Technology LP
(“Company”, “we” or “us”) in relation to your (“you” or “user”) use of our Data Usage Manager mobile
app, which analyzes and keeps track of how much data the various apps installed on your device use, or our
website (collectively, the "Mobile App”).
This Privacy Policy explains how we collect, share and use our users’ data. It is an integrated part of our
Terms of Service (the “Terms of Service”) and, to the extent that the processing of personal data is based
on consent (see below), is a legally binding agreement between you and the Company. Definitions herein
shall have the same meaning as defined in the Terms of Use.
ACCEPTANCE OF THE TERMS: BY USING THE MOBILE APP OR OUR SERVICES YOU HEREBY ACKNOWLEDGE
AND, WHERE THE PROCESSING OF PERSONAL DATA IS BASED ON CONSENT (SEE BELOW), AGREE TO THIS
PRIVACY POLICY. IF YOU OBJECT TO THESE TERMS, PLEASE DO NOT ACCESS, DOWNLOAD OR USE THE
MOBILE APP OR SERVICES.
AGE LIMITATION
You represent and warrant that you are at least 13 years of age and of legal competence to enter into these
terms. If we become aware that a user under the age of 13 has shared any information with us, we will
discard such information. If you have any reason to believe that a child under the age of 13 has shared any
information with us, please contact our Data Protection Officer at: dpo@flavrtech.co. If you are under the
age of 18, please be sure to read the Terms of Service including this Privacy Policy with your parents or legal
guardians.
WHAT TYPE OF INFORMATION DO WE COLLECT?
The first type of information we collect is non-identifiable information pertaining to a user, which may be
made available or gathered via the user’s use of the Mobile App (“Non-Personal Information”). We are not
aware of the identity of and cannot determine the user from whom the Non-Personal Information was
collected.
Non-Personal Information which we collect may include your aggregated usage information and technical
information transmitted by your device, including: (i) certain software and hardware information, such as:
type of device and operating system; (ii) Mobile App session ID, the time and date you access the Mobile
App;; (iii) information about installed apps, such as name, installation and update date, and version of the
Mobile App; (iv) the Internet Protocol (IP) address associated with the communication between your device
and our network server, which we store in hashed (encrypted) form, with the last class permanently
deleted before storing it, in order to retain only general (e.g., country and city) location; and (v) GUID,
which is a random number generated on your device and used to distinguish between different users, and
which we irreversibly encrypt so that it cannot be used to identify you. We consider GUID and IP address as
Non-Personal Information, as we process it only in an encrypted manner.
Furthermore, in order to provide our services, we may request access to certain Android permissions
(“Permissions”), such as App Usage and Storage. We use the information obtained through the Permissions
for the purpose of providing our services, and specifically to monitor your mobile data usage and display
the analysis on your home screen and within the Mobile App. To access these Permissions, you will need to
actively enable them through your mobile device settings. You can disable the Permissions at any time
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through your mobile device settings or Mobile App settings, but note that depending on the Permission you
disable, a feature or all features might not properly operate.
The second type of information we may collect when you install or otherwise use the Mobile App is
individually identifiable information, namely information that identifies an individual or may with
reasonable effort identify an individual (“Personal Information”). The Personal Information we collect on or
through the Mobile App includes contact information, such as your name, telephone number, address,
email, etc., which you might provide us if you voluntarily contact us. We will use this information solely to
respond to your requests and support your needs.
HOW DO WE COLLECT AND USE YOUR INFORMATION?
We collect your information once you access, register or use the Mobile App. We will use the information
to provide you with our service, and deliver, manage and improve our Mobile App and service. We can also
use your information based on our legitimate interests in promoting and improving our services and
products, on the necessity of such information for the provision of the services where applicable (as
described in this Privacy Policy) or, where permitted under applicable law, on the implied consent that you
provide by using the Mobile App, or by requesting support or registering for our service. We also use Non-
Personal Information, aggregated information or statistics regarding user browsing behavior as a measure
of interest in, and use of, the Mobile App in the form of aggregated data, such as overall patterns or
demographic reports, which do not describe or identify any individual user.
HOW DO WE SHARE THE INFORMATION, AND FOR WHAT PURPOSE?
We do not share any Personal Information collected from you with third parties or any of our partners
except in the following circumstances: (i) we will share your information, solely to the extent needed to
comply with any applicable law, regulation, legal process or governmental request or to enforce our
policies (including our policies and agreements) including investigations of potential violations thereof or to
detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security
issues; (ii) we will share your information, solely to the extent needed to establish or exercise our rights to
defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or
any third party or for the purpose of collaborating with law enforcement agencies or in case we find it
necessary in order to enforce intellectual property or other legal rights.
The Non-Personal Information we collect may be shared in any of the above circumstances, as well as
(i) for the purpose of providing and improving our Mobile App and services; or
(ii) internally within the Company to conduct business and marketing analysis, and enhance your
experience; or
(iii) with our Affiliated Companies (as defined below) as part of their aggregated data analysis services.
If we combine Personal Information with Non-Personal Information, the combined information
will be treated as Personal Information for as long as it remains combined.
In addition, we may share your Non-Personal Information with our parent company, any subsidiaries,
affiliates, joint ventures, or other companies under common control (collectively "Affiliated Companies")
solely if and when applicable or necessary for the purposes described in this Privacy Policy. We may share
Information, including Personal Information, in the event of a corporate transaction (e.g. sale of a
substantial part of our business, merger, consolidation or asset sale). In the event of the above, our
Affiliated Companies or acquiring company will assume the rights and obligations as described in this
Privacy Policy.
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Note that we may also appoint third-party service providers, operating under our instructions, who may
need access to your Information in connection with their services on our behalf. Transfers of your Personal
Information will be made in accordance with applicable data protection laws and regulations.
We will take the steps necessary to ensure that international transfers of personal data (including Personal
Information) meet all requirements under applicable data protection laws. When personal data collected
within the European Economic Area ("EEA") is transferred outside the EEA (including but not limited to the
interaction with our US-based servers), we will take the steps necessary to ensure that the transfer of such
data provides sufficient safeguards, and you may exercise your rights, where applicable, to receive
information on such transfer mechanism.
USE OF COOKIES AND THIRD PARTY TOOLS
When you access or use our website, we may use industry-wide technologies such as "cookies" (or similar
technologies), which store certain information on your computer (i.e., locally stored) and which allow us to
customize our service and content as well as enhance your experience. We may also use third party tools
such as Google Analytics. To learn more how Google uses data from our use of Google Analytics Cookie we
recommend you review Google’s policies located at: www.google.com/policies/privacy/partners. We also
encourage you to review the Google Analytics' currently available opt-outs for the web tool available at:
https://tools.google.com/dlpage/gaoptout/.
OPT-OUT RIGHT
You may opt out of the automatic collection and sharing of Non-Personal Information related to our Mobile
App and service, by uninstalling the Mobile App from your device. You may also contact our Data
Protection Officer at: dpo@flavrtech.co and we will be happy to assist you.
After you opt out, we will no longer automatically collect and share your Non-Personal Information as
described in this Privacy Policy in connection with your use of the Mobile App or services. Note that once
you opt out, part of the service provided by us might no longer be available.
USER RIGHTS
Unless you instruct us otherwise, we retain the information we collect for as long as necessary to provide
the services described herein and to comply with our legal obligations, resolve disputes and enforce our
agreements. If you object to such collection, use and sharing of data, please cease using the Mobile App
immediately and remove the Mobile App from your device. The data we receive in the event you access the
Mobile App via a third-party social or other network depends on your privacy settings with such network
(i.e., Gmail, Yahoo). You should always review, and if necessary, adjust your privacy settings on third-party
websites and services before linking or connecting them to our Mobile App.
Where provided under applicable law (e.g., within the European Union), you may have the right to ask us to
delete Personal Information which you have provided to us, subject to applicable exceptions, such as in
order to preserve that information for anticipated litigation or demands from a regulator, or some or all of
the following rights: the right to obtain information on our use of your Personal Information, the right to
obtain a copy thereof, the right to data portability, the right of data rectification, the right to object to
processing based on our legitimate interests, the right to restriction of the processing, and the right to
withdraw your consent.
In order to assert any of these rights, please contact our data protection officer at: dpo@flavrtech.co.
Note that we may request proof of your identity, and we reserve the right to charge a fee where allowed by
law, such as in circumstances where your request is deemed to be excessive.
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In addition, you may have the right to lodge a complaint with a supervisory authority, subject to applicable
law (as is the case in the European Union).
CALIFORNIA CONSUMER PRIVACY ACT
Consumers in the State of California, United States are granted certain rights related to Personal
Information under the California Consumer Privacy Act (the “CCPA”).
The type of Personal Information collected, how it is used, and from where/whom it is collected is detailed
elsewhere in this Privacy Policy. This collection use and/or disclosure may vary depending on the nature of
your relationship and interactions with us.
The CCPA grants California consumers the following rights:
to request a description of the categories of Personal Information collected and under what
circumstances it is sold or otherwise disclosed.
to opt out of the sale of the Personal Information collected. The term “sale” is broadly defined in
the CCPA, and as such certain activities, such as receiving any type of consideration for data, may
constitute a “sale.” In some circumstances, sharing Personal Information with ad tech or third-
party analytics firms for our marketing purposes may be a “sale” under the CCPA. We will not sell
or share Personal Information except as provided in this Privacy Policy.
Subject to certain exceptions, California consumers may also request the following:
o That we delete the Personal Information we collected in the past 12 months;
o That we provide copy of the Personal Information we collected in the past 12 months;
and/or
o That we provide a description of the sources/categories of Personal Information collected,
the purpose for collection, how the information is handled, and with whom it was shared
with and for what purpose.
Requests under the CCPA described above can be made at no cost to the consumer. Requests can only
relate to Personal Information collected in the prior 12 months. Up to two (2) requests can be made in any
12-month period.
Only you or a representative authorized and registered with the California Secretary of State to act on your
behalf may make a CCPA request. Requests must be sent by e-mail to dpo@flavrtech.co.
We must verify your identity and that you have the authority to make the request before we can respond,
beginning with matching the information in the request with information in our files. As a result, while we
will attempt to limit the additional information required in a CCPA request, we need sufficient personal
details to verify your request. At a minimum, we must confirm to a reasonable degree of certainty you are
the person about whom the request relates (or are that person’s duly-authorized representative), and we
must have sufficient details about what you are requesting to allow us to understand and respond.
Without sufficient information, we may need to decline your request.
If we can verify a request, we will make efforts to respond within 45 days. If we need more than 45 days
(up to 90 days), we will inform you in writing, including the reason(s) we need more time.
The exercise of your CCPA rights will not result in any discrimination against you. We will not charge you
more or give you lower-quality goods and services and we will not deny you goods or services as a result of
you exercising your CCPA rights.
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CALIFORNIA SHINE THE LIGHT LAW
California consumers who do business with us have additional rights under California's "Shine the Light" law
(Civil Code Section §1798.83). These include the right to inquire about your Personal Information we
provide to third parties for their direct marketing purposes. Such requests apply only to disclosures made
in the prior calendar year and may not be made more than once in any calendar year. Requests under the
California Shines the Light law must be sent to dpo@flavrtech.co.
We reserve the right to not respond to requests (made under either the CCPA or Shine the Light law) not
submitted by email to dpo@flavrtech.co.
HOW DO WE SAFEGUARD YOUR INFORMATION?
We take great care in implementing and maintaining the security of the Mobile App and your information.
We employ industry standard procedures and policies to ensure the safety of our users’ information, and
prevent unauthorized use of any such information. Although we take reasonable steps to safeguard
information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our
Mobile App, and we make no warranty, express, implied or otherwise, that we will prevent such access. We
may adopt what we believe is appropriate data collection, storage and processing practices and security
measures to protect against unauthorized access to such data.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to
abuse our Mobile App or acted in an inappropriate manner, please contact our Data Protection Officer
directly at dpo@flavrtech.co.
AMENDMENTS
We reserve the right to periodically update or revise this Privacy Policy at our sole discretion; such changes
will be effective immediately upon the display of the revised Privacy Policy. Thus, we encourage you to
check this Privacy Policy regularly for updates, so that you are fully informed of how your data is collected
and used by the Company and your related rights. The last revision date will be reflected in the "Last
Updated" heading. Your continued use of the Mobile App or our services following the display of such
revised privacy policy constitutes your acknowledgement of such amendments to the Privacy Policy and,
where the processing of personal data is based on consent, your agreement to be bound by the terms
therein. In the event of a material change that will substantially affect your use of the Mobile App or service
or the data collection by us, we will endeavor to provide you with notifications through the Mobile App or
by email.
CONTACT US
If you have any general questions about the Mobile App or the information that we collect about you and
how we use it, please contact us at: dpo@flavrtech.co.
