MyVikki Digital SL · Spain
Contents
This Policy is intended to help you understand:
MyVikki is located in Spain.
This Privacy Policy (“Policy”) describes how MyVikki App (“we”, “us”, “our”) may collect, use, and share information obtained when you use MyVikki App (the “App”), our website https://myvikki.com/ (the “Website”), interact with us via our social media such as Facebook, Instagram, Telegram (“social media”), and messengers, or provide us with information about yourself via any other way. Such treatment may include, but is not limited to, the following:
You can be our visitor or client:
When you submit your personal data to us, you may be asked to consent to our processing of the personal data you provide as explained in this Policy to enable us to provide you with the information requested, if no other legal ground can be used.
To facilitate your understanding of this Policy, we explain the usage of the definitions listed here in accordance with the GDPR.
We use the following definitions in this Policy:
“data controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data is processed.
“data processor” means the natural or legal person who processes personal data on behalf of the data controller.
“data subject” is any individual that provides their personal data to us when using App, interacting with Company's social media, messengers, or provide their personal data to us in via any other.
“personal data” means any information relating to you and helping identify you (directly or indirectly) such as your name, last name, email, location data, etc.
“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
In this section, you can learn more about what personal data may be collected.
We collect two basic types of information about you in connection with our services: client data, visitor data, which relate to Clients and Visitors respectively. In particular, we collect:
(a) Contact Information. We can collect some personal data when you submit your personal data via the Website’s forms, social media, messengers, email to contact and/or provide feedback on our App. Such data may include name, email, and other information you may provide us via available contact options.
(b) Registration Information. When you create an account on the App, we collect the following required information about you: email address. You must enter the above information yourself to create an account unless we receive such information about you from the third-party authentication token when you choose to sign up using the respective button.
(c) Authentication Token Information. When you create an account in the App through the respective ‘Sign In with…’ button, we collect an encrypted authentication token obtained from the selected service provider. We can obtain the following information about you via such a token: email address.
(d) Integrations API Information: Clients’ API tokens, which are necessary to integrate your account (giving our App access to a third-party App API) with other third-party services such as social networks, email marketing, payment systems, telephony, banks, etc.
(e) Automatically Collected Information. When you use our App, we collect certain information about you and your device automatically, including user behaviour and conversions.
(f) Geolocation data, such as the general area from which your device accesses our App based on information like its IP address, or precise location information you choose to provide.
(g) Audio information, such as voice. If you opt to sent us a voice messages.
(h) Payment Information. If you order services from us, you will need to provide certain personal details, including name and email address, so the order can be fulfilled. If the payment is made on the behalf of a legal entity, we also may collect some information about such a legal entity. In order to obtain payment from you, we will use or direct you to a separate payment provider who will collect financial information from you and process your payment. Please, read the privacy policy of a separate payment provider before making a payment to us, as that separate payment provider is collecting, processing, and storing your financial information and we do not have direct access to or possession of your payment card information or banking information.
(i) Client’s Information. As part of our services, we can process third-party personal data that has been provided to us by our Clients. In this case, we process such personal data (which may relate to customers, prospects, employees, contractors of Clients) under instructions provided by the respective Client.
We use the personal data we collected and the personal data you provided us with or requested us to collect only for the purposes listed in this Policy. We may share your personal data with third parties solely for the purposes listed herein.
When we act as a data controller, We DO NOT intentionally collect and process any sensitive personal data. Please, refrain from sharing your or third-party sensitive personal data with us.
We DO NOT sell your data.
Our grounds for processing your personal data are:
We do NOT intentionally collect and process sensitive personal information. Please, refrain from sharing your sensitive personal data when you provide information to us through App, or our social media accounts.
We collect and process your personal data in accordance with the provisions of the GDPR.
GDPR provides an exclusive list of lawful bases allowing us to process your personal data. During personal data processing we rely only on four of them, namely:
Article 6.1(a): consent
We collect the information you choose to give us, and we process it under your consent. You may withdraw your consent to the processing of your personal data at any time.
Please remember that the withdrawal of consent does NOT automatically mean that the processing before the withdrawal is considered unlawful. You may withdraw the consent to the processing of your personal data by sending us an email at app@myvikki.com, or by contacting us in any other way convenient for you.
Article 6.1(f): legitimate interests
As a data controller, we process your personal data to prevent any fraudulent actions and to provide you with the desired services. Also, we need some data to enable our App to run smoothly and give you a pleasant user experience. We use only strictly necessary data under this legal ground.
Article 6.1(b): performance of a contract
When you provide us with the personal data during the registration of the account on the App; this can be deemed as your request to form a contract or to perform a contract between you and us. However, we may ask you to give us clear consent in case of doubt.
Article 6.1(c): legal obligation
We process your personal data to fulfil the applicable legal obligations arising mainly from the GDPR. In the event of you sending us the request to fulfil the rights granted by the GDPR, we may ask you for some personal data we already have to identify you and achieve compliance with the applicable law.
As a data controller, we use your personal data for the purposes listed in the table below where we also detail the type of personal data processed, legal bases we rely on to do so, third parties with whom we may share your personal data:
Registration Information, Authentication Token Information: Purposes - Creating an account in the App; Legal grounds - Performance of a contract (Article 6(1)(b)); Third Parties recipients - PLATMA, Contractors.
Registration Information, Authentication Token Information: Purposes - Maintenance of the account in the App; Legal grounds - Performance of a contract (Article 6(1)(b)); Third Parties recipients - PLATMA, Contractors.
Contact Information, Registration Information, Authentication Token Information: Purposes - Communication with visitors and customers; Legal grounds - Your consent (Article 6(1)(a)), Our legitimate interest (Article 6(1)(f)); Third Parties recipients - PLATMA, Contractors.
Communication with visitors and customers: Purposes - Audio information, such as voice; Legal grounds - Your consent (Article 6(1)(a)); Third Parties recipients - ChatGPT, Contractors.
Contact Information, Registration Information, Authentication Token Information, Geolocation data: Purposes - Marketing (informational messages about our App, promotions, events (webinars, seminars, consultations, master classes, etc.) and any marketing activities of our App and conduct other marketing activities, such as personalised advertising; Legal grounds - Your consent (Article 6(1)(a)), Our legitimate interest (Article 6(1)(f)); Third Parties recipients - PLATMA, Contractors.
Contact Information, Automatically Collected Information, Geolocation data: Purposes - Analytics and developing (for optimising and improving our App); Legal grounds - Your consent (Article 6(1)(a)), Our legitimate interest (Article 6(1)(f)); Third Parties recipients - Contractors.
Payment Information: Purposes - Processing of Payments; Legal grounds - Performance of a contract (Article 6(1)(b)); Third Parties recipients - App store, Apple Pay, Google Play, Visa, Mastercard, Contractors.
Contact Information, Registration Information, Authentication Token Information, Integrations API Information, Automatically Collected Information, Geolocation data, Payment Information: Purposes - Complying with the law or legal process; Legal grounds - Legal obligation (Article 6(1)(c)); Third Parties recipients - PLATMA, Contractors.
We will store and process your personal data for as long as needed to provide you or other customers with the services. Also, you may request erasing of your personal data by contacting us in any way convenient for you.
As a data controller, we store and process your personal data until we do not need it for any of the purposes defined in this Policy unless longer storage is required or expressly permitted by law.
Usually, we retain your data while your account is actively used, but we will delete your personal data if we notice that you have not used your account for a long time or if you ask us to delete your personal data.
We may not delete or anonymize your data if we are compelled to keep it to comply with the law or legal process.
Despite any of the aforementioned periods of data storage, you may request to delete your personal data by sending us an email at app@myvikki.com or contacting us via another way convenient for you.
If your account on the App is inactive (you do not access App and/or do not use our services) for 1 (one) year, the personal data is to be deleted.
We have implemented appropriate organisational, technical, administrative, and physical security measures that are designed to protect your personal data from unauthorised access, disclosure, use, and modification. We regularly review our security procedures and policies to consider appropriate new technology and methods.
We only transfer your personal data to third parties according to the requirements of GDPR.
We may share your personal data as a data controller to data processors in accordance with provisions specified hereafter.
There are many features necessary to provide you with access to our App that we cannot complete ourselves, thus we seek help from third parties. We may grant some service providers access to your personal data, in whole or in part, to provide the necessary services.
Therefore, we may share and disclose your personal data to other data processors:
During our business activities we may engage different specialists which may receive your personal data, including technical, sales and marketing specialists, to provide you with better customer service. Also, we may disclose some of your personal data to our outsource legal and accounting professionals to make our business accurate and transparent. The abovementioned specialists are collectively referred to as Contractors.
We may transfer your personal data to countries outside the EU and EEA (for example, the USA) that are not determined to offer an adequate level of data protection on the basis of article 45 of GDPR (adequacy decision) with appropriate safeguards as determined under the GDPR.
We only transfer your personal data to third parties within requirements under the GDPR. Where possible and necessary, we always enter into Data Processing Agreements (DPAs) and Non-Disclosure Agreements (NDAs) with them and treat personal data transfer seriously. Where the Contractor has an appropriate data processing agreement in place, Company may adjoin such data processing agreement. If so, Company and the Contractor may regulate the transfer of the personal data to such Contractor by means of this data processing agreement.
We may transfer your personal data to third countries outside the EU and the EEA under Article 46 of the GDPR on the appropriate safeguards, including the standard contractual clauses (SCC).
For transfers to countries that do not fall under requirements of Article 45 of the GDPR on the adequacy of the level of protection, we may transfer your personal data to the third countries outside the EU and the EEA, including the onward transfers of the personal data from the third countries to another third countries, under Article 46 of the GDPR with the appropriate safeguards, including the SCC.
We disclose your personal data to the countries outside the EU and the EEA, in compliance with our internal procedures regarding international transfers in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of natural and legal persons.
We put supplementary technical and organisational measures in place when transferring data outside the EU and the EEA. e.g. prior assessment of the service supplier’s reliability and personal data protection practices, encryption of the transferred personal data, prompt reacting to any threats to confidentiality, integrity and availability of the personal data, conducting transfer impact assessments (TIA) when necessary, etc.
You may exercise the following rights under the General Data Protection Act (GDPR):
You may exercise the following rights by submitting your request at app@myvikki.com.
When we act as a joint controller regarding particular processing of personal data, you may exercise your rights under the GDPR in respect of and against both other joint controller(s) and us.
You may submit the complaint to the supervisory authority of your place of residence within the EU or to the data protection authority stated in this Policy.
We kindly ask you to contact us directly so that we can quickly answer your question.
We kindly invite you to share your concerns with us in the first place regarding any issue related to your personal data processing. You may contact us to address your inquiries: app@myvikki.com.
Supervisory Authorities under GDPR:
In case of any questions regarding data protection, you can apply to the supervisory authority in your place of residence or domicile. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.
Our App is intended for adults aged 18 and over.
If you are under 18, please do not provide any personal information on our App.
By registering on the App and entering into the contract with us, you are telling us that you acknowledge that you have reached the age of 18 and under the laws of your country of residence you have all rights to provide us with your personal data for processing.
Where you are under 18, we need the consent of your parent (or another holder of parental responsibility, legal guardian) to allow you to use our App.
If you have any reason to believe that a person under the age of 18 has provided his/her personal data to us, please contact us. Please consider applicable laws and regulations regarding the protection of children if you pass children’s personal information to us via the App.
We may change this policy from time to time due to the different purposes. We will notify you on such material changes through means available to us. Please contact us if you have any questions about our processing activities, this Privacy Policy, or your rights.
This Policy may be changed from time to time due to the implementation of new updates, technologies, laws’ requirements or for other purposes. We will send notice to you if these changes are dramatic and where required by applicable laws, we will obtain your consent for the subsequent processing. In any case, we encourage you to regularly review this Policy to check for any changes.
Such notification may be provided via email, announcement and by other means, consistent with applicable law.
If you have a question related to this Privacy Policy, our processing activities, or your data subject rights under GDPR and other applicable laws, you can contact us directly using the following details: