Privacy Policy

Your and your child’s privacy is of the utmost importance to us. In this privacy policy, we explain in detail how we collect, use, and disclose personal data. We also inform you about the choices that you have with respect to your personal data.

Please read this privacy policy carefully before submitting any personal data to us.

GENERAL INFORMATION

In this section, we provide you with general information about us, MYPAX, and this Privacy Policy.

1.1 About the Privacy Policy. This MYPAX privacy policy (the “Privacy Policy”) governs the processing of personal data collected from individual users (“you” and “your”) through the mobile application MYPAX (the “App”) and the website http://webflowcodes.com/mypax (the “Website”) (collectively, “MYPAX”). The Privacy Policy does not cover any third-party websites, applications or software that integrate with MYPAX or any other third-party products and services; such websites, applications, and software are governed by their respective privacy policies.

1.2 Data controller. MYPAX is owned and operated by MYPAX Ltd. having a business address at 495 Green Lanes, Palmers Green, London N13 4BS, United Kingdom (“we,” “us,” and “our”).

1.3 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.4 Amendments. This Privacy Policy can be changed from time to time to address the changes in our business practices, the functionalities of MYPAX, laws, regulations, and industry standards. The amended version of the Privacy Policy will be posted on this page and, if we have your email address, we will send you a notice about all the changes implemented by us. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

WHAT DATA DO WE COLLECT?

In this section, we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use MYPAX, and how we communicate with you.

2.1 Sources of personal data. We obtain your personal data from the following categories of sources:

Directly from you. For example, if you submit your personal data when you register your user account or contact us;

Through your child’s activity on MYPAX. When your child uses MYPAX, we automatically monitor your child’s messages in order to provide you our services, namely, to inform you of the conversations containing the words in your word flag library. Please note that we do not intentionally access your child’s messages or intervene in his/her communication with others; and

From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us (for example, for payment processing purposes).

2.2 Monitoring of your child’s conversations. Your child’s messages and all information transmitted through the App (the “Messages”) will remain confidential at all times. All monitoring of the Messages is conducted automatically for the sole purpose of notifying you about Messages containing information that you specify. This means that we employ technology that scans the Messages without intervening in them. We do not access, examine the Messages, or disclose the content of the Messages to others. We will inform you of the Messages that contain flagged words only. You can manage your word flag library easily to set privacy settings that you are comfortable with. Where the Messages contain personal data, we process such personal data only to comply with our contractual obligations to you.

2.3 Collection of personal data. We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of MYPAX. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. For example, we use it only for the purposes of ensuring the functioning of the App, maintaining and improving MYPAX, replying to your enquiries, and pursuing our legitimate interests. We do not repurpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.

Registration for beta. When you register for beta on the Website, we collect your first name, last name, and email address. We use the said information to inform you about the launch of the App and contact you, if necessary. The legal basis on which we rely is ‘your consent’. We will store this data until the App is launched.

Your account. When you register your account on the App, we collect your first name, last name, email address, phone number, and password. We use the said information to register and maintain your user account, enable you to access and use the App, contact you, if necessary, ensure security of the App, and maintain our business records. The legal bases on which we rely are ‘performing a contract’ and ’pursuing our legitimate interests’ (i.e., operate, analyse, grow, and protect the App, and administer our business). We will store this data until your user account is deleted, unless we are required by law to keep some records longer.

Your child’s personal data. When you add a child on the App, we ask you to provide your child’s name, date of birth, phone number or email address. When your child adds a friend, we collect the friend’s phone number. We use such information to send a code to the child and enable the child’s access to the App. The legal basis on which we rely is ‘performing a contract.’ We will store this data until your child’s account is deleted. We do not ask your child to provide any personal data without your consent.

Enquiries. When you contact us by email or through the contact form available on the Website, we collect your first name, last name, email address, and any information that you decide to include in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to grow and promote MYPAX) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us.

Payments. When you make a payment on the App, our third-party payment processors collect your personal data, such as your full name, billing address, payment details (e.g., credit card number, CVV code, expiration month and year). Your payment data is used to process payments and maintain our accounting records. The legal bases on which we rely are ‘performing a contract’ and ‘pursuing our legitimate interests’ (i.e., to administer and protect our business). We store such data for the time period prescribed by law.

2.4 Access to the contacts on your phone. If you grant us your permission, MYPAX will read your phone address book to determine who has a MYPAX account so you can add those contacts to your MYPAX friends list. Please note that this feature is optional. If you do not want MYPAX to access your address book, simply decline such request. If MYPAX determines that some of your contacts do not use MYPAX, we will ensure their privacy, i.e., we will not further process such contacts’ personal data; i.e., we will de-identify the names and phone numbers of those contacts or delete them from our systems. We do not share information about your contacts with any third parties.

2.5 Cookies. When you browse the Website, we may send essential cookies to your browser. Such cookies may be necessary to ensure the proper functioning of the Website, prevent fraud and abuse, and ensure the security of the Website. The legal basis on which we would rely is ‘pursuing our legitimate interests’ (i.e., provide and protect the Website). Such cookies do not track you or use your data for marketing purposes. So, they do not require your consent.

2.6 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.

2.7 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of MYPAX, receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

2.8 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).

2.9 Aggregate and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregate data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.

2.10 Newsletters. If you opt-in for our newsletter, subscribe to our newsletter, or conclude a service contract with us, we will inform you about our new services, features of MYPAX, and special offers. The legal bases on which we rely is ‘your consent’ (if you opt-in) and ‘pursuing our legitimate business interests’ (i.e., promote MYPAX). You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.

2.11 Transactional notices. If we have your email address and it is necessary to do so, we may send you important informational messages, such as order confirmations, payment receipts, information about your child’s messages, and other technical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

HOW LONG DO WE STORE YOUR DATA?

In this section, we explain for how long we keep your data in our systems and how we delete it.

3.1 Storage of personal data. We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2.2. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than strictly necessary.

3.2 Storage of non-personal data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include storing non-personal data for the period of time needed for us to examine our activities, fulfil our contractual obligations, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

3.3 Storage as required by law. When we are obliged by law to store your personal data for a certain period of time (e.g., for keeping accounting records), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.

HOW DO WE DISCLOSE YOUR DATA?

In this section, you can find information about third parties that may have access to your personal data.

4.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:

Ensuring the proper operation of MYPAX;
Delivering you the requested services;
Processing your payments;
Responding to your enquiries;
Pursuing our legitimate interests;
Enforcing our rights, preventing fraud, and security purposes;
Carrying out our contractual obligations;
Law enforcement purposes; or
If you provide your prior consent to such a disclosure.

4.2 List of data processors. We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are:

Our web hosting service provider Hetzner located in Finland;
Our newsletter service provider MailChimp located in the United States;
Our authentication service provider Twilio located in the United States;
Our payment service providers Apple and Stripe located in the United States; and
Our independent contractors and consultants.

4.3 International transfers. Some of our data processors may be based outside the country where you reside. For example, if you reside in the UK or a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the UK or the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved Standard Contractual Clauses).

4.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving MYPAX, responding to lawful requests from public authorities or developing new products and services.

4.5 Legal requests. If requested by a public authority, we will disclose information about the users of MYPAX to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

4.6 Sharing of your phone contacts information. If you allow MYPAX to access your address book in order to add these contacts to your MYPAX friends list, we will access those contacts’ phone numbers and names in order to provide you with such a service. We do not share your contacts’ personal data with third parties. Nevertheless, such personal data may be stored in our servers, databases, and the related software that facilitates MYPAX (e.g., ChitChats app) until you stop using MYPAX. We remain the sole data controller with regard to such personal data and, therefore, we do not re-purpose your contacts’ personal data.

HOW DO WE PROTECT YOUR DATA?

Here you can find information on how we protect your data against breaches.

5.1 Security measures. We implement technical and organisational information security measures that protect your personal data from loss, misuse, unauthorised access and disclosure. The security measures taken by us include encryption, proper authentication, secured networks, multi level tokens and keys, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), and carefully selected data processors.

5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

HOW CAN YOU MANAGE YOUR PERSONAL DATA?

Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.

6.1 The list of your rights. You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:

Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;

Right to rectification: you can rectify inaccurate personal data that we hold about you;

Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;

Right to restriction: you can ask us to restrict the processing of your personal data;

Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;

Right to object: you can ask us to stop processing your personal data;

Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or

Right to complaint: you can submit your complaint regarding our processing of your personal data.

6.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of the Privacy Policy and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

CONTACT

If you have any questions about this Privacy Policy, your rights, or our data protection practices, please contact us by using the following contact details:

Email: [email protected]

Postal address: MYPAX Ltd., 495 Green Lanes, Palmers Green, London N13 4BS, United Kingdom