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millo app privacy policy

Effective date: 2020-03-18

PRIVACY POLICY

INTRODUCTION

UAB „Millo Appliances“, legal entity code 303331122, address of registered office M. Mažvydo st. 12-33, Vilnius (“Millo”, “us”, “we”, or “our”), operates Mobile App Millo (hereinafter referred to as “MilloApp”).

This Privacy Policy governs your use of MilloApp, and explains how we collect, safeguard and disclose information that results from your use of our services, provided to you by us via MilloApp. By using MilloApp, you accept and agree to follow these privacy terms and conditions.

We collect your data with due care and only for hereby established legitimate purposes, having for that a legal ground. We are acting in accordance with the applicable requirements established by the General Data Protection Regulation (GDPR), also other legal acts on privacy and data protection.

Our Terms and Conditions (“Terms”) govern your use of MilloApp and together with this Privacy Policy constitutes your agreement with us (“agreement”).

DEFINITIONS

Services means the services provided to you by us via MilloApp, enabling you to control your Millo devices and products from your smartphone, to customize, save and share your blending patterns, also to receive regular updates to make your smart Millo devices and products even smarter.

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data is data collected automatically either generated by the use MilloApp and Services herein or from Service infrastructure itself.

Data Controller means a 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 are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject is any living individual who is the subject of Personal Data.

The User is the individual using MilloApp and our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

INFORMATION COLLECTION AND USE

We collect and use your data to provide you with and to improve MilloApp and our Services, also to provide you with efficient support while you use your Millo devices and products.

Types of Data Collected

Personal Data

At the moment, there is no need to register on MilloApp to be able use it, hence typically we do not collect any personally identifiable information and Personal Data of the Users of MilloApp. Also, we do not normally use technical, usage and tracing data available to us to identify you, however you can sometimes be recognized from it. In such situations, technical, usage and tracing data can also be considered Personal Data under applicable laws.

If you address our support team and provide your e-mail address in the support request, we would afterwards process your e-mail address for contacting you with support related information.

Usage Data

We may also collect information that your mobile device discloses whenever you use MilloApp and our Service (“Usage Data”).

Usage Data that is available to us may include information such as the type of device you use, your device operating system, unique device identifiers and other diagnostic data.

After you connect your Millo device with MilloApp via Bluetooth, we would receive and process information about your Millo device that you are using, namely manufacturer, model, unique serial number, UUIP number, application version, Bluetooth config version, firmware version, Bluetooth firmware version, main PCB revision, UI PCB revision, Bluetooth hardware revision.

If you address our support team, Millo device’s unique serial number along with other above described Usage Data would be visible to our support team. We do not normally use it to identify you, however such theoretical possibility exists, especially if you add your e-mail address to the support request.

Tracking Data

We use Firebase Analytics and Firebase Crashlytics tracking technologies, provided by Google Inc., that automatically collects and provides us with some statistical Users’ properties. Please check for more information:

https://firebase.google.com/docs/analytics/?gclid=CjwKCAjwsMzzBRACEiwAx4lLGzP_4IN86OK5SXlvC7HVOIQHbUduAMfNoLQuwV-HgwTKz8Lgv86FPxoCCK4QAvD_BwE.

https://firebase.google.com/docs/crashlytics/?gclid=CjwKCAjwsMzzBRACEiwAx4lLG_aUf_FKpzAqHOGQ1cBnaVx7y_CwXqowLX_BNXufJNBaTfcpF1CaiBoC3AUQAvD_BwE.

This data does not allow us to identify you.

USE OF DATA

Millo uses the collected data for various purposes:

- to provide and maintain our Service;

- to allow you to participate in interactive features of our Service when you choose to do so;

- to provide customer support;

- to gather analysis or valuable information so that we can improve our Service;

- to monitor the usage of our Service;

- to detect, prevent and address technical issues;

- to fulfil any other purpose for which you provide it.

We obtain and collect your data on a legal basis - the necessity to perform contract / enter into a contract - for enabling you to use MilloApp and the Services herein. We also may collect your data due to your consent that you have given to us in advance (e. g., when you address our support team and provide them with your e-mail address) or due to our legitimate interest in our operations as a legal entity (e.g., we may process some data for administrative purposes / to analyze and improve our services, develop new features of MilloApp, to secure our products and/or to improve hereof).

RETENTION OF DATA

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Personal Data processed by us in course of the customer support procedures is stored for not longer than 10 (years) after resolving the relevant support request.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

DISCLOSURE OF DATA

We may disclose data that we collect or you provide:

Disclosure for Law Enforcement: under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

Business Transaction: if we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

We may also disclose your information: to our subsidiaries and affiliates, to contractors, service providers, and other third parties we use to support our business and that process your data on our behalf; these third parties have access to your data only to perform the tasks on our behalf and are obligated not to disclose or use it for any other purpose.

SECURITY OF DATA

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.

YOUR RIGHTS

With the limitations provided for by the applicable laws, you have such rights:

  • To be informed if we maintain your Personal Data;
  • To ask for access to your personal data (commonly known as the “data subject request”). This enables you to receive a copy of your Personal Data that we maintain and check whether we process it legally;
  • To ask for the correction of your Personal Data we maintain. This enables you to correct any incomplete or inaccurate information of your data;
  • To ask for the deletion of your personal information. This enables you to ask us to delete or remove Personal Data where there is no reason to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have exercised the right to object to their processing (see below);
  • To request the transfer of your Personal Data to you or another party (commonly known as the “data portability” right) in an electronic and structured format. This allows you to receive your data from us in an electronically usable form and you can transfer your data to another party in an electronically usable form;
  • Withdrawal of consent. In the limited circumstances where you may have given your consent to the collection, processing and transfer of your personal data for a particular purpose, you have the right to withdraw your consent to such processing at any time. Once we receive the notice that you have withdrawn your consent, we will cease processing your information for the purpose or purposes for which you originally agreed, unless we have another legal basis to do so legally.

If you have any questions or concerns regarding the processing of your personal data or if you wish to exercise your rights under this Privacy Policy, you may contact us via hello@getmillo.com or phone +37065944844.

You also have the right to submit a complaint to the competent data protection authority (please find more information here: https://vdai.lrv.lt/) regarding the actions (inaction), which, in your opinion, are in breach of the provisions of legal acts.

CHILDREN’S PRIVACY

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).

We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on MilloApp.

We will let you know via prominent notice on MilloApp, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy, please contact us by email hello@getmillo.com or phone +37065944844.