In order to use the service, we will ask you to enter your gender, age category and email. We also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the service, to serve ads. For improving our service and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Appsflyer, Facebook, Google, Amplitude, Firebase, Mailfire, Snapchat. Some of the data is stored and processed on servers of such third parties. This enables us to: (1) analyze different interactions (how often users make purchases, what is the average time spent by users on the website); (2) serve and measure ads (and are able to show them only to a particular group of users, for example, to users that have already visited the website).
TABLE OF CONTENTS
1. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, when you enter your gener, age category, email). We also collect data automatically (for example, your IP address). We also may receive data about you from third parties.
1.1. Data you give us
You provide us information about yourself in the process of ordering personalized personal development plan. For example: gender, age category, email address.
1.2. Data we collect automatically:
1.2.1. Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the web where you were when you tapped on our ad).
1.2.2. Device and Location data.
We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system and its version, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
1.2.3. Usage data
We record how you interact with our Service. For example, we log your taps/clicks on certain areas of the interface, the features, and content you interact with, how often you use the Service, how long you are in the Service, and your purchases. We also record the ads on our Website with which you interact (and the Internet links to which those ads lead).
1.2.4. Advertising IDs
We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset
these numbers through the settings of your device’s operating system (but
we do not control this).
1.2.5. Transaction data
When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.
Cookies are used, in particular, to automatically recognize you the next time you visit our Website. As a result, the information, which you have earlier entered in certain fields on the Website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.
2. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
2.1. To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
To host personal data and enable our Service to operate and be distributed we use Google Cloud, which is a hosting and backend service.
2.2. To customize your experience
We process your personal data, such as gender, age, books preferences, to adjust the content of the Service and make offers tailored to your personal preferences. As a result of such processing, we will be able to provide personalized development plan.
2.3. To manage your account and provide you with customer support
2.4. To communicate with you regarding your use of our Service
We communicate with you, for example, by emails. These may include, for example, emails with information about the Service.
The services that we use for these purposes may collect data concerning the date and time when the message was viewed by
the Website’s users, as well as
when they interacted with it, such as by clicking on links included in the message.
We use Mailfire, which is a marketing personalization and retention platform, to deliver tailored email messages to our users.
2.5. To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of the Website our users like more, what categories of users use our Website. As a consequence, we often decide how to improve the Website based on the results obtained from this processing.
To analyse how visitors use our Service and to measure effectiveness of some ads we use Google Analytics, a web analysis program of Google. In order to provide us with analytics, Google Analytics places cookies on your device. On Google Analytics we get, in particular, aggregated information on the data you enter on our Service and users’ interactions within the Service. Google allows you to influence the collection and processing of information generated by the Google, in particular, by installing a browser plug-in available here
2.6. To send you marketing communications
We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our products, such as for example, special offers. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails. We use Mailfire, which is a marketing personalization and retention platform, to deliver tailored email messages to our users.
2.7. To personalize our ads
We and our partners, including Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have accessed our Service, you might see ads of our products, in your Facebook’s feed. How to opt out or influence personalized advertising
iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.
Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).
To learn even more about how to affect advertising choices on various devices, please look at the information available here.
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
• Network Advertising Initiative http://optout.networkadvertising.org/
• Digital Advertising Alliance http://optout.aboutads.info/
• Digital Advertising Alliance (Canada) http://youradchoices.ca/choices
• Digital Advertising Alliance (EU) http://www.youronlinechoices.com/
• DAA AppChoices page http://www.aboutads.info/appchoices
Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.
We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
We use Facebook pixel on the Website. Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Website (for example, purchased a meal plan). We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the App (for example, installed it). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook CustomAudience here.
Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows to us to tailor the ads in way that they will appear, for example, only to users that have conducted certain actions with our App ( for example, show our ads to users who have purchased a subscription).
Some other examples of events that may be used for tailoring ads include, in particular, installing our App. Google allows its users opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
2.8. To process your payments
We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for a subscription and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
2.9. To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
2.10. To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users) In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.
We process your personal data under the following legal bases:
3.1. to perform our contract with you;
Under this legal basis we:
• Provide our Service (in accordance with our Terms and Conditions of Use)
• Customize your experience
• Manage your account and provide you with customer support
• Communicate with you regarding your use of our Service
• Process your payments
3.2. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
• to communicate with you regarding your use of our Service
The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you, which may help you to advance in life and career.
• to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features).
• to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.
• to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
• to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non- compliance with our Terms and Conditions of Use.
3.3. to comply with legal obligations.
4. WITH WHOM WE SHARE YOUR PERSONAL DATA
4.1. Service providers
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We share your personal information with the following types of service providers:
• cloud storage providers (Google)
• data analytics providers (Facebook, Google, Appsflyer, Firebase, Amplitude)
• measurement partners
• marketing partners (in particular, social media networks, marketing agencies, email delivery services, Facebook, Google, Snapchat)
• payment processing providers
• communication services providers (Mailfire)
4.2. Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
4.3. Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
To be in control of your personal data, you have the following rights: Accessing / reviewing / updating / correcting your personal data. You may request a copy of your personal data and request us to update/correct your personal data collected during your use of the Service at [email protected].
Deleting your personal data. You can request erasure of your personal data by sending us an email at [email protected].
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations. Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at [email protected].
Additional information for EEA-based users.
If you are based in the EEA, you have the following rights in addition to the above:
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at [email protected].
6. AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at [email protected].
7. INTERNATIONAL DATA TRANSFERS
9. CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to [email protected], which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
10. DATA RETENTION
11. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
This Service does not support “Do Not Track” requests. To determine whether any of the third- party services it uses honor the “Do Not Track” requests, please read their privacy policies.
12. PERSONAL DATA CONTROLLER
MMLJ d.o.o., a company registered in the Republic of Slovenia (with registered office at Trubarjeva cesta 24, Ljubljana, 1000 Ljubljana, Slovenia, Europe) will be the controller of your personal data.
13. CONTACT US
Effective as of: 1 May 2021