Pulsey Privacy Policy - Protecting Your Health Data

Effective day: November 20, 2023
At SANATORIJA K Development LCC, we respect the privacy rights and data protection rights of our users and recognize the importance of protecting the personal information we collect about you. Our Privacy Policy is designed to help you understand what information we collect and how we use and share that information.
This Privacy Policy applies to Websites, Apps, Games and other Services operated by SANATORIJA K Development LCC. For simplicity, we refer to all of these as our “us”, “we”, “publisher”, “services” or “apps” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services, including apps and games.
We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!
We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

INTRODUCTION

This Privacy Policy applies when you use any of the Apps of SANATORIJA K Development LCC Publisher and should be read together with Terms of Use. By using a our Apps, you are consenting to our processing of your information in ways set out in this Privacy Policy. If you do not agree with it, please do not use any our Apps. In certain cases, for example, if geolocation data is processed by the relevant App, the App will prompt you to give additional consent. In such case, you can choose not to give consent to us processing data related to your location but you can still use the Publisher’s App. From time to time, Publisher may modify this Privacy Policy so you should review it regularly.

INFORMATION WE COLLECT

When you use Apps, Publisher may collect data, including information which directly or indirectly identifies you. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it. The information we collect about you includes:
We will collect information about you when you interact with us such as when you report a problem, contact or communicate with us.
To use certain features in our services, you may allow us to access your camera or the microphone. Depending on your device, Apple and Android system will ask for your permission before allowing us to access these features.
If an Publisher’s App offers you the option to register, we will collect the information you provide to us in the registration form. This may include identification data such as your name, email address or other account or registration information.
Features that allow you to share content about your use of our services with your connections or through your social network.
We will also collect your information when you use publisher’s Apps such as when you post or share material, upload data, request further services or make selections using the publisher’s Apps, if such functionality is available in the Publisher’s App.
We may collect certain device information and electronic identifiers such as your mobile device identifier provided by your mobile device operating system, your mobile operating system details and the name of your mobile carrier, hardware and software information such as app version, app crashes, device type, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser. For example, if you use the iOS platform then Advertiser IDs (also known as “IDFAs”) may be collected. Other identifiers collected may include IP addresses, OpenUDID, Session ID, ODIn1, iOS Vendor IDs, MAC addresses, IMEI, Android ID for Android platform, and ODIN1 for OS X (together with the IDFAs, the “App Identifiers”).
Information about how and when you use the Publisher’s App. This includes the amount of times you used the Publisher’s App, which parts of it you viewed and other technical data such as country settings and timestamps.
Geolocation data, which is any information which indicates the geographical position of your device and which may include the time the location was recorded. Before processing any precise GPS geolocation data, the Publisher’s App will require you to give your consent, which you can revoke by changing the privacy settings of your device.
Information on your wireless and mobile network connection, like your service provider and signal strength.
Any of your information you provide or permit to be provided to us via a social network or public forum provider like Facebook when you link the Publisher’s App to your social network or public forum account. This data may include your use of the Publisher’s App on such public forums and/or social networks, including with whom you share the Publisher’s App. For further information how and for what purpose the social network provider collects etc. your data see their privacy policy.
We automatically collect certain information from your device when you use the Publisher’s App including information about your device, carrier and other technical data.
If you opt-in, some services may collect movement data from your device.
We may collect the facial feature data separately from your photos only to provide you remove background functionality (our AI works only with photos with people). Please note, we collect the facial feature data that is not biometric data. This facial data does not contain your identity and is not uploaded to or otherwise stored on our servers, and we never access (nor are we able to access) those photos/images from your device.
In addition to the information you provide us directly, we receive information about you from other services, including:
You may be able to use your Facebook account to login to create an account. When you use this feature, we may receive any of your information you provide or permit to be provided to us via a social network or public forum provider like Facebook. This data may include your use of our app on such public forums and/or social networks, including with whom you share our app. For further information as to how and for what purpose the social network or public forum provider collects, uses and shares your data, as well as how you can set your privacy preferences on their site or apps, please see their privacy policy.
We may receive information about you from our partners, for instance where our ads are published on a partner’s website or platform (in which case they may pass along details on a campaign’s success).
If you purchase a subscription in our apps, neither Google nor Apple provide us with any personal information of the subscription purchaser (like name, email or payment information). Only anonymized data gets passed to us.

HOW DO WE USE UPLOADED IMAGES?

Your images are secure and will be treated confidentially.
We transfer them SSL/TLS-encrypted and use them only to remove the background and then offer you the result for download.
We do not share them with third parties, do not publish them and do nothing else with them.
At the latest about one hour after the upload we delete both the uploaded image and the result image.
Apart from that, we keep usage statistics (without images) and if you contact us e.g. by email, we also receive personal data from you, which we use to reply to you. If we have a customer/supplier relationship, we also use your data for bookkeeping and similar purposes.

ONLINE TRACKING AND OPT-OUT

We are committed to providing you with meaningful choices about the information collected from you on our publisher’s Apps for third party purposes, and that is why we provide the links below to the NAI “Consumer Opt-out,” DAA opt-out, and Google and other opt-outs that are only applicable to participating third parties, which does not include Publisher. As stated below you may also block certain App Identifiers by changing the settings of your device. However, we do not currently recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is still working on Do Not Track standards, implementations and solutions. https://support.google.com/ads/answer/2662922?hl=en, http://www.networkadvertising.org/choices/, http://www.aboutads.info/choices/, https://info.yahoo.com/privacy/us/yahoo/, http://www.flurry.com/legal-privacy/end-user-opt-out, https://www.adjust.com/terms/privacy-policy, http://www.google.com/intl/en/policies/privacy, https://policies.google.com/privacy,

COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use Google Analytics tool Firebase in order to carry out analysis on Information which is gathered by publisher’s Apps. App Identifiers and other Information which Publisher’s gather are provided to Google in order to enable them to carry out data analysis. Any Information (including App Identifiers) which are provided to Google will become subject to Google’s privacy policy which is located here: www.google.com/privacy.html. For further information on how Google’s Firebase analytics tool uses data, please see the site “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).
Separately to the publisher’s Apps, the Publisher’s website itself uses cookies. Certain information about you, (including personal information), may be collected through the use of cookies when you visit and interact with our website. Some of these cookies are essential for the Publisher’s website to operate and ensure that we provide the services you requested. By using our services you agree to the use of certain non-essential cookies unless you set your browser to reject them. A cookie is a small text file that is stored on your computer’s hard drive or browser. We use cookies and the information contained therein for a number of purposes including but not limited to: tracking the duration of visits and content accessed; and storing frequently used user information to personalise your online experience and ease the log-in process.
You may block cookie/ cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our website. Further information on cookies and how websites use them can be obtained at www.cookiecentral.com.
More information on our use of cookies on our websites can be found in Cookie Policy.

HOW WE USE THE INFORMATION WE COLLECT

We may use your information:
To administer your account and provide our services to you Deliver the publisher’s Apps to you and ensure their optimal functionality and operation.
Identify, establish and manage your account and our relationship with you.
Provide you with customer support and respond to your requests.
Should you provide us with this information, we may use your email address, name, country and language for customized marketing purposes.
When we collect your precise geolocation data (subject to your consent) (which may be via the device’s cellular, Wi-Fi, Global Positioning System (GPS) networks and/or Bluetooth information), we do so to provide you with our location-related products and services, for example to provide you with forecast and weather alerts for your location, and also to facilitate, measure, or otherwise support advertising by third parties (through our apps or third parties’ apps) that may be related to your location over time.
Some of our apps may offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the app you are using, and on the social media provider concerned, but may often include your name, e-mail address, mobile phone number and friends list. If you login using your Facebook account, your e-mail or your phone number then we may receive a unique ID in connection with this login. This is solely used for confirmation purposes and is kept separate from all other online identifiers. We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you in the app you are using. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you see their privacy policy to understand how they collect, use and share your information, and how you can set your privacy preferences on their sites and apps.
If you have registered with an app using your social media account details, we may use the information we receive from your social media provider to identify which of your friends are also using our services so that you can connect with them in our app.
In some services, to ensure a consistent experience across your devices:
Link the various apps and devices you use, so that you can enjoy a consistent experience of our services on all of them. This will allow us to form a single view of your use of our services, so you can easily access your content on multiple devices. For this purpose and better user experience generally, we may use and combine your personal information which we collect across different services used by you.
To improve our services and develop new ones:
Develop new features and services (for example, we may decide to build a new feature further to requests or feedback received from users).
We use the Google Analytics tool Firebase in order to carry out analysis on information which is gathered by our apps. Device information and other information which we gather are provided to Google in order to enable them to carry out data analysis. Any information which is provided to Google will become subject to Google’s privacy policy which is located here: www.google.com/privacy.html. For further information on how Google’s Firebase analytics tool uses data, please see the site “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).
Conduct research and analysis of your behaviour about your use of, or interest in, our products, services, or content to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour). This software may record information such as how often you use the services, what happens within the services, aggregated usage, performance data, app errors and debugging information, and where the apps were downloaded from.
To communicate with you:
Communicate with you by postal mail, telephone and/or mobile devices (including through in-application advertising) about products or services that may be of interest to you either from us, our parent or subsidiary companies or other third parties. If you do not wish to receive in-application advertising, in some cases you can upgrade to the paid version of the app.
When you share your information with us via a social network provider like Facebook, we use this to show information on your social network profile (subject to your privacy setting and preferences for such social network) and to allow you to share information about our services with your connections or on your social network profile.
With your consent (where needed), to send you email marketing in order to provide you with information about services that you may find of interest. You can opt-out of receiving direct marketing communications from us by following the unsubscribe instructions included in our marketing communications. We also send you non-marketing emails or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, service availability or modification of key features or functions. To serve you relevant offers and ads:
Develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. When you are on our services, third-party ad partners may provide you with advertising based upon your interests. These companies may use technologies to collect data about users, including precise device location data, to help them tailor relevant ads and measure ads’ effectiveness. These companies may collect this data through SDKs or from users who view or interact with their advertisements. For the purposes of European law, most of these ad partners are independent controllers of your information, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the services. It also means that if you are a Facebook app user for example – you provided consent to Facebook in your Facebook app to allow them to show you personalized ads inside of our services.
Verify your eligibility and deliver prizes in connection with contests and sweepstakes and in order to conduct polls and surveys.
To prevent, detect and fight fraud or other illegal or unauthorized activities:
Perform data analysis to better understand and design countermeasures against these activities.
Retain data related to fraudulent activities to prevent against recurrences.
To ensure legal compliance:
Comply with legal requirements.
Assist law enforcement.
Enforce or exercise our rights.
To process your information as described above, we rely on the following legal bases:
Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to maintain your account and provide our cool features to you.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings and we process information for administrative, fraud detection and other legal purposes.
Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time where indicated in the services or by contacting us at the address provided at the end of this Privacy Policy.

CROSS-APP ADVERTISING AND OTHER INTEREST-BASED ADVERTISING TECHNOLOGIES

As described above, we sometimes work with third parties to deliver ads, content or offers. Sometimes we or these third parties do so through a mobile “SDK.” The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services to be implemented. We may use this and similar technology to deliver certain advertising through mobile applications and browsers based on data associated with your mobile device, and we may work with third parties who likewise embed their SDKs into our apps, for third party advertising. If you’d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions below.
If you wish to opt out of interest-based cross-application tracking through your mobile device, you can do so through your device “settings”, as follows (but please note that the below is for informational purposes only and Apple, Google, or other device platforms may change the manner in which their “opt out” settings work at any time). Please note that if you opt out through these settings, you will continue to receive advertising after you opt-out, but it may not be tailored to your interests. For instance, that advertising may be based on your real-time or “contextual” application usage or general location inferred from IP address. Opting Out on iOS Devices Such as iPhones, iPads or iPods:
If you have an Apple device, you can opt out of mobile interest-based or “cross-app” advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON’. On an iPhone 6 for example, you can do this by clicking on Settings -> General -> Privacy -> Advertising and toggling “Limit Ad Tracking” to ‘ON’. Our systems are designed to respect your choice and not use Information to provide interest-based advertising when this setting is ON.
We may sometimes work with partners to help us or help them correlate content or ads provided to users across devices or browsers. For instance, a brand may wish to use the Information that we collect (or data that its own partners collect) to send offers to its customers across both mobile applications and browsers. We thus also provide the links below to the NAI “Consumer Opt-out,” DAA opt-out, and Google opt-out that are only applicable to participating third parties. You may also block certain App Identifiers by changing the settings of your device. However, we do not currently recognize or respond to browser-initiated Do Not Track signals, as the Internet industry has not reached a consensus as to Do Not Track standards, implementations and solutions. http://www.google.com/policies/privacy/partners/ , https://support.google.com/ads/answer/2662922?hl=en, http://www.networkadvertising.org/choices/, http://www.aboutads.info/choices/
More information on our use of cookies on our websites can be found in our Cookie Policy.

HOW WE SHARE YOUR INFORMATION

We do not share your information with others except as indicated below:
We may share your information with our authorized service providers that perform certain services on our behalf. These services may include providing customer service and marketing assistance, performing business and sales analysis, supporting apps functionality, and supporting marketing promotions (e.g., contests and sweepstakes) surveys and other features offered through our Apps. These service providers may have limited access to your information, which is needed to perform their functions, but are not permitted to share or use such information for any other purposes.
When you engage in promotions offered through our Apps, we may share your information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other information to that merchant.
We may also allow third-parties, including our authorized service providers, parent and subsidiary companies, affiliates, advertising companies, and ad networks, to display advertisements in the publisher’s Apps or use App Identifiers for the purpose of advertising and direct marketing. These companies may use technologies to collect information about users who view or interact with their advertisements. This information allows them to deliver targeted advertisements and gauge their effectiveness.
We combine information internally at Publisher across different publisher’s Apps. This will enable us to provide more tailored and personal experiences and services to you across the family of publisher’s Apps. Other Situations. We may disclose your information if reasonably necessary (i) in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency, (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others; (iv) to comply with applicable law or cooperate with law enforcement; (v) to enforce publisher’s Apps terms and conditions or other agreements or policies; and (vi) in connection with a substantial corporate transaction, such as the sale of our business or the publisher’s Apps, a divestiture, merger, consolidation, or asset sale or transfer, or in the unlikely event of bankruptcy. In addition, we may share aggregated information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other legitimate business purposes. Please note that such aggregated information will not include any information which allows third parties to identity you.

HOW WE PROTECT YOUR INFORMATION

The security and confidentiality of your information is very important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. Please know that, despite our efforts, no security measures are perfect or impenetrable.

INFORMATION RELATING TO CHILDREN

Some if the publisher’s Apps are not directed to children under the age of 13. We do not knowingly collect (or knowingly allow any third party to collect) information from persons under the age of 13. If we become aware that information has been collected from a person under the age of 13, we will delete this information and terminate the person’s account as quickly as possible. If you believe that we may have information from or about a child under the age of 13, please contact us and we will promptly delete that information.

YOUR RIGHTS

We want you to be in control of your information and be aware of your privacy rights, so here are a few key points to remember:
Depending on your location you may have some or all of the following rights in relation to how we use your personal information:
Access: you may request access to your personal information and receive copies of it; Correction: you may have inaccurate/incomplete personal information corrected and updated; Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it.
Deletion: in certain circumstances, you can request a right “to be forgotten” (this is a right to have your information deleted or our use of your data restricted). We will honour such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it. Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider) Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.
If you wish to exercise any of these rights, or wish to object to our use of your information, please write to us at the address listed below and we will consider your request in accordance with applicable laws. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.
For your protection, we may ask you to provide proof of identity before we can answer the above requests.

CROSS-BORDER DATA TRANSFERS

The information that we collect from you may be transferred to, and stored at, a destination outside of your country and the European Economic Area (“EEA”) and, in particular, the US. It may also be processed by any service providers appointed by us who operate outside the EEA and their staff, and/or our own staff based outside of the EEA. By submitting your data, you agree to this transfer, storing or processing outside of the EEA. Data transferred will be treated in accordance with this Privacy Policy.

HOW LONG WE STORE YOUR INFORMATION

We retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active or as needed to provide the services to you. We will also retain and use your information to the extent necessary: to comply with applicable law; to evidence our compliance with applicable law; if there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or if the information must be kept for our legitimate business interests, such as enforcing our terms or fraud prevention. For example, information may need to be kept to prevent a user who was banned for security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

DATA DELETION

Uninstallation and removal methods vary depending on your device. To uninstall and remove the publisher’s Apps, please use the application manager provided with your device or consult your device manual for reference. Any of your data stored by us will be deleted after a reasonable period following deletion of a Publisher’s App.

ACCESS TO AND CHOICES REGARDING YOUR INFORMATION

You have the right to access information held about you or require it to be modified if inaccurate or deleted. Your right of access can be exercised by contacting us using the details set out below. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

Because we’re always looking for new and innovative ways to help you enjoy our services, this policy may change over time. We will notify you of any material changes so that you have time to review the changes.