Privacy policy

Effective 24 June 2021

We are committed to respecting your data privacy and providing transparency about our data practices.
This
Privacy Policy (this «Privacy Policy») explains how Mikita Danko («Company» or «we» or «us») collects,
stores,
uses, transfers and discloses Personal Data from our users («you») in connection with the Company mobile
application and related services (collectively, the «App»).

We reserve the right to and may change this Privacy Policy from time to time. If we make any material
changes,
we will notify you by email (if you provide us any email address), through the App, or by publishing a
notice on
our website, or by presenting you with a new version of this Privacy Policy for you to accept, if we,
for
example, add new processing activities or collect some additional Personal Data from you.

Your continued use of the App after the effective date of an updated version of the Privacy Policy will
indicate
your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept
changes
to
Privacy Policy to continue using the App. We strongly encourage you to review our website from time to
time
for
the latest information on our data privacy practices. If you do not accept the terms of the Privacy
Policy,
we
ask that you do not use the App. Please exit the App immediately and delete it if you do not agree to
the
terms
of this Privacy Policy.

1. PERSONAL DATA AND INFORMATION WE COLLECT ABOUT YOU

We collect the following Personal data and information from you:

  • Contact Information such as name and email address.
  • Preferences Information you provide such as product or content interests, or communication or
    marketing
    preferences.
  • Usage activity about how you interact with us such as purchase history, what content you viewed,
    and which areas
    of our app you visited.
  • Fitness or Health information such as your weight, height, and activity
  • Device and Usage Information that may include data specific to your mobile device (e.g., make,
    model, operating
    system, advertising identifier and similar information); information about your use of features,
    functions, or
    notifications on the device; and signal strength relating to Wi-Fi or Bluetooth functionality,
    temperature,
    battery level, and similar technical data.
  • Demographic information such as age and gender.
  • Information about your mobile device such as your mobile device id (similar to a website IP
    address), device
    type, and mobile service carrier.

We may collect this Personal data and information even if you are not logged in to the application.

You will also have an option to permit us to import and export the App data from third-party services
such as
Apple HealthKit and Google Fit, among others. Such information may include: weight, gender, height,
heartbeat
rate, number of steps/distance travelled, and other information about your health.

  • We do not use the information obtained via the HealthKit framework for advertising or similar
    purposes.
  • We do not disclose any information obtained via HealthKit to third parties without expressed
    permission
    from the users.
  • We do not sell information obtained via HealthKit to advertising platforms, data brokers or
    information
    resellers.

Permitting us to access third party information can help you to maximize your App experience, and we
will handle
any such third-party information in full accordance with this Privacy Policy.

If the information covered by this Section is aggregated or de-identified so it is no longer reasonably
associated with an identified or identifiable natural person, we may use it for any business purpose. To
the
extent information covered by this Section is associated with an identified or identifiable natural
person and
is protected as personal data under applicable data protection laws, it is referred to in this Privacy
Policy as
«Personal Data». We use pseudonymization for particular types of Personal Data. Please
bear in mind that
provisions of Section 3 do not apply to pseudonymized Personal Data.

YOUR CONSENT FOR PROCESSING OF YOUR PERSONAL DATA.

By installing the App and creating a profile in the
App, (or
by explicitly accepting this Privacy Policy and explicitly consenting to the processing of your Personal
Data)

you explicitly consent that:

  • WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND THROUGH THE
    ACCOUNT
    CREATION PROCESS SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE
    FEATURES
    AND OTHER
    PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU
    INFORMATION AND
    REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS YOU PROVIDED TO US.
  • PERSONAL DATA YOU PROVIDE TO US THROUGH THE USE OF THE APP INCLUDES PERSONAL DATA YOU ENTER INTO THE
    APP, SUCH
    AS YOUR ACCOUNT DATA (E.G. YOUR NAME AND EMAIL ADDRESS), AND YOUR HEALTH DATA (E.G. BODY
    MEASUREMENTS,
    PHYSICAL
    ACTIVITY AND OTHERS). DEPENDING ON THE DATA YOU PROVIDE, IT MAY ALSO CONTAIN INFORMATION ABOUT YOUR
    GENERAL
    HEALTH (E.G. WEIGHT, AND OTHERS).
  • WE WILL NOT TRANSMIT ANY OF YOUR HEALTH DATA TO THIRD PARTIES UNLESS WE HAVE ASKED FOR YOUR EXPLICIT
    CONSENT.

YOU CAN ALWAYS WITHDRAW YOUR CONSENT TO PROCESSING OF YOUR PERSONAL DATA AND (OR) ITS TRANSMISSION TO
THIRD
PARTIES BY CONTACTING US AT dankonikitaproject@gmail.com

2. HOW WE USE YOUR PERSONAL DATA AND INFORMATION

We may use your information, including your Personal Data, and by accepting this Privacy Policy you
provide us
with your explicit consent, for the following purposes:

  • to analyze, operate, maintain and improve the App and marketing activities, to add new features and
    services to
    the App;
  • to assess your needs to determine suitable products or services;
  • to send product updates or warranty information;
  • to respond to your comments, questions and requests and provide customer service;
  • to send you push notifications, both internal and external. IF YOU DO NOT WANT TO RECEIVE THESE
    NOTIFICATIONS,
    YOU CAN MANAGE YOUR PREFERENCE EITHER THROUGH YOUR DEVICE OR APP SETTINGS DEPENDING ON YOUR DEVICE
    TYPE.
    YOU CAN
    ALSO CONTACT US AT dankonikitaproject@gmail.com
  • to send you marketing communications;
  • to improve our App and marketing efforts, to conduct research and analysis, including for scientific
    and
    academic research purposes;
  • for any other purposes disclosed to you at the time we collect Personal Data or any other purposes
    indicated in
    this Privacy Policy.

Choice/Opt-Out. You may opt-out of receiving our newsletter or marketing emails from us
by following the
instructions on how to unsubscribe included in each newsletter or marketing email, or you can contact us
at
dankonikitaproject@gmail.com

Social Networks. We enable you to create a profile, and share information such as
messages, photos, and
videos
with others within your network. We cannot control the actions of others with whom you may choose to
share your
pages and information. Also, we cannot guarantee that the content you post on our App will not be viewed
by
others outside your network.

Any information (including Personal Data) you share in any online community area or online discussion is
by
design open to the public and is not private, unless provided differently in the App settings. You
should think
carefully before posting any Personal Data in any public forum. What you post can be seen, disclosed to,
or
collected by third parties and may be used by others in ways we cannot control or predict, including to
contact
you for unauthorized purposes. As with any public forum on any site, the information you post may also
show up
in third-party search engines.

If you mistakenly post Personal Data in our community areas and would like it removed, you can send us
an email
as listed below to request that we remove it. In some cases, we may not be able to remove your Personal
Data,
e.g. for technical reasons.

3. YOUR RIGHTS

Modification, correction, and erasure. You are able to modify, correct, erase and update
your Personal
Data in
the App account settings or, if that is impossible, by writing to us at dankonikitaproject@gmail.com

Opt-out. If you do not want any of your Personal Data to be processed by us or any third
parties, you
may opt
out at any time by contacting us at dankonikitaproject@gmail.com For other options for third party
tracking
limitation please also refer to Section 4 of this Privacy Policy.

Access. You have a right to access your Personal Data you insert into the App and ask us
about what kind
of
Personal Data we have about you. You can do this by using the app settings or by writing to
dankonikitaproject
@gmail.com

EU residents. Individuals residing in the countries of the European Union have certain
statutory rights
in
relation to their personal data introduced by the General Data Protection Regulation (the «GDPR»).
Subject to
any exemptions provided by law, you may have the right to request access to Personal data (including in
a
structured and portable form), as well as to seek to update, delete or correct Personal data:

  • Rectification of Personal Data and Restriction of Processing. You are responsible
    for ensuring the
    accuracy of
    your Personal Data that you submit to the App. Inaccurate information will affect your experience
    when
    using the
    App Web Sites and tools and our ability to contact you as described in this Privacy Policy. If you
    believe that
    your Personal Data is inaccurate, you have right to contact us and ask us to correct such Personal
    Data
    by
    contacting us at dankonikitaproject@gmail.com You shall also have the right to request restriction
    of
    processing of your Personal Data, if you contest the accuracy of the Personal Data, and we need some
    time to
    verify its accuracy.
  • Access to your Personal Data and Data Portability. The App gives you the ability to
    access and update
    Personal
    Data within the App and your account settings. You shall be entitled to request information about
    whether we
    have any Personal Data about you, to access your Personal data (including in a structured and
    portable
    form) by
    using your app settings or by simply writing to us at dankonikitaproject@gmail.com
  • Erasure of your Personal Data. If you believe that your Personal Data is no longer
    necessary in relation
    to the
    purposes for which it was collected or otherwise processed, or in cases where you have withdrawn
    your
    consent or
    object to the processing of your Personal Data, or in cases where the processing of your Personal
    Data
    does not
    otherwise comply with the GDPR, you have right to contact us and ask us to erase such Personal Data
    as
    described
    above. You can simply write to us at dankonikitaproject@gmail.com Please be aware that erasing some
    Personal
    Data inserted by you may affect your ability to use the App and its features. Erasure of some
    Personal
    Data may
    also take some time due to technical reasons.
  • Right to object processing of your Personal Data. You can object to processing your
    Personal Data and
    stop us
    from processing your Personal data by simply writing to us at dankonikitaproject@gmail.com Please
    be
    aware that
    erasing some Personal Data inserted by you may affect your ability to use the App and its features.
  • Notification requirements. We commit to notify you within a reasonable period of
    time and your data
    protection
    authority within the timeframe specified in applicable law (72 hours) about any personal data
    breaches
    in the
    App.
  • Data Protection Authorities. Subject to GDPR requirements, you also have the right
    to (i) restrict our
    use of
    Personal Data and (ii) lodge a complaint with your local data protection authority about any of our
    activities
    that you deem are not compliant with GDPR.

Please keep in mind that in case of a vague access, erasure, objection request or any other request in
exercise
of the mentioned rights we may engage the individual in a dialogue so as to better understand the
motivation for
the request and to locate responsive information. In case this is impossible, we reserve the right to
refuse
granting your request.

Following the provisions of GDPR we might also require you to prove your identity (for example, by
requesting an
ID or any other reasonable proof of identity) in order for you to invoke the mentioned rights,
specifically if
you exercise them in respect to special categories of Personal Data like data about health. This is made
to
ensure that no rights of third parties are violated by your request, and the rights described in this
section
are exercised by an actual Personal Data subject or an authorized person.

4. SHARING YOUR PERSONAL DATA AND INFORMATION

Sharing with third parties. We will share your Personal Data and information with third
parties only in
the ways
that are described in this Privacy Policy.

We may disclose your Personal Data:

  • as required by law, such as to comply with a subpoena, or similar legal process.
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your
    safety or
    the
    safety of others, investigate fraud, or respond to a government request.
  • if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be
    notified via
    email and/or a prominent notice on our Web site of any change in ownership or uses of your personal
    information,
    as well as any choices you may have regarding your personal information.
  • to any other third party with your prior explicit consent to do so.

We share the information we collect with third-party business partners who commit to comply with
applicable laws
concerning their usage of your Personal Data (for example, GDPR for the EU residents). Our third-party
business
partners may share your Personal Data with their own third-party business partners, granted they have
appropriate data protection safeguards in place, and use the information either for themselves or on
behalf of
their own business partners to:

  • operate and improve their services;
  • provide you with advertisements and information for products and services in this app or on other
    apps
    or
    websites based on variables such as your location, and assess your level of engagement with them;
  • carry out other purposes that are disclosed to you and to which you consent.

Depending on a service you use, we may share some of your Personal Data and information with third-party
business partners who perform analytical and other tasks for us (in some jurisdictions such parties may
qualify
for being a ‘processor’ under applicable laws). These are the third-party services with whom, among
others, we
may share some of your Personal Data and information:

  • Facebook. We use Facebook as our advertising partner to display advertising in our
    App or to manage our
    advertising on other sites. We are using the following Facebook services: Ads manager, Lookalike
    audience,
    Campaign Planner, Creative Hub, Business Manager, Page Posts, Ads Reporting, Monetization Manager,
    Pixels,
    Audience Insights. We use Facebook’s Software Development Kit (SDK) within our apps in order to link
    various
    Facebook services with our apps. For example, this enables users to share content from our apps
    within
    their
    Facebook timeline. Further information about the Facebook SDK within iOS can be found here; for
    Android
    here. We
    may share certain non-identifiable information about you and some Personal Data (but never any data
    related to
    health without your explicit consent) for the purposes described above, including to carry out
    marketing
    activities and provide you with better and more targeted service. We share the following data with
    Facebook:
    your IDFA or Android advertising ID, your user sessions, device information (model, location, OS
    version, CPU,
    screen size, etc.), application information (version, build number, etc.), information on launching,
    updating,
    installing the App and attribution source. Learn more about Facebook ads here. Facebook may use
    data
    we
    provide
    for its own advertising purposes in accordance with the Facebook Data Policy.
  • Fabric. We use Fabric, an analytics company and a Google subsidiary, to better
    understand your use of
    the App.
    For example, Fabric may use device identifiers that are stored on your mobile device and allow us to
    analyze
    your use of the App in order to improve our App features. We never share with Fabric data related to
    health
    without your explicit consent. Read more in Fabric Data Processing and Security Terms.
  • Crashlytics. Crashlytics, a Google business division, provides us crash reporting
    solution that we use
    in order
    to track when the App crashes or works improperly on your device. Crashlytics may collect certain
    device
    identifiers in order to understand on what devices and under which circumstances the App does not
    work
    or
    crashes. We share the following data with Crashlytics: your application information (version, build
    number,
    etc.), device information (model, location, country, OS version, installation date, time zone,
    carrier,
    etc.),
    data on crushes (frequency, number, etc.), and your user session. We never share with Crashlytics
    data
    related
    to health without your explicit consent. Diagnostic information is subject to the Crashlytics
    Privacy
    Policy
    which is available here.
  • Intercom. We use Intercom as an intermediary for user support services. Intercom
    may collect some of
    your
    Personal data (like contact information) in order to connect us with you. We never share with
    Intercom
    data
    related to health without your explicit consent.See more about Intercom and its Privacy
    Policy.
  • Firebase. Firebase is an analytics product from Google, Inc. that allows us to
    track crashes of the App,
    monitor
    events in the App, provide us stats regarding the use of the App. To track and analyze behavior of
    our
    App’s
    users (in particular, how they react to changes of the App structure, text or any other component),
    we
    also use
    Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided
    by
    Google,
    which also enables us to tailor the content that our App’s users see (for example, it allows us to
    show
    different onboarding screens to different users). Firebase may collect certain device identifiers in
    order to
    understand on what devices and under which circumstances particular incidents and events happen. We
    share the
    following data with Firebase: your IDFA or Android advertising ID, data on installing the App, your
    actions in
    the App (for example, tapping particular buttons like whether to receive notifications or not),
    including
    actions with additional parameters, opening particular screens, starting and cancelling a trial
    period,
    starting
    and cancelling subscription, passing the onboarding screen, completing registration, different
    technical
    events
    (for example, whether you have read a manual or not). We never share with Firebase data related to
    health
    without your explicit consent. Read about Privacy and Security in Firebase here.
  • Amplitude. We use Amplitude as analytics platform. Amplitude may collect certain
    device identifiers in
    order to
    understand on what devices and under which circumstances particular incidents and events happen. We
    share the
    following data with Amplitude: your IDFA or Android advertising ID, data on installing the App, your
    actions in
    the App (for example, tapping particular buttons like whether to receive notifications or not),
    including
    actions with additional parameters, opening particular screens, starting and cancelling a trial
    period,
    starting
    and cancelling subscription, passing the onboarding screen, completing registration, different
    technical
    events
    (for example, whether you have read a manual or not). We never share with Amplitude data related to
    health
    without your explicit consent. Read about Privacy and Security in Amplitude here.
  • Appodeal. We use Appodeal as our advertising partner to display advertising in our
    App or to manage our
    advertising on other sites. We share the following data with Appodeal: your IDFA or Android
    advertising
    ID, your
    user sessions, device information (model, location, OS version, CPU, screen size, etc.), application
    information
    (version, build number, etc.), information on launching, updating, installing the App and
    attribution
    Appodeal
    may use data we provide for its own advertising purposes in accordance with the Appodeal Data
    Policy
    .
  • Appsflyer. Appsflyer is a mobile marketing platform. We may share certain
    non-identifiable information
    about you
    and some Personal Data (but never any data related to health) in order to carry out marketing
    activities
    and
    provide you better and more targeted service. Learn more about Appsflyer: https://www.appsflyer.com
  • AppMetrica. AppMetrica is a mobile marketing platform. We may share certain
    non-identifiable information
    about
    you in order to carry out marketing activities and provide you better and more targeted service.
    Learn
    more
    about AppMetrica: https://appmetrica.yandex.ru/docs/data-security/gdpr.html

Our third-party partners are either EU-based or certified under EU-US Privacy Shield Framework that
ensures that
European data protection requirements are met. We commit to execute formal data processing agreements
with any
of our partners to ensure your privacy rights are observed. The privacy policy of these services can be
found on
their respective websites. Be informed that some third-party service providers may have their servers
located in
the United States.

You can use your device settings in iOS or Android in order to stop sharing your IDFA or Android
advertising ID
with any third parties. In any case, unless otherwise is provided by this Section, sharing of your IDFA
or
Android advertising ID does not result in any advertising that might be shown to you by the above
services. The
use of these identifiers is strictly limited to the purposes indicated in this Section of the Privacy
Policy.

BY USING THE APP, YOU CONSENT THAT WE MAY USE COOKIES AND THIRD-PARTY SERVICES AND COLLECT YOUR USAGE
(INCLUDING
FOR PROCESSING BY THIRD-PARTY SERVICE PROVIDERS) AND SOME PERSONAL DATA UNDER A UNIQUE IDENTIFIER, FOR
THE
PURPOSES OF TRACKING, ANALYSIS, AND IMPROVEMENT OF THE APP. BY USING OUR SERVICE, YOU EXPLICITLY CONSENT
TO THE
USE AND PROCESSING OF YOUR DATA COLLECTED AS DESCRIBED ABOVE.

Aggregated Information. We may also share aggregated, anonymized or de-identified
information, which
cannot
reasonably be used to identify you. For example, we may share, including, without limitation, in
articles, blog
posts and scientific publications, general age demographic information and aggregate statistics about
certain
activities or symptoms from data collected to help identify patterns across users.

5. DATA SECURITY

Security of your Personal Data is important to us. When you provide your Personal data that is
considered to be
sensitive or falls under «categories of special data» under applicable laws to us, we encrypt the
transmission
of that information using secure socket layer technology (SSL). We follow generally accepted industry
standards
to protect the Personal Data submitted to us, both during transmission and once we receive it.

Among others, we utilize the following security measures to protect your Personal Data:

  • Pseudonymization and tokenization of certain categories of your Personal Data;
  • Protection of data integrity;
  • Encryption of your Personal Data in transit and in rest;
  • Systematic vulnerability scanning and penetration testing;
  • Organizational and legal measures. For example, our employees have different levels of access to
    your
    Personal
    Data, and only those in charge of data management get access to your Personal Data and only for
    limited
    purposes
    required for the operation of the App. We impose strict liability on our employees for any
    disclosures,
    unauthorized accesses, alterations, destructions, misuses of your Personal Data.
  • Conducting periodical data protection impact assessments in order to ensure that the App fully
    adheres
    to the
    principles of ‘privacy by design’, ‘privacy by default’ and other internationally accepted data
    protection
    principles. We also commit to undertake privacy audit in case of Company’s merger or takeover.

Bear in mind that no method of transmission, or method of electronic storage, is 100% secure. Therefore,
we
cannot guarantee its absolute security. If you have any questions about security on our App, you can
contact us
at hi@mycoachapp.io.

6. RETENTION AND STORAGE OF YOUR PERSONAL DATA

We will retain your Personal Data for as long as the application is installed on your mobile device or
as needed
to provide you service. If you remove the application from your phone or (and) deactivate your
subscription, we
will remove all your Personal Data within 12 months and use copies of your Personal Data only as
necessary to
comply with our legal obligations, resolve disputes, and enforce our agreements. We retain your Personal
data
for the indicated period of time in order for you to be able to restore all your information and
settings, if
you like to return to the App. If you wish to cancel your account or request that we no longer use your
information to provide you services, or wish to delete all your information and Personal Data
permanently,
contact us at dankonikitaproject@gmail.com

In some cases, after we may anonymize you Personal Data in such a way that it will never identify you,
actually
or potentially. We may use such anonymized data for various purposes like training our AI built into the
App.

We use our own servers located in the European Union to transfer, process, and store your Personal Data.

7. CHILDREN’S PRIVACY

General age limitation. We are committed to protecting the privacy of children. The App
is not intended
for
children and we do not intentionally collect information about children under 16 years old. The App does
not
collect Personal Data from any person the Company actually knows is under the age of 16. If you are
aware of
anyone under 16 using the App, please contact us at dankonikitaproject@gmail.com and we will take
required
steps to delete such information and (or) delete their account.

8. CONTACTING US

General contact details. If you have any questions or concerns about your privacy, any
provisions of
this
Privacy Policy or any of your rights, you may contact us at:

Mikita Danko

http://fitme.by/

220131, Republic of Belarus, Minsk, Heroev of 120 devision, 6 / 237

Business ID: 193174187

Email: dankonikitaproject@gmail.com