This mobile application is operated by affcompanion.com (“we” “our” or “us”). Your privacy is important to us. To better protect your privacy, we provide this policy explaining how we collect, use and disclose the information you submit on this mobile application (“App”).

Where we process personal data of individuals located in the European Economic Area (EEA), including Cyprus, we do so in accordance with Regulation (EU) 2016/679 (the “GDPR”) and applicable national implementing laws, including the Cyprus Law on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of Such Data, Law 125(I)/2018.

By visiting and/or using our App, you are agreeing to the terms of this Privacy Policy. If you do not agree with anything contained in this Privacy Policy then please refrain from using our App immediately.

1. Who We Are and How to Contact Us

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For the purposes of applicable data protection law, the data controller of your personal data is: Codeiverse Ltd

Email: contact@affcompanion.com

2. Information we Collect or Receive

In the course of operating the App, we will collect and/or receive the following types of information that are necessary to provide you access to and the services offered through the App. Where required by applicable law (for example, for precise geolocation data in the EEA), we will obtain your consent before collecting or using such information.

You authorize us to collect and/or receive such information:

(a) Log In information. When you sign in to our App or contact us, you will be required to provide us with personal information about yourself. Such Log In information may include, but is not limited to your name, username, email address, password (in encrypted form), and any other authentication credentials you choose to use.

(b) Technical, Usage and Device Information. We collect certain non-personally identifiable technical, usage, and device information when you use our App. This may include details about the type of device you are using, device-specific identifiers, operating system type and version, and cookie information. This data enables us to provide you with a consistent and personalized experience, including tailored content and advertising across the devices you use.

(c) Third-Party Analytics. We and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies and ad servers with which we work use third-party analytics services (e.g., Google Analytics) to evaluate your use of the App, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the App and mobile and Internet usage. We do this to improve the App and to help us offer you new features and services. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the App.

(d) Cookies. We may use both session cookies, which expire once you close the App, and persistent cookies, which stay on your mobile device until you delete them and other technologies to help us collect data and to enhance your experience with the App. Cookies are small text files an app can use to recognize a repeat visitor to the app. We may use cookies for various purposes, including to i) Determine type of mobile device; ii) Personalize your experience; iii) Analyze which portions of the App are visited and used most frequently; and iv) Measure and optimize advertising and promotional effectiveness.

Where we collect or access information through cookies or similar technologies, we do so in accordance with the ePrivacy rules applicable in the EEA and Cyprus. Non-essential cookies or tracking technologies are only activated where you have provided valid consent.

If you do not want us to deploy cookies in the App, you can opt out by setting your mobile device to reject cookies. You may still use the App if you choose to disable cookies, although your ability to use some of the features may be affected.

3. How Information is Used and Shared

(a) You authorize us to use the Log In Information, Technical, Usage and Device Information, Third-Party Analytics and Cookies (collectively, the "Information") to:

(i) Provide and operate our services and App;
(ii) Maintain the security and integrity of our App, prevent fraud or misuse;
(iii) Perform analytics and improve the performance and usability of our App;
(iv) Send you push notifications or deliver personalised content or advertising where you have given your consent.

(b) In order to provide our services and administer our App, we may share the Information with our affiliated companies for them to perform functions on our behalf. Examples may include providing technical assistance, customer service and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

(c) As part of our ongoing effort to better understand our users, the App, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage and improve the App and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the App and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

(d) As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution or similar event, the Information may be part of the transferred assets.

(e) To the extent permitted by law, we may also disclose the Information: when required by law, court order, or other government or law enforcement authority or regulatory agency; or whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

4. Your choices

(a) Marketing Communications. You may manage your receipt of marketing and non-transactional communications by (i) clicking on the "unsubscribe" link located on the bottom of any of our marketing e-mails or (ii) contacting us as explained below. You may also disable the notifications delivered to your mobile device (e.g., push notifications) by deleting the relevant service or by changing the settings on your mobile device.

(b) Uninstalling a Mobile Application. If you no longer wish to have any information collected by the App, you may uninstall the application by using the standard uninstall processes available on your mobile device or via the mobile application marketplace or network. We make no representation of any kind as to the accessibility or stability of your wireless network and/or cellular service provider.

5. Security and data retention

We take commercially reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration or destruction. You acknowledge and understand, however, that no security system is impenetrable. We cannot assure you that the Information we collect will never be used or disclosed in a manner that is inconsistent with this Privacy Policy, nor can we guarantee the security of our databases or the databases of the third parties with which we may share such Information or that the Information you supply will not be intercepted while being transmitted over the Internet.

We will retain the Information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes (such as for the purposes of exercising our legal rights), or for as long as the law otherwise permits.

6.Information updates, corrections and withdrawals of consent

If you have provided us any personally identifiable information, you may, subject to legal or contractual requirements or restrictions, access, remove, review and/or make changes to this information by contacting us as explained below. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that even if you withdraw your consent, pursuant to applicable law, it is not always possible to completely remove or modify information in our subscription databases. To help protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or erasing any information.

7. Important Notices to Non-Cypriot Residents

The App and its servers are operated in the Republic of Cyprus. If you are located outside of the Republic of Cyprus, please be aware that your Information may be transferred to, processed, maintained and used on computers, servers and systems located outside of your district, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside of the Republic of Cyprus and choose to use the App, you hereby irrevocably and unconditionally consent to such transfer, processing and use in the Republic of Cyprus and elsewhere.

8. App Stores

Your App store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the App, such as personal Information, geolocational information and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party's applicable privacy policies.

9. Children

The App is not directed to children under the age of 13. We adhere to the Children's Online Privacy Protection Act of 1998, 15 U.S.C. §§ 6501–6506 ("COPPA"), and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use the App. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

10. Privacy Policy updates

We may change this Privacy Policy from time to time. In any event, we will not reduce your rights under this Privacy Policy without your explicit consent, and any substantial change will be posted on the App. By accessing the App after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

11. Contact us

If you have any questions or concerns about this Privacy Policy or its implementation you may contact us through the following contact@affcompanion.com.