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Privacy Policy for App and Interactive Map

Last updated: December 13, 2024

RADIACODE LTD (“we”, “us”, “our”) value your privacy and are committed to transparency in how we handle your personal data. This Privacy Policy lets you know how and for what purposes we are processing your information. We pledge that we will take reasonable steps to ensure that your personal data will only be used in ways that comply with this Privacy Policy and applicable regulations.

This Privacy Policy governs the processing of personal data in your interactions with us, including when you: (1) use our Radiacode App (the “App”), (2) use RadiaVerse interactive radiation portal including the Interactive map (the “RadiaVerse”) (collectively the “Product(s)”), (3) communicate with us and as otherwise described in this Privacy Policy.

Before you share any personal data with us, please review this Privacy Policy and our End User License Agreement (the “EULA”) and Terms and Conditions (the “Terms”).

When you choose to use our website, please understand that this Privacy Policy  describes how your personal information is collected and used.

Content

1.
Who we are?
2.
How do we collect personal data?
3.
How do we process personal data?
4.
How long do we keep your personal data?
5.
Sharing your data with third parties
6.
Rights under GDPR
7.
Your US State privacy rights
8.
Children's privacy
9.
Changes to the privacy policy
1.

Who we are?

RADIACODE LTD is duly incorporated in and registered under the laws of the Republic of Cyprus, with a registered office at 10 Spyrou Kyprianou, 4040 Limassol, Cyprus.  We act as a “data controller”. It means we determine the purposes and means of the processing of personal data.

We have appointed a Data Protection Officer to ensure compliance with the applicable data protection laws and oversee our state of compliance, also, to ensure your data protection related questions are answered.

Since we are registered under the law of the Republic of Cyprus, the personal data authority overseeing us regarding the personal data processing is Commissioner for Personal Data Protection. You always have the right to make a data protection related complaint at any time to a supervisory authority. You may also contact your local data protection authority. A list of local data protection authorities is available here.

If you would like to exercise your data protection related rights you can submit your request to our Data Protection Officer’s e-mail: security@radiacode.com.

2.

How do we collect personal data?

We process personal data in the following ways:

a.

when you provide us with personal data. You provide us with your personal data in order to utilize our services. For example, in order to create an account, and carry out marketing or informational mailings, we need the relevant personal data requested from you to create said account;

b.

when personal data is collected automatically. There are tools that allow us to collect technical personal data about you when you use our Products. For certain purposes (e.g. to enable you to technically use the App and Interactive map, to track and fix bugs on the Products), we automatically collect your personal data where there is a legal basis to do so.

3.

How do we process personal data?

We process your personal data only when it is necessary to achieve the purpose of the personal data processing and only to the extent necessary to achieve the purpose of the processing. Furthermore, we keep your personal data for a limited period of time and once the processing period has expired, we delete all existing copies of your personal data.

Below we have provided you with a full description of the data processing purposes, what personal data we process, legal basis of data processing and information about the retention period.

Users of the Radiacode App

Maintaining the correct operation of the App, tracking technical problems in the App, troubleshooting App problems

Processed Personal Data

  • Usage Information: information relating to use of the App, the type of device, the features you use, access times, IP address (the “Usage Information”)

  • Device Information: information about the device, including information about the device manufacture, device model, device's OS, device time zone, language of device, device OS version, device region (the “Device Information”)

Legal basis for the processing

Contract (EULA)

Data retention period

As long as you use the App and 3 years thereafter

Send technical notifications, updates, security alerts, and helpdesk and administrative messages

Processed Personal Data

  • Device Information

Legal basis for the processing

Contract (EULA)

Data retention period

As long as you use the App and 3 years thereafter

Tracking and analyzing trends, usage, and actions related to the App in order to better understand the using of the App and improve it

Processed Personal Data

  • Device Information

  • Usage Information

Legal basis for the processing

Legitimate interest:

  • your interest is to make the App fit your preferences;

  • our interest is to improve our App, to make it more user-friendly

Data retention period

As long as you use the App and 3 years thereafter

To serve advertisements, including personalized advertisements using third-party advertising networks

Processed Personal Data

  • Device Information

  • Device identifiers: online identifiers of the device, including IDFA, Google Ads ID, Google Device ID, Game Center ID, Google Play Account ID;

  • Advertisement data: ads type (e.g., interstitial / banner / rewarded); advertisement placement name; impressions count; revenue figures

Legal basis for the processing

Legitimate interest

  • your interest is in using App completely or partially for free

  • our interest is to monetize the App while providing them to you fully or partially free

and
Consent – to show personalized advertisements

Data retention period

As long as you use the App and 3 years thereafter

Registration an account for using our App and Interactive map

Processed Personal Data

  • Google ID, email address of the integrated Google account, or Apple ID, email address of the integrated Apple account

  • username

  • image / photo

Legal basis for the processing

Contract (EULA)

Data retention period

As long as you use the App and 3 years thereafter

Use of the App, its functionality (sending information about radiation level in the area)

Processed Personal Data

  • Location data (including real-time geographic location of your computer or device)

Legal basis for the processing

Contract (EULA)

Data retention period

As long as you use the App and 3 years thereafter

To consider and reply to incoming issues

Processed Personal Data

  • Email

  • Category of the issue

  • Other data that you provide in the issue and further correspondence

Legal basis for the processing

Legitimate interest

  • your interest is in receiving response to the issue;

  • our interest is in ensuring good customer service

Data retention period

1 years after the receipt of the request

Users of the RadiaVerse

Maintaining the correct operation of the RadiaVerse, tracking technical problems in the Interactive map, troubleshooting Interactive map problems

Processed Personal Data

  • Usage Information

  • Device Information

Legal basis for the processing

Contract (Terms)

Data retention period

As long as you use the RadiaVerse and 3 years thereafter

Tracking and analyzing usage, and actions related to the RadiaVerse in order to better understand the using of the RadiaVerse and improve it

Processed Personal Data

  • Device Information

  • Usage Information

Legal basis for the processing

Legitimate interest:

  • your interest is to make the RadiaVerse fit your preferences;

  • our interest is to improve our RadiaVerse, to make it more user-friendly

Data retention period

As long as you use the RadiaVerse and 3 years thereafter

Filling the interactive map with information about users' activities, publishing information in the interactive map about the radiation level in the area

Processed Personal Data

  • Username

  • Date of sending information on the radiation level in the area

Legal basis for the processing

Contract (Terms)

Data retention period

As long as you use the RadiaVerse and 3 years thereafter

To carry out promotional emails by e-mail to offer you products and service and making recommendations to you, including third-party products and offerings

Processed Personal Data

Email

Legal basis for the processing

Consent

Data retention period

As long as you use the RadiaVerse and 3 years thereafter

4.

How long do we keep your personal data?

We keep your personal data for as long as necessary to fulfill the purpose of the processing. Specific timeframes are specified in Section 3.

Under certain circumstances, we may be required to retain your personal data for a longer period of time in accordance with applicable law or regulatory requirements. This may include but is not limited to situations involving legal proceedings, investigations, or government inquiries. We will only retain your personal data for as long as necessary to comply with these legal obligations, and we will take appropriate measures to ensure its security and confidentiality during this period.

5.

Sharing your data with third parties

Your privacy is of utmost importance to us, and we handle your personal data with the highest level of care and responsibility. While we endeavor to minimize the sharing of your personal data, there are certain circumstances where it becomes necessary to disclose it to third parties.

We share your personal data in such cases:

a.

to comply with applicable law.

We are committed to complying with all applicable laws, regulations, and legal obligations. In certain situations, we may be required to disclose your personal data to comply with legal requirements, such as to respond to subpoenas, court orders, or other lawful government requests. We may also share your personal data if we believe in good faith that such disclosure is necessary to protect our rights, enforce our EULA, Terms, investigate fraud, or protect your safety.

b.

to accomplish the purposes set forth above.

In an effort to provide an exceptional experience, we work closely with a select group of trusted partners and service providers. These partners play an important role in supporting various aspects of our business, thereby enhancing the quality of the Products. When selecting the partners with whom we share your personal data, we take a cautious approach, ensuring that we only work with companies that take strict measures to protect personal data from unauthorized access, disclosure, or misuse.

Although we carefully screen our partners, it is important to recognize that we cannot guarantee absolute compliance with data protection legislation in all cases. We encourage you to review the privacy policies of these third parties to gain an understanding of their practices in processing your personal data.

a.

Hosting providers

We take responsibility for the storage of your personal data and store it only with trusted hosting providers. We use the following third parties services to store your personal data obtained through the Radiacode App and RadiaVerse:

  • Microsoft Azure (Microsoft, USA).
    You may read Microsoft’s Privacy Policy here.

  • Google Cloud (Google LLC, USA).
    You may read its Privacy Policy here.

b.

Third parties that provide support services for us to communicate with you

We try to make communication with us the most convenient way for you. Therefore, we are introducing mechanisms that help us send you questions and suggestions. We may share and disclose your personal data to the following data processor:

  • TYPEFORM, S.L. (Spain)
    You may red its Privacy Policy here.

We transfer your personal data to third parties under the requirements of the GDPR. Where possible, we always enter into Data Processing Agreements with said third parties and treat personal data transfer seriously. Where our partner has an appropriate data processing agreement in place, we may adjoin such a data processing agreement. If so, our relationship may regulate the transfer of the personal data to such partner by means of following data processing agreements:

  • Google – https://cloud.google.com/terms/data-processing-addendum;

  • Microsoft – https://www.microsoft.com/licensing/docs/view/microsoft-products-and-services-data-protection-addendum-dpa

6.

Rights under GDPR

As a data subject, you have certain rights regarding your personal information. We are committed to upholding these rights and ensuring that you can exercise them effectively.

Below, you can find the information regarding your rights as a data subject under EU legislation:

Right of access

This right allows you to request access to the personal data we hold about you.

To exercise this right, please contact us at the following e-mail address: security@radiacode.com.. Upon receiving your request, we will provide you with a copy of the personal data we process in the form in which you have requested the provision of this information. Please note that in some cases we may charge you a reasonable fee for providing this information. If we are unable to fulfill your request for any reason, we will provide you with an explanation and inform you of your rights to appeal the decision.

Right to rectification

This right enables you to request the correction or updating of any inaccurate or incomplete personal data we hold about you.

You can exercise this right in two ways:

1.

by yourself by following these steps:

  • log in to your account on the Radiacode App

  • open a personal profile on the Radiacode App

  • locate personal data you wish to correct and edit it

  • save the changes to update your data instantly

2.

by contacting us by e-mail at security@radiacode.com.

Upon receiving your request for rectification, we will review the accuracy and completeness of your personal data and make any necessary corrections or updates.

Right to erasure

This right allows you to request the deletion or destruction of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or processed (or, as we all know, the “right to be forgotten”).

You can exercise this right by contacting us at security@radiacode.com.

Upon receiving your request for erasure, we will assess whether the conditions for erasure are met and, if so, promptly delete or anonymize your personal data from our systems and notify any third parties to whom the data have been disclosed.

Also, we may delete, block or anonymize the personal data that is linked to your account in the Products in accordance with clauses 12.3 of the Terms and Conditions and 3.7 of the End User License Agreement.

Right to restrict processing

This right allows you to request the restriction of processing of your personal data in certain circumstances, such as when the processing is unlawful, when we no longer need the personal data, or when you have objected to the processing.

To exercise this right, please contact us at security@radiacode.com. Upon receiving your request to restrict processing, will not process your personal data (except for storage) unless it is based on consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

Right to data portability

This right allows you to receive a copy of your personal data in a structured, commonly used, and machine-readable format if it is technically possible to do so and to transmit those data to another controller.

To exercise this right, please contact us at security@radiacode.com. Upon receiving your request for data portability, we will provide you with a copy of your personal data in the requested format, where technically feasible.

Right to object

This right enables you to object to the processing of your personal data in certain circumstances, such as where the processing is based on legitimate interests or for direct marketing purposes.

To exercise this right, please contact us at security@radiacode.com. Upon receiving your objection to processing, we will assess the validity of your objection and, if valid, cease processing your personal data for the purposes to which you have objected.

Right to withdraw consent

You have the right to withdraw your consent to the processing of your personal data at any time. This means that if we are processing your personal data based on your consent, you have the right to revoke that consent.

To exercise this right, please contact us at security@radiacode.com. Upon receiving your request to withdraw consent if we do not have any other legal basis for processing your personal data, we will stop processing it.

Right to lodge a complaint

If you believe that our processing of your personal data violates applicable legislation, you have the right to lodge a complaint with a supervisory authority.

Please note that these rights are subject to certain limitations and exceptions as provided by law. To exercise any of these rights or for further inquiries, please contact us at at security@radiacode.com.

We will review your request as soon as possible, but not longer than one (1) month following your request. Please keep in mind that this period may be extended for an additional two (2) months, if necessary, based on the complexity and number of requests we have received. If we need to extend the response timeframe, we will tell you about the response extension within one (1) month of receipt of your request and explain the reasons for the delay.

7.

Your US State privacy rights

If you are a California resident, you have certain rights under the California Consumer Privacy Act (the “CCPA”) amended with the California Privacy Rights Act (the “CPRA”) and other applicable laws regarding the collection, use, disclosure, and sale of your personal data. This section of our Privacy Policy outlines those rights and explains how you can exercise them:

Right to know

California residents have the right to request that we disclose the categories and specific pieces of personal data that we have collected about them, the categories of sources from which the personal data was collected, the purposes for which the personal data was collected, and the categories of third parties with whom we have shared the personal data.

To exercise this right, please contact us at security@radiacode.com. Upon receiving and verifying your request, we will promptly provide you with the requested information for the 12-month period preceding your request free of charge in a readily usable format, unless an exception applies.

Right to delete

California residents have the right to request the deletion of their personal data that we have collected, subject to certain exceptions as permitted by law.

You can exercise this right by contacting us at security@radiacode.com.

Upon receiving and verifying your request, we will delete your personal data from our records and direct our partners to do the same, unless an exception applies.

Also, we may delete, block or anonymize the personal data that is linked to your account in the Products in accordance with clauses 12.3 of the Terms and Conditions and 3.7 of the End User License Agreement.

Right to opt-out

California residents have the right to opt-out of the sale of their personal data. Sale is defined broadly in the CCPA to include “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating” the personal data of California residents.

Please, note, that we do not sell personal data to third parties. As we do not sell personal data, you do not need to take any action to exercise this right.

Right to non-discrimination

California residents have the right to non-discrimination under which we cannot refuse to provide goods or Services, charge you a different price, or provide goods or Services of a different level or quality just because you exercised your rights under the CCPA.

We will not deny websites, charge different prices, or provide a different level or quality of websites based on their exercise of CCPA rights.

Right to correct

California residents have the right to ask us to correct inaccurate personal data that we have about them.

You can exercise this right in two ways:

1.

by yourself by following these steps:

  • log in to your account on the Radiacode App

  • open a personal profile on the Radiacode App

  • locate personal data you wish to correct and edit it

  • save the changes to update your data instantly

2.

by contacting us at security@radiacode.com.

Upon receiving and verifying your request, we will promptly review your personal data and make corrections as appropriate, ensuring that it is accurate and complete.

Right to limit

California residents have the right to direct us to only use your sensitive personal data for limited purposes, such as providing you with the services you requested.

We do not process such sensitive personal data.

Right of access

This right allows you to request access to the personal data we hold about you.

To exercise this right, please contact us at security@radiacode.com. Upon receiving your request, we will provide you with a copy of the personal data we process in the form in which you have requested the provision of this information. Please note that in some cases we may charge you a reasonable fee for providing this information. If we are unable to fulfill your request for any reason, we will provide you with an explanation and inform you of your rights to appeal the decision.

Right to data portability

This right allows you to receive a copy of your personal data in a structured, commonly used, and machine-readable format if it is technically possible to do so and to transmit those data to another controller.

To exercise this right, please contact us at security@radiacode.com. Upon receiving your request for data portability, we will provide you with a copy of your personal data in the requested format, where technically feasible.

Please note that these rights are subject to certain limitations and exceptions as provided by law. For the rights to deletion and correction, we have specific procedures in place to ensure their effective realization. We encourage you to first utilize the account functions available to you to modify your data or delete your account for data removal. If you encounter any difficulties or if these options are not available, please contact us directly, and we will assist you in fulfilling your request. To exercise any rights or for further inquiries, please contact us using the provided contact information.

We will respond to your request within 45 calendar days or extend that deadline by another 45 days (90 days total).

8.

Children's privacy

We do not knowingly collect or solicit your personal data to anyone under the age of 13 (in USA) or 16 (in European Economic Area) or knowingly allow such persons to use our Products. If you are under the age of 13 (or 16, where applicable), please do not provide any personal data to us. If we learn that we have collected personal data about a child under the age of 13 (or 16, where applicable), we will delete that personal data as soon as possible. If you believe that we might have any personal data from or about a child under the age of 13 (or 16, where applicable), please contact us at security@radiacode.com.

9.

Changes to the privacy policy

This Privacy Policy may be changed from time to time due to the implementation of new technologies, laws’ requirements or for other purposes. Your continued use of the Products after the effective date of the updated Privacy Policy will be subject to the new Privacy Policy. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your personal data, we will request your consent or your renewed consent (in case it was obtained previously).

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