Privacy Policy

Last Updated: June 23, 2022

Introduction

This privacy policy (“Policy”) describes how Mjav Consultancy Ltd (“Company,” “we,” “our,” and “Controller”)) processes, collects, uses and shares personal data when using the PRIFIR app (the “app”). Please read the following information carefully to understand our practices regarding your personal data and how we will process data.

What is personal data?

We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation, this includes any information which, either alone or in combination with other information we process about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

Processing Your Personal Data

Information from Social Networking apps.

Our app includes interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our app, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Automated Decision Making and Profiling.

We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.

We may use your personal data as follows:

• to operate, maintain, and improve our app, products, and services;
• to manage your account, including to communicate with you regarding your account, if you have an account on our app;
• to operate and administer our rewards program and other promotions you participate in on our app;
• to respond to your comments and questions and to provide customer service;
• to send information including technical notices, updates, security alerts, and support and administrative messages;
• with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
• to process payments you make via our app;
• as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others;
• for analysis and study services; and
• as described in the “Sharing of your Personal Data” section below.

Third-Party Processing

Our app may contain links to third party apps and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their apps, features or policies. Please read their privacy policies before you submit any data to them. Links can be found below.

https://www.pubnub.com/legal/privacy-policy/ https://virgilsecurity.com/privacy-policy/ https://aws.amazon.com/compliance/gdpr-center/ https://www.apple.com/legal/privacy/en-ww/ https://play.google.com/about/developer-content-policy/

User Generated Content

You may share personal data with us when you submit user generated content to ourapp.Please note that any information you post or disclose on our app will be available to other users of our app .We urge you to be very careful when deciding to disclose your personal data, or anyother information, on our app. Such personal data and other information will not be private or confidential once it is published on our app.

If you provide feedback to us, we may use and disclose such feedback on our app, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your feedback on our app. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.

International Data Transfer

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By accepting this Policy, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

Security

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.

Retention

We will only retain your personal data as long as reasonably required for you to use the app until you close your account/cancel your subscription unless a longer retention period is required or permitted by law (for example for regulatory purposes).

Our Policy on Children

Our app is/are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

Your Rights

• Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the app may be ineffective upon opt-out.
• Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
• Amend. You can also contact us to update or correct any inaccuracies in your personal data.
• Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
• Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Complaints

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us through the information listed on our app. We will reply to your complaint as soon as we can and in any event, within 30 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.

Contact Information

We welcome your comments or questions about this Policy. You may contact us in writing or through our app.

Miss A Parr-Dobrzanski

MJAV Consultancy LTD 
405 Hatfield Road 
St Albans 
Hertfordshire 
AL4 0XP

info@mjav-consultancy.co.uk