PRIVACY POLICY

Revo Permission Analyzer

I. INTRODUCTION

“VS REVO GROUP” LTD (hereinafter referred to as “Controller”) aims to provide you with the best possible experience when using its mobile application Revo Permission Analyzer. This is why, the privacy of individuals is taken very seriously by the Controller. Therefore, this Privacy Policy applies to the use of the mobile application Revo Permission Analyzer of the Controller.

The mobile application Revo Permission Analyzer (hereinafter referred to as “The Application” or “Application”) is operated by “VS REVO GROUP” LTD, a Bulgarian company, with UIC: 200204019, having its seat registered address at: Ruse, 12 “Nikolaevska” Street, office 18. The Application is intended to be used by individuals who are at least 14 years old. By accepting this Privacy Policy, the individual declares that he/she meets these conditions.

BY USING THIS APPLICATION YOU AGREE TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA IN COMPLIANCE WITH THIS PRIVACY POLICY.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS APPLICATION AND IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY POLICY, PLEASE CONTACT US AT contact@revomobileapps.com. IF YOU DO NOT AGREE TO ANY OF THE CONDITIONS CONTAINED IN THIS PRIVACY POLICY, YOU SHOULD NOT USE THIS APPLICATION.

DATA CONTROLLER

“VS REVO GROUP” LTD (hereinafter referred to as “Controller”) is a Bulgarian company, with UIC: 200204019, having its seat and registered address at: Ruse, 12 “Nikolaevska” Street, office 18 and website: www.revomobileapps.com.

SUPERVISORY AUTHORITY

Commission for Personal Data Protection

Address: Republic of Bulgaria, Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Telephone: +3592/91-53-518; +3592/91-53-515; +3592/91-53-519
Fax: +3592/91-53-525
Е-mail: kzld@cpdp.bg
Web-site: www.cpdp.bg

II. PURPOSE AND SCOPE OF THE PRIVACY POLICY

1.1 The Controller understands the privacy concerns of the visitors to this Application (hereinafter referred to as “individuals”) regarding the protection of personal data and is committed to protect their personal data by applying all the standards for protection of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as “GDPR”). With this Privacy Policy, the Controller respects the privacy of individuals and undertakes every effort to protect the personal data of individuals against unlawful processing by applying technical and organizational measures, which measures are entirely consistent with state-of-the-art technological developments and provide a level of protection that corresponds to the risks associated with the processing and the nature of the data that should be protected.

1.2  With this Privacy Policy and in compliance with the requirements of the GDPR, the Controller provides information on:
– the purpose and scope of this Privacy Policy;
– personal data collected and processed by the Controller;
– purposes of personal data processing;
– period for which the personal data will be stored;
– mandatory and voluntary nature of provision of personal data;
– processing of personal data;
– protection of personal data;
– recipients of personal data;
– rights of individuals;
– procedure to exercise the rights.

III. DEFINITIONS

2.1 For the purposes of the GDPR and this Privacy Policy, the following terms shall have the following meaning:

1. Personal data means any information relating to an identified or identifiable natural person (‘individual’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
2. Processing of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.
4. Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
5. Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
6. Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
7. Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
8. Third party means a natural or legal person, public authority, agency or body other than the individual, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
9. Consent of the individual means any freely given, specific, informed and unambiguous indication of the individuals’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
10. Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

IV. PRINCIPLES RELATING TO PROCESSING OF PERSONAL DATA

3.1 The Controller observes the following principles relating to processing of personal data:
– The personal data are processed lawfully, fairly and in a transparent manner in relation to the individual (‘lawfulness, fairness and transparency’);
– The personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
– The personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
– The personal data are accurate and, where necessary, kept up to date (‘accuracy’);
– The personal data are kept in a form which permits identification of individuals for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’);
– The personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

V. PERSONAL DATA COLLECTED AND PROCESSED BY THE CONTROLLER

A. Processing of special categories of personal data (“sensitive data”)

4.1 The Controller does not collect and record special categories of personal data from users and visitors of the website, such as: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Individuals shall not provide such sensitive data to the Controller. If the individual negligently or intentionally provides sensitive data to the Controller, the Controller undertakes to immediately delete such data.

B. Information collected in order the Application to be used

5.1 Personal data collected directly from individuals when individuals contact the Controller by e-mail

Individuals provide personal data to the Controller when they contact the Controller by sending an e-mail. The e-mail address of the Controller is specified in the Controller’s Identification Information in this Privacy Policy. When the individual sends an e-mail to the Controller, the Controller collects and processes the the e-mail address of the individual and the other information that the individual provides in the sent message. These personal data are processed for the purpose of communication with the individual and record keeping. The processing of these personal data is necessary:

– for actions undertaken at the request of the individual, namely providing more information on the services offered by the Controller in connection with a possible conclusion of a contract with the individual.

The Controller uses the services of an e-mail service provider to store received emails on a server that is located in the Republic of Bulgaria.

5.2 Personal data collected directly from individuals when individuals subscribe to a newsletter

Individuals provide their e-mail addresses when they want to subscribe for receiving of a newsletter. When the individual subscribes to receive newsletters containing publications and useful information about the services offered by the Controller, promotional offers and the like, the Controller collects and processes the e-mail address of the individual. This data is processed for the purpose of sending of newsletters to the individual. The reason for processing of the provided personal data is the consent of the individual. The Controller uses the services of Mailjet, an independent service provider located in France, to send newsletters and manage the email list. This means that the provided e-mail addresses will be stored on the servers of Mailjet. Mailjet has its own Privacy Policy and individuals are advised to get acquainted with it in order to get more information. Mailjet’s Privacy Policy is posted at https://www.mailjet.com/privacy-policy/.

5.3 Information collected when the individual uses the Application

The Controller does not collect any other personal data except this specified in items 5.1 and 5.2 on this Privacy policy. However, when individuals download and use the Application the following information about the use of the Application is collected and processed:

- for how long the Application has been installed on a device without being collected information about the individual who owns the device;

- information about the installed applications on the respective device without being collected information about the individual who owns the device;

The collection and processing of this personal data is necessary for the realization of the legitimate interests of the Controller, which legitimate interests are to facilitate the use of the Application and to improve the functionality of the Application.

5.4 The Controller may request access or permission to certain features from the mobile device of the individual. Examples of such features are the mobile device’s camera, microphone, reminders, sensors, contacts, social media accounts, storage and other features. If the individual wishes to change the access or permissions of the Controller, this can be done in the individual’s device settings.

5.5 The Controller may also collect information about the device of the individual like mobile device ID number, manufacturer, model, version of the operating system, phone number, country, location, as well as any other information the infividual wishes to provide.

5.6 The Controller may also collect information from third parties. Examples of such information is personal information or network friends, in case the individual connects his/her account to the third party and grant the Applications permission the information to be accessed.

5.7 The Controller may request the individual a permission for sending of push notifications regarding the account or the Applications. In case the individual wishes to opt-out from receiving these types of communications, the individual can at any time turn them off in the device’s settings.

5.8 The Application contains hyperlinks that redirect individuals to external sources. Individuals shall be informed that this Privacy policy does not cover hyperlinks in the Application that redirect individuals to external sources.

5.9 The payment is made through the Google Play system and the Controller does not collect any information regarding the payment made by the individual. The individual shall be informed that part of the payment information is stored by Google Payments, therefore the individuals are advised to read the Privacy policy of Google at: https://www.google.com/policies/privacy/.

C. Data collected automatically

6.1 When an individual uses the Application, the Controller automatically collects the following data, namely:

– The type of device from which the individual accesses the Application (for example, a mobile phone, a tablet, etc.);

– Frequency and duration of using of the Application, but not the concrete actions by using of the Application;

– Date and time of use of the Application;

The collection and processing of this personal data is necessary for the realization of the legitimate interests of the Controller, which legitimate interests are to facilitate the use of the Application and to improve the functionality of the Application.

6.2 Ads: The Controller has the right to disclose non-personal data to third parties. The Controller has also the right to allow third parties to collect non-personal data through their own embedded technology. The third-party advertising companies may place cookies, anonymous identifiers or similar technology for non-personally identifiable information for the purpose of delivering of ads. For more information, individuals are advised to read the Privacy policy of Google at: https://www.google.com/policies/privacy/.

VI. LEGAL BASIS FOR PERSONAL DATA PROCESSING:

7.1 The legal basis for collecting processing of the personal data of individuals in most of the cases is one of the following:

- for the realization of the legitimate interests of the Controller such as understanding how individuals use the Application in order to improve the Application. In this case the Controller ensures that the legitimate interests of the Controller are not overridden by the interests of individuals or fundamental rights and freedoms.

- for fulfilling the contractual relationship like providing services;

- for actions undertaken at the request of the individual in connection with a possible conclusion of a contract with the individual;

- consent when the Controller sends a newsletter to the individual who has subscribed for receiving a newsletter.

VII. PURPOSES OF THE PROCESSED INFORMATION

8.1 The Controller collects and processes the information described in chapter V of the Privacy policy for the following purposes, namely:

– to provide the services that the Controller offers;

– to contact the individual via e-mail in order to respond to the received inquiries;

– for the execution of an obligation of the Controller, stipulated by law;

- for sending newsletters containing publications and useful information about the services offered by the Controller, promotional offers and the like. Newsletters are sent only after the Controller has received an explicit consent of the individual;

– statistical purposes.

8.2 The Controller collects and processes the personal data of individuals who are automatically collected for the following purposes, namely:

– improving the efficiency and functionality of the Application;

– preparing anonymous statistics on how the Application has been used;

- to provide a better service;

- to administer the Application.

The Controller may not use the personal data of individuals for purposes other than those specified in this section of this Privacy Policy.

VIII. PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

A. Period for which the personal data will be stored

9.1 Inquiries and correspondence by email: The Controller stores the personal data and the communication received by e-mail for a period necessary to answer to the received message and to satisfy individual’s request, as well as for one calendar year after the Controller has answered to the received message and satisfied individual’s request.

9.2 Newsletter mailing list: The Controller stores the personal data provided for newsletter subscription, which is the e-mail of the individual, until the individual remains subscribed for receiving of newsletters or until the Provider ceases sending newsletters, whichever of the two circumstances comes first.

B. Criteria for determining the period for which the personal data will be stored

9.3 In other situations, not specified above, the Controller will store the personal data of the individual for no longer than needed considering the following criteria, namely: - if the Controller is obliged by a legal norm to continue with the processing of the personal data of the individual; - purpose for storing of the personal data both currently and in the future; - purposes for using of the personal data currently and in the future; - if it is necessary to contact the individual in the future; - if the Controller has any legal ground to continue to process the personal data of the individual; - any other sufficient grounds, like the character of the relationship with the individual.

9.4 Unless otherwise specified, the Controller retains information as long as it is necessary to achieve the purpose described above.

IX. MANDATORY AND VOLUNTARY NATURE OF PROVISION OF PERSONAL DATA

10.1 The personal data required to be provided by the individuals are in accordance with the services offered by the Controller. The provision of personal data by individuals is voluntary. In the event that the individual refuses to provide the personal data:
- the individual will not be able to contact the Controller;
- the individual will not receive a newsletter.

X. PROCESSING OF PERSONAL DATA

11.1 The Controller processes the personal data of individuals by means of a set of actions that can be performed by automatic or non-automatic means.

XI. PROTECTION OF PERSONAL DATA

12.1 The Controller undertakes the appropriate technical and organizational measures to protect the personal data against accidental or unlawful destruction, or against accidental loss, unauthorized access, alteration or dissemination, as well as against other unlawful forms of processing, including the following:
– using only secure and protected servers and folders for storing of the personal data;
– verifying and confirming the identification of the individual inquiring access to his/her personal data before granting access to such personal data;
- The Controller provides individuals with a secure and encrypted connection when sending personal data;
- The Controller never sends correspondence, including electronically, requiring a user name and password to access the individual's profile.

12.2 In case you would like to receive detailed information about the technical and organizational measures, please do not hesitate to contact us at contact@revomobileapps.com.

XII. RECIPIENTS OF PERSONAL DATA

13.1 The Controller does not share the personal data of individuals publicly.

13.2 The Controller has the right to disclose the personal data processed only to the following categories of persons, namely:

• to Individuals to whom the data relate when they exercise the right of access the personal data relating to him/her.

13.3 The Controller does not sell personal data provided by the individual to third parties.

XIII. RIGHTS OF INDIVIDUALS

Right of access by the individual:

14.1 The individual has the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed. If the Controller processes personal data of the individual the Controller shall provide a copy of the personal data undergoing processing.

Right to rectification:

14.2 The individual has the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the individual has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (‘right to be forgotten’):

14.3 The individual has the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay and the Controller has the obligation to erase personal data without undue delay where one of the stated in article 17 of the GDPR grounds applies.

Right to restriction of processing:

14.4 The individual has the right to obtain from the Controller restriction of processing where one of the stated in article 18 of the GDPR grounds applies. If the processing has been restricted, such personal data shall, with the exception of storage, only be processed with the individual’s 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 of the Union or of a Member State. The Controller informs the individual who has obtained restriction of processing before the restriction of processing is lifted.

Right to data portability:

14.5 The individual has the right to receive the personal data concerning him or her, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller without hindrance from the Provided to which the personal data have been provided, if the processing is based on consent or on a contract.

Right to object:

14.6 The individual has the right to object on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. According to Article 21, Paragraph 4 of the GDPR the right to object shall be explicitly brought to the attention of the individual and shall be presented clearly and separately from any other information. For compliance of this obligation, more information about the right to object, can be found in the section below titled “Right to object to processing of personal data”.

Right of withdrawal of consent:

14.7 The individual has the right at any time to withdraw the consent he has given. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. The order for withdrawal of the consent is specified in Section XIV of this privacy policy. The individual may either withdraw the given consent by choosing the "unsubscribe" option when receiving a newsletter.

Profiling rights:

14.8 The individual has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

Right to be informed about the personal data breach:

14.9 The individual has the right to be informed without undue delay about the personal data breach when the personal data breach is likely to result in a high risk to the rights and freedoms of individual.

Right to judicial and administrative protection:

– Right to lodge a complaint with a supervisory authority

14.10 Without prejudice to any other administrative or judicial remedy, the individual has the right to lodge a complaint with the supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the individual considers that the processing of personal data relating to him or her infringes the GDPR.

– Right to an effective judicial remedy against a supervisory authority

14.11 Without prejudice to any other administrative or non-judicial remedy, the individual or legal person has the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them. Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.

– Right to an effective judicial remedy against the Controller or processor

14.12 Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority, the individual has the right to an effective judicial remedy where he or she considers that his or her rights under the GDPR have been infringed as a result of the processing of his or her personal data in non-compliance with the GDPR. Proceedings against the Controller or a processor shall be brought before the courts of the Member State where the Controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the individual has his or her habitual residence.

Right to compensation and liability:

14.13 Individual who has suffered material or non-material damage as a result of an infringement of the GDPR has the right to receive compensation from the Controller or processor for the damage suffered. Court proceedings for exercising the right to receive compensation shall be brought before the courts of the Member State where the Controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the individual has his or her habitual residence.

XIV. PROCEDURE TO EXERCISE THE RIGHTS

15.1 The individual exercises his or her right to withdraw the given consent, right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object and profiling rights, by submitting a written request to the Controller (either by post at the address specified in the identification of the Controller above or by e-mail), which should contain the following information:

1. the name, address, and other data necessary for identifying the respective individual;
2. a description of the request;
3. signature, date of submission of the request and e-mail address.

15.2 The request shall be filed personally by the individual. The Controller keeps the requests filed by the individuals in a separate register.

15.3 When the individual exercises the right of access to the personal data relating to him or her the Controller shall verify the identity of the individual before responding to the request. This is necessary to minimize the risk of unauthorized access and identity theft. If the Controller cannot identify the individual from the collected information, then the Controller has the right to require a copy of individual’s documentation (such as ID card, driving license, other documents containing personal data that identify the individual) in order to verify the individual’s identity.

15.4 The Controller considers the request and provides the information on action taken on the request of the individual within two months of receipt of the request. This period may be extended by one further month where necessary, taking into account the complexity and number of the requests.

15.5 The Controller informs the individual of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the individual makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the individual.

15.6 In case the Controller does not take action on the request of the individual, the Controller informs the individual without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

15.7 The Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller informs the individual about those recipients if the individual requests it.

XV. RIGHT TO OBJECT TO PROCESSING OF PERSONAL DATA

16.1 The individual has the right to object on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. According to Article 21, Paragraph 4 of the GDPR the right to object shall be explicitly brought to the attention of the individual and shall be presented clearly and separately from any other information. For compliance of this obligation, more information about the right to object, will be provided in this section of the Privacy Policy.

16.2 The individual has the right to object on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller or processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual which require protection of personal data, in particular where the individual is a child, including profiling based on any of these provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the individual or for the establishment, exercise or defense of legal claims. The individual can exercise this right by submitting a written request to the Controller, either by post at the address specified in the identification of the Controller above or by e-mail.

16.3 Where personal data are processed for direct marketing purposes, the individual has the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the individual objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. The individual can exercise this right by submitting a written request to the Controller, either by post at the address specified in the identification of the Controller above or by e-mail requiring to stop sending him or her marketing information or by clicking the unsubscribe link contained at the bottom of the e-mail the Controller sends to the individual.

XVI. THIRD PARTIES SERVICE PROVIDERS

17.1 The Application uses third party services, which may collect information used to identify the individual. These third parties have their own Privacy Policies and it is recommended that individuals familiarize themselves with the relevant Privacy Policy of the respective company for more information.

Such third parties are:

Google Play Services

Analytics

- Google Analytics for Firebase (Google LLC)

Hosting and backend infrastructure

- Firebase Cloud Storage (Google LLC)

Infrastructure monitoring

- Firebase Performance Monitoring (Google LLC)

- Firebase Crash Reporting (Google Inc.)

- Firebase Crashlitycs

Managing contacts and sending messages

- Firebase Cloud Messaging (Google Inc.)

- Firebase Notifications (Google LLC)

Registration and authentication

- Firebase Authentication (Google Inc.)

- Google OAuth (Google Inc.)

XVII. CHANGES TO THE PRIVACY POLICY

18.1 This Privacy Policy may be updated at any time in the future. When this happens, the Controller will notify the individuals. It is therefore advisable to carefully read such notice to make sure that you are familiar with any changes of the Privacy Policy. Using the Application after publishing or sending a notice about the updated Privacy Policy, means that you will be deemed to agree with the changes made.

XVIII. CONTACTS

19.1 If you have additional questions about this Privacy Policy, please do not hesitate to contact the Controller at: contact@revomobileapps.com.