Effective date: May 25, 2018

General

Terracom S.A. (hereinafter “Terracom”), the developer of SpotyPal, is firmly committed to the privacy of its customers. Terracom shall take all reasonable measures to have your personal information protected to ensure you feel safe and secure.

This Privacy Policy covers how Terracom uses personal information that users provide to Terracom when they use Terracom’s open tracking system SpotyPal. By using any of the SpotyPal services you accept the terms of our Privacy Policy.

The way we collect and use your information

The information that SpotyPal collects about you can be classified as Personal Information and Anonymous Information. Personal Information refers to information that identifies you as a person, for example, your name, email address, phone number etc. Anonymous Information refers to information that does not identify a specific individual.

Personal information

Contact form

We collect your Personal Information (Name, Company, Country, State -In case of USA- and Phone number) to respond to your inquiry or request, and to send updates or notices about the Service.

Orders: Contact and Payment Information

We collect your email address, your name, postal and billing address, phone number and other billing information (VAT / Tax ID) for invoicing.

We may use your Personal Information to respond to an email or other inquiry or request, to help improve the service, to customize your experience at the Websites or to send updates or notices about the service. We also use your Personal Information to bill you for your purchase. The billing is performed by the third-party billing service PayPal securing your sensitive financial and billing information.

Registering for the Mobile App

You will have to provide a valid email address and a password in order to create an account for the SpotyPal system. You can also add your First and Last name, phone number and photo. You are responsible for keeping the secrecy of your password. We do not identify you personally to other users and we do not make your account information available to third parties in any way that could identify you without your prior consent.

Usage of Mobile App

We collect information about your phone’s model, operating system type, and version. This information will be used to provide you with the best services and support.

SpotyPal Device information

When you activate your SpotyPal device using the SpotyPal app, its unique identifier and name will be associated with your account.

Location Information

Our system is designed to help you find your lost items. It is necessary to collect data about the location of your phone and SpotyPal device in order to provide you information about where your items are. While the app is running on your phone, it periodically transmits information about your location. This allows us to show you the place where your SpotyPal device was last seen, and this way help you find it. We will never share information about your location with other users unless you choose to share it through our services. We may also collect and update location information for your SpotyPal device completely anonymously from other SpotyPal users who are running the app within Bluetooth range of your SpotyPal device. This is done in order to provide you information about those SpotyPal devices, which have been reported lost by you. The location information associated with your SpotyPal device is never made available to these users.

Your data protection rights

In accordance with the European General Data Protection Regulation 2016/679 (GDPR) you have a right of access, correction, removal of your personal data which you may exercise or receiving them in a structured, commonly used and machine-readable format, or withdraw your consent at any time by sending us a support ticket at https://www.spotypal.com/contact. Your requests will be processed within 30 days.

You are also able at any time to modify personal data by logging into your account and clicking on “Edit”.

Data Retention, account deactivation and deletion

We store data to our databases for as long as a client is active and for a period of 10 years after the deactivation of the client’s account. However, the time period of the data storage may be a case-by-case determination that depends on things such as the nature of the data, the legal framework of the client’s country and the reason why it is collected and processed.

Anonymous information

Websites visits

Every time you visit the Websites, Terracom collects certain technical information from your Web browser. It includes the pages that were visited and returned to, the time spent on the Terracom website (www.spotypal.com) by a visitor, the operating system, the Web browser version, the referring site and any keywords used to find the Websites on search engines. This information does not contain any reference to the personal information. This information can only be accessed by Terracom and can be used with the sole purpose of tracking visits to the Websites and improve the experience, content and layout of the Websites. Using the anonymous information, Terracom can also identify defects in the service and thus continually improve the quality of the service.

Cookies

Terracom may automatically collect some information through the use of cookies. A cookie is a small data file that is stored on a user’s computer to enable the service to recognize a user that previously used the service. Terracom uses information collected from cookies to track the pages of the Websites that our users view, the browsers they use, the devices they logged in from (tablet, desktop, etc) and other information about user activity when visiting the Websites.

Terracom implements Remarketing campaigns with Google Analytics for Display Advertising online. Terracom and the third-party vendors, including Google Inc., use the first-party cookies (such as the Google Analytics or Google AdWords remarketing cookie) to inform, optimize, and serve ads based on a person’s past visits to the Websites. As a result, Terracom ads shall be displayed on the sites across the Web. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager.

Facebook Connect & Google+ Log-in

You can sign up or log in to our mobile and web app using sign-in services such as Facebook Connect and Google+ Log-in. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.

Services like Facebook Connect and Google+ Log-in give you the option to post information about your activities on mobile app or e-shop to your profile page to share with others within your network. We offer social sharing features, like Share button to Facebook, Twitter and Instagram, that let you share content or actions you take on our Services. Your use of these features enables the sharing of certain information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these social sharing features.

The way we share your information

Privacy of our users is very important for Terracom. We shall not disclose, sell or rent your Personal Information to any third party for marketing purposes. We shall share your Personal Information with the third parties only if you instruct us to and only if such information is required to provide you with specific services.

Like other companies, we may disclose your Personal Information, including Location information, to government or law enforcement officials when necessary to comply with a law, regulation, or legal request; to investigate fraud or other illegal activities; to protect our rights, our property and our users.

We shall use a PayPal to bill our users for subscriptions and other fees. These third parties shall not retain, share or store any Personal Information except to provide these services and shall be bound by strict confidentiality agreements, which limit their use of such information.

We might use your Personal information, including Location information, to create anonymous statistical data reports in order to improve the quality of the services we provide you.

How we protect your information

Terracom shall use all and every commercially reasonable physical, managerial and technical safeguard to preserve the integrity and security of your Personal Information. We cannot warrant the security of any information you provide in the service and you do so at your own risk. Once we received any information from you, Terracom shall make all and every commercially reasonable effort to ensure the security of our systems. Please note that this is not a guarantee that unauthorized entry or use, hardware or software failure and other factors that may at any time compromise the security of user information, will not happen.

E-mail communication

Terracom is committed to keeping your email address confidential. We shall never sell, rent or lease our user email lists or otherwise disclose the user email addresses to any third party. We shall use our users’ email addresses exclusively to communicate Terracom information to them. We respect your attention and time so we shall limit the frequency of our mailings to a reasonable amount.

We collect e-mails in our website via opt-in forms. By submitting your e-mail address to an opt-in form, you will receive notification regarding any system update, pricing plans offers, company’s participation in exhibitions and events or crucial system interruptions.

Terracom administrative and service announcements

Terracom shall automatically email administrative messages such as “Thank you” messages, welcome messages or other messages introducing users to the Terracom products and services, responses to password recovery, password and email change requests and similar explanatory messages that are necessary for user guidance. Users cannot opt-out from these emails.

Terracom may email you service announcements such as day and time of expected interruptions of services, change of prices or service specifications. These emails have no opt-out status either.

Changes in our Privacy Policy

Your use of the services, including any dispute concerning privacy, is subject to this Privacy Policy, Terracom Terms of Use. Terracom reserves the right to modify this Privacy Policy from time to time and such modifications shall be effective upon posting them on the Website. You agree to be bound by any changes to this Privacy Policy when you use the services after any such modification is posted. It is, therefore, important that you review this Privacy Policy regularly to ensure you are updated of any changes.

Dispute resolving

Exclusive competent Court for dispute solving that may arise from the application of this agreement is the court of Ioannina, Greece.

Contact Terracom

If you have any questions or comments about our Privacy Policy please contact us at: info(at)spotypal(dot)com or you can email SpotyPal’s Data Protection Officer directly at: privacy(at)terracom(dot)gr or by mail to: Terracom S.A., Attn: Data Protection Officer, Thesi Ntousia, Mpafra, Zip: 45500 Greece.