STRADDLE PRIVACY POLICY

 

v0.1 Last updated 02/02/2023

 

WHAT IS STRADDLE?

It is the software application (Straddle or Application) for mobile devices. The Application is a tool to organize your debts and credits with your friends. You can add people from your phone book and keep records of all your money exchanges with them inside the Application. The Application will provide a useful summary of your debts and credits with easily accessible functionality - repay debt, close debt, debt reminders and status changes. 

STRADDLE LLC – THE CONTROLLER] (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile Application.   

Please read this Privacy Policy carefully.  

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION. 

IN ORDER TO USE THE APPLICATION, YOU MUST FIRST ACKNOWLEDGE AND AGREE TO OUR PRIVACY POLICY. 

YOU CANNOT USE THE APPLICATION WITHOUT FIRST ACCEPTING OUR PRIVACY POLICY.

 

 

DEFINITIONS

 

PERSONAL DATA: data about a living individual who can be identified from those data (or from those and other information either in our possession or likely into our possession).

AUTOMATICALLY COLLECTED DATA: data collected automatically either generated by the use of the Application or from the Application itself.

DATA CONTROLLER: a natural or legal person who (either alone or in common with the other persons) determines the purpose for which and the manner in which any personal data are, or able to be, processed. For the purpose of this Privacy Policy, we are Data Controller of your data.

DATA PROCESSOR (SERVICE PROVIDERS): any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively. 

DATA SUBJECT: any living individual who is the subject of Personal Data. 

USER: any individual using our Application. The User corresponds to Data Subject, who is the subject of Personal Data.

 

 

• COLLECTION OF YOUR INFORMATION

 

We may collect information about you in a variety of ways. The information we may collect via the Application includes:  

 

Personal data 

Personally identifiable information 

• Contact information (e.g. your name, surname, e-mail address, mobile telephone number);

• The profile data such as your profile picture (photo);

 

Financial data 

We may collect financial information, such as debts and credits and operations such as transaction identifiers with them between other users of Application, the status of changes and summary information.

We don’t collect data related to your credit card.

The Application does not charge any real money from the user.

 

Data from social networks  

The Application may not access your User information from social networking sites, such as Facebook, Google+ Instagram, Pinterest, Twitter ets., including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts.

 

Geo-location information 

This Application does not collect precise information about the location of your mobile device.

 

Mobile device access (camera, contacts, reminders)

We may request access or permission to certain features from your mobile device, including your mobile device’s (camera, contacts, reminders). The application uses camera/photo permission to upload users avatar and shows it in debts concerning the user.

The Application uses contact access permission in order to view users contacts while creating new debt. This allows you to create a debt on your contact name instead of exact telephone number.

If you wish to change our access or permissions, you may do so in your device’s settings.

 

Mobile device data 

Application may collect certain information automatically:

device information such as but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.

 

Push-notifications 

We may request to send you push-notifications  in order to send updates and reminders regarding debt status changes. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

 

Third-party data 

We don’t collect the information from third parties, such as personal information about your friends, if you connect their accounts/contacts from your phone book.

 

 

• USE OF YOUR INFORMATION

 

We use the collected data for various purposes:

• To provide and maintain our service;

• To notify you about changes to the Application, any products or services we offer or provide though it;

• To provide user support;

• To provide you with information or services that you request from us;

• To carry out our obligations and enforce our rights arising from any contracts;

• To gather analysis or valuable information to improve the Application;

• To monitor the usage of our Application;

• To detect, prevent and address technical issues;

• To provide you with news, special offers and general information about services we offer unless you have opted not to receive such information;

• For any other purpose with your consent.

• In any other way we may describe when you provide the information (such as it is described in this Privacy Policy);

 

 

• DISCLOSURE OF YOUR INFORMATION

 

We may share information we have collected about you in certain situations. Your information (provided by you and automatically collected) may be disclosed as follows: 

 

By Law or to protect rights 

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and other criminal actions.

 

Third-party service providers 

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service and marketing assistance. These people have entered into confidentiality agreements prior to having been granted access to your Personal Data.

In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, we are required by law to notify you if the breach is likely to affect your privacy.

 

Marketing communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

 

Interactions with other users 

If you interact with other users of the Application, those users may see your name, profile photo, telephone number. Descriptions of your activity in Application is not disclosed. 

 

Affiliates 

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

 

Business partners 

We may share your information with our business partners to offer you certain products, services or promotions in which case we will require our business partners to honor this Privacy Policy. 

 

Other third parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law in which case we will require our advertisers and investors to honor this Privacy Policy. 

 

Sale or bankruptcy 

If we reorganize or sell all or a portion of our assets, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.  You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy. 

 

Other cases

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of STRADDLE, our customers, or others.

We are not responsible for the actions of third parties with whom you share personal data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly. 

 

 

• YOUR RIGHTS

 

Right of access 

If you are concerned or have any questions about your Personal Data, you have the right to request access to the Personal Data which we hold or process about you. We will then provide you with information about the data that are being processed and on the source of those data.

 

Right of rectification and right of erasure 

You have the right to request us free of charge to correct, erase or block any inaccuracies in your Personal Data if such Personal Data would be incomplete, inaccurate or processed unlawfully.

 

Right to not be subject to automatized individual decision making 

You have the right to request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

 

Right to object to data processing 

You may withdraw at any time your consent to the processing of your Personal Data by STRADDLE by permanently removing the Application and notifying us in writing thereof via email provided below. 

You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. 

Upon receipt of this notification, we shall promptly stop any processing of your Personal Data. You may also ask us to stop using your Personal Data for direct marketing purposes.

To exercise your abovementioned rights or any other questions concerning this Privacy Policy, please contact us by e-mail on the address below. We will undertake the necessary action without undue delay and provide information on action taken within 30 days.

 

 

• WEBSITE ANALYTICS 

 

We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Application to analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors for the indicated purposes. We do not transfer personal information to these third-party vendors.

 

 

• SECURITY OF YOUR INFORMATION

 

We use administrative, technical, and physical security measures to help protect your personal information. The security of your data is important for us. 

While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party. 

 

 

• POLICY FOR CHILDREN

 

We do not knowingly solicit information from or market to children under the age of 18. If you become aware of any data we have collected from children under age 18, please contact us using the contact information provided below. 

If you are a parent or guardian and you are aware that your children has provided us with Personal Data, please email us immediately at email provided below. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information.

 

 

• OPTIONS REGARDING YOUR INFORMATION

 

You may at any time review or change the information in your account in Application by logging into your account settings and updating your account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations during the period of time that is logically necessary to achieve such goals.

 

 

• CALIFORNIA PRIVACY RIGHTS

 

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

 

YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

 

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. 

If you wish to be informed what the Personal Data we hold about you and if you want it to be removed from our system, please email us at email provided below.

 

DATA RETENTION AND DELETION

 

We may retain information regarding you and your use of the Application, including Personal Data, for as long as reasonably needed to provide you with the services of Application and the uses described in this Privacy Policy.

Please note that we retain your Personal Data even if you temporarily stop using the Application until you permanently delete the Application on your mobile device and notify us thereof. Upon notification, we may retain, continue to use and disclosure your Personal Data to Third Parties exclusively on a fully anonymized basis.

 

 

CONTROLS FOR DO-NOT-TRACK FEATURES  

 

Some mobile operating systems (and mobile applications) include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.  

 

 

CHANGES TO OUR PRIVACY POLICY

 

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last updated” date of this Privacy Policy.  You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.  

 

 

EMAILS AND COMMUNICATIONS

 

If you no longer wish to receive emails or other communications from us, you may opt-out by contacting us using the contact information provided below.

 

 

CONTACT US

 

If you have questions or comments about this Privacy Policy, please contact us at:

 

STRADDLE LLC

610 W Broadway

Suite 201

Jackson, WY 83001

Phone Number +13076998966

Email: app.straddle@gmail.com