Date: Mar 15, 2024
TABLE OF CONTENTS
1. PURPOSE OF THIS POLICY2. CONTACT DETAILS
3. CONTROLLER
4. PRIVACY POLICY
5. THE DATA WE COLLECT
6. HOW IS YOUR PERSONAL DATA COLLECTED
7. PURPOSES FOR WICH WE WILL USE YOUR PERSONAL DATA
8. DATA SHARING
9. INTERNATIONAL TRANSFERS
10. RETENTION PERIOD
11. YOUR LEGAL RIGHTS
12. SAFETY MEASURES
1. PURPOSE OF THIS POLICY
1.1. This Privacy Policy sets out how we collect and use your personal information when you use the Canyon Life Application (the “App”),and the choices available to you in relation to the use of your personal information (the “Privacy Policy”). This Privacy Policy should be read in conjunction with our Terms and Conditions (the “Terms”).This Policy is designed to help you understand our privacy practices, including what personal data we collect, why we collect it, what we do with it and how we protect it, as well as your individual rights. It also describes how you may contact us to learn more about our data practices or to exercise your rights.
1.2. It is important that any data we collect, and store is accurate. Therefore, if anything changes regarding your personal data during your relationship with us, please keep us informed.
1.3. We may change this Policy from time to time, to reflect how we are processing your data, and if we make changes, we will notify you by revising the effective date at the top of this Policy. If we make significant changes that materially affect your privacy rights, we will provide advanced notice and make that clear on the App, or by some other means of contact such as email, so that you are able to review the changes before you continue using the services. If you do not agree with the modified Policy, please discontinue the use of the services or do not consent to the updates.
1.4. If you have any questions about this privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
2. CONTACT DETAILS
1 Iapetou, Agios Athanasios, 4101, Limassol, CyprusContact Us - Canyon
dpo@asbis.com – Data Protection Officer
3. CONTROLLER
3.1. ASBISC ENTERPRISES PLC, a company registered under the legislation of the Republic of Cyprus, with registered number HE 75069, registered address: 1 Iapetou,4101, Agios Athanasios, Limassol, Cyprus (the “Company”, “We”, “Us” “Our”) and its affiliated companies, are the Data Controllers and responsible for your personal data. For the purposes of this policy an affiliated company, means an entity which, directly or indirectly, owns or controls, is owned or is controlled by or is under common ownership or control with another entity or Canyon brand or products. As used herein, “control” means the power to direct the management or affairs of an entity, and “ownership” means the beneficial ownership of fifty percent (50%) or more of the voting equity securities or other equivalent voting interests of the entity.4. PRIVACY POLICY
4.1. In making the App available to you, we act reasonably and believe that:you have all necessary rights to register and use the App.
If the product is going to be used by children under the age of 14, parents’ consent is required.
provide true information about yourself to the extent necessary to use the App services.
you understand that by posting your personal information you have apparently made that information public and that information may become available to the Company.
you understand that certain types of information transmitted by you to other users of the App cannot be deleted by you or the Company.
4.2. We do not review the user information we receive from you unless such review is necessary for the Company to fulfil its obligations to you.
4.3. This Privacy Policy applies to EU citizens only.
5. THE DATA WE COLLECT
5.1 When using the term “Personal Data” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. We collect, use, store and transfer different kinds of personal data grouped together as follows:a) Identity Data
Includes: name, middle name, last name, moniker of user or similar identifiers
b) Contact Data
Includes: email address, mobile phone number, phone moniker, phone’s contact information, emergency numbers
c) Location Data
Includes: exact location information, location information history, safety zone location
d) Account Data:
Includes: age, gender, password to control the device, general device settings, chat history sound recordings.
e) Marketing and Communication Data
Includes: your preferences in receiving marketing from us, related to our products: AENO, Canyon, Prestigio, Perenio, Lorgar and Prestigio Solutions, from third parties related to us and your communication preferences.
f) Technical Data
Includes: IP address, your installed applications, your behavior when using our App or when you provide us with your feedback e.g., rating , Store ID number.
g) Special Category Data
Includes: health data such as, pulse history, weight, height, steps history, sleep history, training history, blood oxygen history, temperature history, ecg history.
h) Usage Data
Includes: information on how you use our App products, and services.
i) Aggregated Data
Includes: We collect, use, and share Aggregated Data. This kind of data, result from processing personal data for statistical purposes (output data).
6. HOW IS YOUR PERSONAL DATA COLLECTED
6.1 We collect your data through different methods:| Methodology | |
|---|---|
| 1.Direct interactions | You provide us with your Identity, Contact data, Location data, Account data and Special category data. This includes personal data you provide when you: - set up the App - consent to receive marketing material |
| 2. Automated technologies or interactions | When you interact with our app, we automatically collect Technical Data. |
7. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
7.1. We use your personal information to perform the contract between you and us.7.2. We use your personal information to provide you with access to the app, to provide functionality, analyze performance, correct errors, and improve the usability and effectiveness of the App.
7.3. We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. Where you consent to the processing of your personal data for a specific purpose, you may withdraw your consent at any time by contacting us and we will stop processing your data for that purpose.
7.4. We process personal information to comply with laws and/or to prevent and detect fraud and abuse in order to protect the safety of our customers, app and others.
7.5. We describe in more detail and in addition to the aforementioned purposes the information we collect when you use our application services, why we collect and process it and the following legal bases.
| Purpose/ Activity | Type of data | Legal basis for processing |
|---|---|---|
| We use these data so we can provide our services to you and for the proper functionality of the App. We also use this information to create, customize and improve the services presented on the App. |
Identity data Contact data Location data Account data Technical data Special Category data |
1)Performance of our contract with you. 2)Consent for Special category data |
| We use these data in order to delete your account upon your request. | Contact data such as email. | Performance of our contract with you |
| We use this data to verify your account and prevent abuse and violation of your or others' rights. For example, we use this information to verify your identity if you lose your credentials and wish to access your account. | Contact data such as email. Technical data such as IP address. We may also request invoice or receipt or device box photo or device label. |
Performance of our contract with you |
| We use these data for internal review in order to continuously improve our App content, understand any errors you may encounter while using the App, notify you of changes, and personalize your use of the App. | Technical data | Legitimate interest |
| We use this information to verify your identity and fulfil your support request. We may also use this data to investigate any complaints you may have and provide you with a more efficient service | Information generated by you when submitting requests to the website’s support service. | Performance of our contract with you Legitimate interest |
| We use these data to send you marketing material and promotional offers through emails and push notifications. | Marketing and Communication data | Consent |
| We use this information to administer the App, including providing the application services to you. We use this information for quality of service. We may also use this data to investigate any complaints you may have and provide you with a more efficient service as well as to fix any errors you may encounter. | Usage data | Legitimate Interest Performance of our contract with you. |
| We use these data in order to fulfill our contract with you. | Sensitive data | Consent |
7.6. Your personal information may also be processed if required by law enforcement or a regulatory authority, body or agency or for the defence or exercise of legal claims. We will not delete personal information if it is related to an investigation or dispute. They will continue to be stored until these issues are fully resolved and/or during the period required and/or permitted under applicable/relevant law.
7.7. The opt-out option will also be included in any email (as direct marketing) sent to you by us or our selected third-party partners, if the direct marketing is actually carried out by us or our selected third-party partners with our permission.
7.8. Please note that if you do not want us to process sensitive and special categories of data about you (including data related to your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life and sexual orientation) you should take care not to provide your consent for the processing of such data. In case you have provided your consent, you may withdraw it at any time by contacting us.
7.9. Please note that if you withdraw your consent to processing or do not provide the data we require to maintain and administer the App, you may not be able to access or register with the App.
7.10. If we intend to further process your data for any purpose other than those set out in this Privacy Policy, we will provide you with details of that purpose before we start processing.
8. DATA SHARING
8.1. It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for the Company to disclose your Personal Data. We may also disclose information if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public, and/or governmental authorities, and/or Supervisory Authority.8.2. We also use Google Analytics to analyze user’s behavior and obtain statistics.
9.INTERNATIONAL TRANSFERS
9.1. We may transfer and maintain some of your personal information on our servers or databases outside the European Union.9.2. Countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or apply standard contractual clauses (e.g., Standard Clauses, Data Processing Agreement/Addendum) to ensure that your data is adequately protected.
10. RETENTION PERIOD
10.1. We will retain your personal data for as long as necessary to carry out the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or if additional legal/regulatory obligations require us to retain your personal data in during the period required and/or permitted under applicable/relevant legislation.10.2. You can delete your personal data by removing the data from your personal page. Alternatively, you can delete your account using the “Delete my Account” feature available in the Setup – General – Account section. You may also request the deletion of your account here: https://canyon.eu/account-removal-request/. You have the right to restore your account within 90 days of the deletion.
10.3 We may remove your profile or the information you post on the application if there are reasons provided by applicable law or as provided by the terms.
11. YOUR LEGAL RIGHTS
11.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data.11.2. Access. Request access to your personal data (commonly known as “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
11.3. Rectification, Portability, and Deletion of your Personal Information. You have the right to correct or update your personal data, object to the processing of your personal data, ask us to restrict processing of your personal data, or request the portability of your personal data. To protect the privacy and the security of your personal data, we may request data from you to enable us to confirm your identity and your right to access such data, as well as to search for and provide you with the personal data we maintain upon your request. There are instances where applicable laws or regulatory requirements allow or require from us to refuse to provide or delete some or all the personal information that we maintain.
11.4. Request erasure of your personal data. This enables you to request the deletion or removal of your personal data when there is no good reason for us to continue processing it. You also have the right to request for deletion or removal of your personal data when you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be communicated to you, if applicable, at the time of your request.
11.5. Object to processing of your personal data when we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
11.6. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to the use of your data but we need to verify whether we have overriding legitimate grounds to use it.
11.7. Request the transfer of your personal data to you or to a third party. We will provide to you, or to a third party of your choice, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
11.8. Withdraw consent at any time when we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
11.9. Unsubscribe from Our Marketing Communications. If you no longer wish for us to use your email address to send you marketing emails or non-transactional promotional materials, please directly click on the unsubscribe link at the bottom of any of our email messages to you or contact us.
11.10. You also have the right to independently remove your profile, the information in your profile, and make changes and corrections to your personal profile on the App provided that such changes and corrections contain updated and truthful information. You can also see an overview of the information we hold about you through the App.
11.11. Lodging Complaints. If you believe we have infringed or violated your privacy rights, please contact us so that we may attempt to resolve any issues to your satisfaction. Notwithstanding the approaches of exercising your rights stated above, this is without prejudice to your right to lodge a claim or complaint to your data protection authority (more details on data protection authorities and their contact info can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en).
11.12. If you wish to exercise any of the rights set out above, please contact us either through support or by using the contact details provided in section 2. We will aim to respond to you within 30 days from receipt of the request. We will need to verify your identity before we are able to disclose any personal information to you.
12. SAFETY MEASURES
12.1. We take technical, organizational and legal measures, including encryption where appropriate, to ensure that your personal data is protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.12.2. Access to the App functions is authorized using your login details (e-mail address) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties, and we recommend that you take steps to ensure that this information remains confidential.
12.3. If you forget your password you can press “Set up” – GSM devices – Login – Forgot your password. Then you write your email and you press “Send code”. Then you will receive a reset password confirmation code to the email you have provided. If you forget your email, we only provide it after receiving proof of ownership, as specified in section 7.5 above, of the GSM device. We won’t provide you with a full email address. Such request may also be made through tech support here https://canyon.eu/contact-us/