The use of the Application means the unconditional consent of the Client with this Policy and the conditions specified in it for processing information received from the Client's Device.
In case of disagreement with the Policy, the Client must refrain from using the Application.
The Application and services within the Application are sold to the Client on the basis of contracts and agreements with the Company, which, among other things, regulate all issues of processing and storage of the Client's personal data by the Company.
Company is the “controller” in accordance with the applicable data protection law, in particular the EU General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA).
The Policy applies only to the Application. The Company does not control and is not responsible for the information (the consequences of its transfer) transferred by the Client to a third party, if such transfer was made on a third party resource, to which the Client could go through links from the Application.
The Company has the right to amend the Policy by posting a new version of the Policy on the Company's website and (or) in the Application. The obligation of self-acquaintance with the current version of the Policy lies with the Client. The Policy has been approved by the Company's CEO and posted on the Company's website www.apphero.app.
1. TERMS AND DEFINITIONS
1. The terms used in the Policy shall have the following meanings.
1.1. Client – an individual who is a user of the Application and who applied to the Company with the intention of receiving or received a financial service from the Company using the Application.
1.2. Company – Appbooster Lp, which is a financial service provider to the Client using the Application.
1.3. Application - a set of programs, databases for computers under the name "Mobile application" AppHero "(mobile version of the Company's remote service system) the exclusive right to which the Company belongs by virtue of the fact of creation.
1.4. Device - a mobile technical device (smartphone, tablet or other device) that has access to the Internet, on which the Application is installed.
1.5. OS – operating system of the Device.
1.6. Software means a software tool installed on the Device and providing the functionality of the Application.
2. USER INFORMATION
The composition of the information that can be obtained from the Device when using the Application and the purpose of obtaining it:
2.1. Information about the location of the Device (based on data from the mobile operator's network and GPS signals) can be obtained by the Company in order to inform the Client when using the Application about the location of the Company's divisions, its representative offices and (or) third parties engaged by the Company on the basis of agency in order to provide financial services, as well as additional services available to the Client and due to its location.
2.2. Photo images obtained using the Device's camera for the purpose of obtaining and using photo images within the services implemented in the Application, including for creating and saving photo images in the Client's profile in the Application.
2.3. Information about the operating system version and Device model received by the Company in order to analyze possible errors in the operation of the Application and improve the operation of the Application. For analysis purposes, the Company may transfer information about the operating system and Device model to third parties in an anonymized form.
2.4. Information about the Client's IP address and connection point address received by the Company in order to improve the Client's security when using the Application.
2.5. Information about SMS messages on the Device may be received by the Company in order to store and use in the Application SMS messages received from the Company (with the AppHero sender ID).
2.6. Audio data obtained using the microphone of the Device for the purpose of making audio calls from the Client to the Company using the Application.
2.7. In order to improve the quality of the software and update the software: information about the results of the software update, data about the installed OS, technical and other information automatically transmitted by the device, information about errors that have occurred in the operation of the software components.
3. TERMS OF INFORMATION PROCESSING
3.1. In accordance with this Policy, the Company processes only that information and only for those purposes that are defined in section 2 of the Policy.
3.2. The Company takes all organizational and technical measures depending on it to protect the Client's information from unauthorized access by third parties, use, copying and distribution.
3.3. For the purposes set forth in the Policy, the Company may involve in the processing of the Client's information partners with whom the Company has concluded appropriate confidentiality agreements. The transfer by the Company to partners of anonymous data on the use of the Application for the purpose of improving the operation of the Application is carried out on the basis of agreements with partners.
3.4. The Client's information may be stored on the resources of the Company and its partners during the term of the contractual relationship between the Company and the Client regarding the Application, as well as for five years after the termination of such agreements.
4. POLICY APPROVAL AND CHANGES
4.1. The Company has the right to make changes and additions to the Policy that do not contradict the requirements of the legislation of GDPR and CCPA.
4.2. An unconditional basis for making changes and additions to the Policy is a significant change in the legislation of GDPR and CCPA. in the field of microfinance activities.
4.3. Changes and additions to the Policy are put into effect after they are approved by the Company.