Effective Date: March 25, 2020
This Privacy Policy covers any information about you including personal data as defined by applicable laws and regulations, as well as advertising identifiers which Period Tracker & Pregnancy and Baby Calendar Limited (a legal entity registered in accordance with the laws of the Hong Kong Special Administrative Region located at: 2301, Bayfield Building 99, Hennessy Road, Wanchai, Hong Kong, Registration Number: 2798808), and/or its affiliated entities, including all entities belonging to the same group as Period Tracker & Pregnancy and Baby Calendar Limited (hereinafter referred to as “PT”, or “we”), may obtain when you use the mobile application “Pregnancy Tracker” (hereinafter referred to as “the Application”).
The Application allows for the calculation of the gestational age, keeping your pregnancy table, provides insights into your pregnancy, your well-being and your baby's development, and provides users throughout the world with personalized content, messages, tips and other services. This Privacy Policy is meant to help you understand our privacy practices when you use our services, including what data we collect, why we collect it, and what we do with it, as well as your individual rights.
PT uses personal data collected or processed by the Application.
This Policy is designed for you to understand what methods of securing confidentiality we use, including which exactly information we collect, for what purposes we do it, and what we do with this information, as well as what rights you have in this regard.
Please also read our Terms of Use, which describe the terms under which you use our services.
How do you give consent to the processing of your personal data?
You give your consent to the processing of your personal data by means of ticking the check box “I hereby agree to the processing of my personal data in accordance with the Privacy Policy” and then clicking the button “I agree to processing of my personal data in accordance with the terms of the Privacy Policy”.
By accepting this Privacy Policy you give PT your express consent, in your own power and for your own benefit, to the processing of your personal data in accordance with the conditions set forth in this Privacy Policy.
How and what Personal Data are collected and for which Purposes?
We receive or collect personal data, as described in detail below, when you perform your authorization, whether by entering your Personal Data directly, or by importing the data from external sources such as your social media profiles or other Internet sources (in particular, from your Facebook or Google accounts), as well as when we provide our Services in the Application including when you access, download, install the Application on your device, or use our Services. We may use this personal data to perform our services, to operate, provide, improve, customize, support and market our own or our partners’ services based on our legitimate interest, or to comply with a legal obligation to which we may be subject.
If you do not want us to collect and process your personal data, you can refuse to give your consent to the processing thereof but in such a case you may not be able to use some or all of the services.
Account Data
We collect your personal data when you create an account. You may log in to the Application using your account or using your social media profile. The personal data we collect may include your username, name, email address, telephone number, gender, country, language, due date, social media profile, location.
The collected personal data is used to create and manage your account. You can use your account to securely log in to the Application. After you’ve created an account to log in to the Application, we will send you a welcoming e-mail. We will communicate with you in response to your enquiries, and send you service-related announcements or direct marketing communication if you have opted in. You may also use your account to participate in a promotion or event, participate in a social media activity related to promotion (for example by clicking "Love the App" or "Share the App" buttons) and participate in product testing or surveys.
Other Provided Data
Such data includes:
- Your name
- Your DOB
- Your gender
- Your town/city
- Your IP-address
- idfa/aid, udid
- the number of children
- Your due date
- Your weight
- Your waist circumference
- Baby’s kick counts
- Information on contractions and labour
- Your uploaded pictures
- Your doctor's visits (personal notes that you may wish to record, such as: pregnancy weight, blood pressure, foetal heart rate)
The collected personal data is used to provide you the full functionality of the Application, including to give your insights into the current pregnancy stage, general recommendations regarding your well-being during the pregnancy and after the delivery as well as personalized content. We do this by means of displaying the information, or sending you e-mails, push notifications and in-app messaging.
You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before withdrawing your consent.
Sensitive Personal Data
We do not request and we ask you not to provide, including not to send us on or through the Application or otherwise, or disclose, any sensitive personal data that might be deemed confidential under the applicable laws (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).
We can also use your information for the following purposes:
Product Analytics
We use product analytics tools to process the information on how users use the Application and to get analytical reports. Therefore, the generated data regarding your usage of the Application is transmitted to the servers of our analytics service providers in depersonalized form.
Companies whose analytics tools we use are listed below. Please read their privacy policies carefully because they contain information on the privacy regulations that these companies use including how they use, process and protect personal data. By accepting this Privacy Policy you give PT your consent to transfer your personal data to the companies listed below for the purposes set forth in this Privacy Policy and the privacy policies of such companies, and you also confirm that you’ve read their privacy policies and accept their terms.
You may withdraw your consent to processing your data by such companies at any time by means of sending a corresponding request to PT or directly to the below listed companies at the contracts below:
Appmetrica
Privacy policy: https://yandex.ru/legal/confidential
Address: 119021 Leo Tolstoy Street 16, Moscow, Russia
Contacts: http://feedback.yandex.ru
AsoDesk
Privacy policy:: https://asodesk.com/docs/ru-en/privacy_policy/old
Address: 121087 Barklaya Street 6, Building 5, 1-st Floor, Suite 22, Moscow, Russia
Contacts: hello@asodesk.com
Appfollow
Privacy policy: https://appfollow.io/ru/privacy
Address: AppFollow.fi Oy, Mannerheiminaukio 1, 00100, Helsinki, Finland
Contacts: hi@appfollow.io
AppsFlyer
Privacy policy:: https://www.appsflyer.com/ru/website-privacy-policy
Address: AppsFlyer Ltd. (Attn: Legal Dept.) 14 Maskit St., Herzliya, Israel
Contacts: privacy@appsflyer.com, +49-30-3119-9129
Flurry
Privacy policy:: https://policies.oath.com/us/en/oath/privacy/index.html
Address: 701 First Avenue Sunnyvale, CA 94089
Contacts: https://io.help.yahoo.com/contact/index?y=PROD_ACCT&token=w5FCchB1dWFBK0e02%252BwEylJn1ziDqe...
AppAnnie
Privacy policy:: https://www.appannie.com/ru/legal/privacy/
Address: 23 Geary Street, Suite 400/800 San Francisco, CA 94108
Contacts: dpo@appannie.com
Fabric
Privacy policy: https://fabric.io/terms
Contacts: support@fabric.io
Amplitude
We use Analytics Service from Amplitude, Inc. to analyze and process information about the use of the Application. Information about your use of the Application is deposited with Amplitude, Inc. servers and processed in accordance with Amplitude's privacy policy. Privacy Contact: Address: 631 Howard Street, Floor 5, San Francisco, CA 94105, United States, tel.: 415-802-9277; e-mail: legal@amplitude.com .
You can read the privacy policy here: : https://amplitude.com/privacy
Qonversion
We use this service of Qonversion Inc. to aggregate analytical data about paid subscriptions used in the Application.
Privacy policy: https://qonversion.io/page/privacy
e-mail: hi@qonversion.io
Transactional information
If you pay for our Services, we may receive information and confirmations, such as payment receipts, including from app stores or other third parties processing your payment.
Customer support
You may provide us with information related to your use of our Services, including your interaction with PT, and how to contact you so we can provide you customer support. We operate and provide our Services, including providing customer support, and improving, fixing and customizing our Services. We also use your information to respond to you when you contact us.
Advertising
In order to support and develop the Application we cooperate with advertisers and may use your data for the purposes of marketing of goods, works and services of PT as well as its partners both by means of showing you direct ads in the Application’s interface and by contacting you directly via means of communication. Also, we may use your data in order to fulfill our obligations towards you in course of customer loyalty programs, as well as in order to provide you with the information on promotional actions and programs for clients (owners of discount cards) which may include sharing your data with our partners.
Companies with whom we may share your data are listed below. Please read their privacy policies carefully because they contain information on the privacy regulations that these companies use including how they use, process and protect personal data. By accepting this Privacy Policy you give PT your consent to transfer your personal data to the companies listed below for the purposes set forth in this Privacy Policy and the privacy policies of such companies, and you also confirm that you’ve read their privacy policies and accept their terms.
You may withdraw your consent to processing your data by such companies at any time by means of sending a corresponding request to PT or directly to the below listed companies at the contracts below:
Procter and Gamble Distribution Company LLC (incorporated in Russia, TIN 7701639976, Primary National Registration Number 1067746158083) and Procter and Gamble LLC (incorporated in Russia, TIN 7701032910, Primary National Registration Number 1027700413927)
You can find the terms of their privacy policy here:
https://www.pg.com/privacy/russian/privacy_statement.shtml
Address: Leningradskoye Shosse 16A, Building 2, 125171, Moscow, Russia.Customer Support Hotline: +7 800 200 20 20.
How do we process your personal data?
We process your personal data by automated means, including in information- and telecommunication networks. and/or without them.
We process your data by means of collection, recording, organization, coding/decoding, structuring, storage, adaptation (updating, alteration), retrieval, consultation, use, submission (disclosure by transmission, dissemination or otherwise making available), alignment or combination, restriction, depersonalization, blocking, erasure or destruction. We may also employ other means of processing allowed by the applicable law of your country.
Combined Data
We may combine your personal data, including account data, other data provided by you, Device data, cookies, location data, data collected during your interactions with PT and/or using digital channels, such as social media, websites, e-mails, apps and connected products, IP address, cookies, device information, communications you click on or tap, location details and websites you visit.
The combined data is analyzed and used to provide you with Services such as to give you insights into your pregnancy, your well-being and your baby's development, and to provide you with personalized content, messages and tips, and to help us improve the content, functionality and usability of the Application, Device and Services, as well as to develop new products and services.
If you opt-in to receive promotional communications about the products, services, events and promotions of PT that may be relevant to you based on your preferences and online behavior, we may send you marketing and promotional communications via email, phone and other digital channels, such as mobile apps and social media. To be able to tailor the communications to your preferences and behavior and provide you with a more relevant and personalized experience, we may analyze and combine your personal data. You may opt-out and unsubscribe from such communications at any time.
Permissions
The App may request your permission to access your phone or sensors (e.g. camera, Wi-Fi, geo-location or Bluetooth) or other data (e.g. photos, agenda or contacts) on your mobile device.
We use such data only when it is needed to provide you with the Services and only after you have provided your explicit consent.
Sometimes, the permission is a technical precondition of the operating systems of your mobile device. In such case, the Application may ask your permission to access such sensors or data, however, we will not collect such data, unless when it is required to provide the Application support and only after you have given consent.
With whom are your Personal Data shared?
PT may disclose your personal data to third party service providers, business partners, state authorities, or other third parties in accordance with this Privacy Policy and/or applicable law.
Service providers
We work with third-party service providers who help us operate, provide, improve, understand, customize, support the Application and market our services.
We may share your personal data with the following service providers:
IT, CRM and cloud service providers
These service providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the Application or provide the Services.
PT requires its service providers to provide an adequate level of protection to your personal data similar to the level that we provide. We require our service providers to process your personal data only in accordance with our instructions and only for the specific purposes mentioned above, we let them access to the minimum amount of data they need to deliver a specific service, and we require them to protect the security of your personal data.
For example, we use the Qonversion service of Qonversion Inc. to manage paid subscriptions in the Application.
Address: 1160 Battery Street, East Suites 100, San Francisco, 94111
Privacy policy: https://qonversion.io/page/privacy
e-mail: hi@qonversion.io
Other third parties
PT may also work with third parties who process your personal data for their own purposes. Please read their privacy policies carefully as they inform about their privacy practices, including what type of personal data they collect, how they use, process and protect them. By accepting this Privacy Policy you give PT your consent to transfer your personal data to such third parties for the purposes set forth in this Privacy Policy and the privacy policies of such third parties, and you also confirm that you’ve read their privacy policies and accept their terms.
From time to time PT may sell a business or a part of a business to another company. Such a transfer of ownership could include the transfer of your personal data directly related to that business, to the purchasing company. All of our rights and obligations under our Privacy Policy are freely assignable by PT to any of its affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your personal data to any of our affiliates, successor entities, or a new owner.
We may share your personal data with the following third parties:
Third parties
These third parties may provide their own services to you.
We may share your personal data with Ad Serving Technology companies and also provide you with links to other websites at your request and/or in accordance with the applicable law.
Ad Serving Technologies
For the purposes of demonstration of advertisement in the Application we use third-party ad serving technologies, including software development kits (SDK). Such technologies may gather and transmit your data, including your IP-address for the purpose of identifying your location; information about your mobile device, such as its type or model, manufacturer, mobile service provider, OS and browser as well as its ID (such as iOS or Android advertising identifier); the history of your contact with advertisements, Internet-sources and third-party applications. This data may be used and disclosed in accordance with this Privacy Policy, and the privacy policy of the company providing the ad serving technologies. The advertising companies who deliver ads for us may combine the information collected with other information they have independently collected from other services or products. Although we take commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, we do not have access to or control of third-party technologies.
Developers and advertising companies with whom we cooperate are listed below. Please read their privacy policies carefully because they contain information on the privacy regulations that these companies use including how they use, process and protect personal data. By accepting this Privacy Policy you give PT your consent to transfer your personal data to the companies listed below for the purposes set forth in this Privacy Policy and the privacy policies of such companies, and you also confirm that you’ve read their privacy policies and accept their terms.
You may withdraw your consent to processing your data by such companies at any time by means of sending a corresponding request to PT or directly to the below listed companies at the contracts below:
We cooperate with AdMob owned by Google.
You can find the terms of their privacy policy here:
https://policies.google.com/privacy.
We cooperate with AdFox platform owned by Yandex LLC, with its principal office at: Leo Tolstoy street 16, Moscow, 119021, Russia. AdFox may collect your data through the Application.
You can find the terms of their privacy policy here:
https://www.adfox.ru/ru/about/privacy/.
We cooperate with Appodeal platform owned by Appodeal Inc., Delaware, USA, with its principal office at: Leo Tolstoy street 16, Moscow, 119021, Russia for the purposes of advertisement broadcasting.
You can find the terms of their privacy policy here:
https://www.appodeal.com/privacy-policy.
We use the DoubleClick for Publishers (DFP) service to show programmed ads in the Application. The information from the Application’s settings, e.g. the current trimester as well as the individual device number will be sent to DFP so that it can show the most relevant ads. Besides the DFP service uses IP address resolution so that the ads can be shown in the user’s language.
You can find the terms of their privacy policy here:
https://policies.google.com/privacy?hl=en
Their terms of use are available here:https://www.google.com/doubleclick/publishers/small-business/terms.html
We cooperate with myTarget the advertising space of Mail.Ru Group owned by My.com B.V., located at: Barbara Strozzilaan 201, 1083HN, Amsterdam, the Netherlands, e-mail: target@corp.my.com.
You can find the terms of their privacy policy here:
https://legal.my.com/us/mytarget/.
Links to Other Sites
The Application may contain links to other sites or services of interest. Once you have used these links to leave the Application, we do not have any control over those third-party sites or services. The information which you provide whilst visiting such sites is not governed by this Privacy Policy.
Cross-border transfer
Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, so by accepting this Policy and/or using the Services you consent to the transfer (if any) of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.
If you are located in the EEA, your personal data may be transferred to our affiliates or service providers in non-EEA countries that are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here).
How long do we keep your data?
We will retain your personal data for as long as needed or permitted in light of the purpose(s) for which the data is collected. The criteria we use to determine our retention periods include: (i) the length of time you use the Application and Services; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Your choices and rights
If you would like to submit a request to access, rectify, erase, restrict or object to the processing of personal data that you have previously provided to us, or if you would like to submit a request to receive an electronic copy of your personal data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at help@pregnancytracker.app. We will respond to your request consistent with applicable law.
In your request, please make clear what personal data you would like to access, rectify, erase, restrict or object to its processing, etc. For your protection, we may only implement requests with respect to the personal data associated with your account, your email address or other account information that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that if you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, of our Services anymore.
Should you have any complaints against PT regarding the processing of the personal data of Russian citizens you are entitled to direct your complaints to the Federal Supervision Agency for Information Technologies, Communications and Mass Media (Roskomnadzor). The address of the Agency: Kitaygorodsky proyezd 7 build. 2, 109074, Moscow, Russia. The common e-mail box of Roskonadzor is: rsoc_in@rkn.gov.ru.
In other cases you can address the Hong Kong Office of the Privacy Commissioner for Personal Data – the public authority for protection of rights of subjects of personal data:
12/F, Sunlight Tower, 248 Queen’s Road East, Wanchai, Hong Kong
T +852 2827 2827
F +852 2877 7026
http://www.pcpd.org.hk/.
We protect your personal data
We take seriously our duty to protect the data you entrust to PT against accidental or unauthorized alteration, loss, misuse, disclosure or access. PT uses a variety of security technologies, technical and organizational measures to help protect your data. For this purpose, we implement, among others, access controls, use firewalls and secure protocols.
Special information for parents
While the Services are not directed to children, as defined under applicable law, it is Philips policy to comply with the law when it requires parent or guardian permission before collecting, using or disclosing Personal Data of children. We are committed to protecting the privacy needs of children and we strongly encourage parents and guardians to take an active role in their children's online activities and interests.
If a parent or guardian becomes aware that his or her child has provided us with his or her Personal Data without their consent, please contact us at help@pregnancytracker.app. If we become aware that a child has provided us with Personal Data, we will delete his/her data from our files.
Local specific information: Your California Privacy Rights (US Only)
California Civil Code Section 1798.83 permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we have disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us at help@pregnancytracker.app.
Changes to this Privacy Policy
Our Services may change from time to time without prior notice to you. For this reason, we reserve the right to amend or update this Privacy Policy from time to time. When we update this Privacy Policy, we will also update the date at the top of this Privacy Policy.
We encourage you to review regularly the latest version of this Privacy Policy.
The new Privacy Policy will become effective immediately upon publication. If you do not agree to the revised notice, you should alter your preferences or consider stopping using our Services. By continuing to access or make use of our Services after those changes become effective, you acknowledge that you have been informed and agree to the Privacy Policy as amended.
Contact Us
If you have any question about this Privacy Notice or about the way in which PT uses your personal data, please contact us at help@pregnancytracker.app or at: 2301, Bayfield Building 99, Hennessy Road, Wanchai, Hong Kong. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.