Privacy Policy of NewTowner

This Application collects some Personal Data from its Users.

 

POLICY SUMMARY

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Personal Data collected for the following purposes and using the following services:
Access to third-party accounts
Facebook account access
Permissions: About Me; Email; Photos; Analytics; Fabric Answers; Personal Data: Cookies; unique device identifiers for advertising
(Google Advertiser ID or IDFA, for example); Usage Data Facebook Analytics for Apps; Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service; Google Analytics; Personal Data: Cookies; Usage Data Google Analytics for Firebase
Personal Data: Application opens; Application updates; Cookies; device information; first launches; geography/region; In-app purchases; number of sessions; number of Users ; operating systems; session duration; Usage Data; Beta Testing; Google Play Beta Testing; Personal Data: Data communicated while using the service; device information; device logs; email address; Usage Data; TestFlight; Personal Data: Cookies; Data communicated while using the service; device information; device logs; email address; first name; Usage Data; Contacting the User; Contact form; Personal Data: email address; first name; last name; phone number; Mailing list or newsletter; Personal Data: city; country; date of birth; email address; first name; last name; Content performance and features testing (A/B testing); Firebase Remote; Config; Personal Data: various types of Data as specified in the privacy policy of the service; Data transfer outside the EU; Data transfer abroad based on consent; Personal Data: various types of Data; Device permissions for Personal Data access; Device permissions for; Personal Data access; Personal Data: Calendar permission; Camera permission; Contacts permission; Photo Library permission; Precise; location permission (non-continuous); SMS permission; Social media accounts permission; Displaying content from external platforms
Google Maps widget; Personal Data: Cookies; Usage Data; Hosting and backend infrastructure; Firebase Realtime Database and Firebase; Cloud; Storage; Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service; Amazon Web Services (AWS); Personal Data: various types of Data as specified in the privacy policy of the service; Interaction with external social networks and platforms; Facebook Like button and social widgets and Twitter Tweet button and social widgets; Personal Data: Cookies; ; Usage Data; Location-based interactions; Non-continuous geolocation; Personal Data: geographic position; Managing contacts and sending messages; Firebase Notifications; Personal Data: various types of Data as specified in the privacy policy of the service; Mailchimp
Personal Data: date of birth; email address; first name; last name; Managing data collection and online surveys; Typeform; Personal Data: address; country; date of birth; email address; first name; gender; last name; profession; Platform services and hosting; Apple App Store and Google Play Store; Personal Data: Usage Data; Wix; Personal Data: various types of Data as specified in the privacy policy of the service; Registration and authentication; Firebase Authentication; Personal Data: email address; first name; profile picture; Facebook Authentication; Personal Data: various types of Data as specified in the privacy policy of the service; Social features; Firebase Dynamic; Links; Personal Data: various types of Data as specified in the privacy policy of the service; Inviting and suggesting friends

Personal Data: various types of Data; Public profile; Personal Data: city; date of birth; first name; geographic position; picture; profession; Further information about Personal Data; Access the address book; This Application may request access to your address book;

 

Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data
processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken
solely by technological means, without any human intervention. This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be

provided by third parties. The rationale behind the automated decision making is: to enable or otherwise improve the decision-making process; to grant Users fair and unbiased treatment based on consistent and uniform criteria; to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party
services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant
sections in this document.

Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken. In particular, Users have the right to: obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis; request and obtain from the Owner human intervention on such processing. To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
 

Personal Data collected through sources other than the User
The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing. Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant
sections of this document or by contacting the Owner. 

 

Push notifications based on the User's geographic location
This Application may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile
phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
 

Push notifications for direct marketing
This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application). Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for this Application or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively
affect the utility of this Application. Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

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Contact information

Owner and Data Controller
Páginas De Felicidade Unipessoal LDA
5 Zambeze 3C, Lisbon, Portugal
Owner contact email: contact@newtowner.app

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FULL POLICY

Owner and Data Controller

Páginas De Felicidade Unipessoal LDA

5 Zambeze 3C, Lisbon, Portugal

Owner contact email: contact@newtowner.app

Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: first name; email address; profile picture; Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems; Data communicated while using the service; device logs; last name; phone number; country; date of birth; city; various types of Data; Calendar permission; Contacts permission; Camera permission; Precise location permission (non-continuous); SMS permission; Social media accounts permission; Photo Library permission; geographic position; gender; address; profession; picture.
 

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
 

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
 

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
 

Mode and place of processing the Data

Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any
time.
 

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following
applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided
 

in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore: Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
 

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
 

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Registration and authentication, Social features, Managing contacts and sending messages, Access to third-party accounts, Analytics, Beta Testing, Contacting the User, Data transfer outside the EU, Device permissions for Personal Data access, Displaying content from external platforms, Hosting and backend infrastructure, Interaction with external social networks and platforms, Location-based interactions, Managing data collection and online surveys, Platform services and hosting and Content performance and features testing (A/B testing). Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

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Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc. For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
 

The permissions asked are the following:
Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me
Provides access to the 'About Me' section of the profile.

Email
Provides access to the User's primary email address.

Photos
Provides access to the photos the User has uploaded, and photos the User has been tagged in.

Device permissions for Personal Data access
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below. By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document. The exact procedure for controlling app permissions may be dependent on the User's device and software. Please note that the revoking of such permissions might impact the proper functioning of this Application.
 

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Calendar permission
Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.

Camera permission
Used for accessing the camera or capturing images and video from the device.

Contacts permission
Used for accessing contacts and profiles on the User's device, including the changing of entries.

Photo Library permission
Allows access to the User's Photo Library.

Precise location permission (non-continuous)
Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services. The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.

SMS permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

Social media accounts permission
Used for accessing the User's social media account profiles, such as Facebook and Twitter.

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Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services: Access to third-party accounts; Analytics; Beta Testing; Contacting the User; Content performance and features testing (A/B testing); Data transfer outside the EU; Device permissions for Personal Data access; Displaying content from external platforms; Hosting and backend infrastructure; Interaction with external social networks and platforms; Location-based interactions; Managing contacts and sending messages; Managing data collection and online surveys Platform services and hosting; Registration and authentication; Social features; Further information about Personal Data; Access the address book; Analysis and predictions based on the User’s Data (“profiling”); Automated decision-making; Personal Data collected through sources other than the User; Push notifications based on the User's geographic location; Push notifications for direct marketing; The rights of Users;

 

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following: Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the
processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
 

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month. 

 

Additional information about Data collection and processing Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
 

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
 

System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
 

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
 

How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not
Track” requests, please read their privacy policies.
 

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Latest update: November 28, 2021