PRIVACY POLICY
Owner and Data Controller
ATOM OPERATIONS LIMITED
Arch. 116 Main Street, P.O. Box 3324, Road Town, Tortola, BVI
Contact email: hello@atomoperations.tech
- Terms and Definitions
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"Application" means Lap, a mobile application, that is also
the means by which the Personal Data of the User is collected and
processed.
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"Cookies" means portions of code that is transferred to a User's mobile device
assisting the Owner in providing the Service according to the purposes
described. The User may find out more about the use of cookies on http://www.cookiecentral.com/.
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"Data Controller" (or "Owner") means the natural
or legal person, public authority, agency or other body which, alone
or jointly with others, determines the purposes and means of the
processing of Personal Data, including the security measures
concerning the operation and use of the Application. The Data
Controller, unless otherwise specified, is the Owner of the
Application.
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"Data Processor" means the natural or legal person, public
authority, agency or other body which processes Personal Data on
behalf of the Controller, as described in this privacy policy.
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"Data Subject" means the natural person to whom the
Personal Data refers.
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"Personal Data" (or "Data") means any information
that directly, indirectly, or in connection with other information
– including a personal identification number – allows for
the identification or identifiability of a natural person.
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"Usage Data" means information collected automatically
through the Application (or third-party services employed in the
Application), which can include: the IP addresses or domain names of
the computers utilized by the Users who use the Application, the URI
addresses (Uniform Resource Identifier), the time of the request, the
method utilized to submit the request to the server, the size of the
file received in response, the numerical code indicating the status of
the server's answer (successful outcome, error, etc.), the country
of origin, the features of the browser and the operating system
utilized by the User, the various time details per visit (e.g., the
time spent on each page within the Application) and the details about
the path followed within the Application with special reference to the
sequence of pages visited, and other parameters about the device
operating system and/or the User's IT environment.
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"User" means the individual using the Application who,
unless otherwise specified, coincides with the Data Subject.
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"Service" means the service provided by the Application as
described in it and in the relative terms (if available).
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Unless otherwise specified, all references made within this document
to the European Union include all current member states to the
European Union and the European Economic Area.
- Types of Data collected
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Among the types of Personal Data that this Application collects, by
itself or through third parties, there are: the name and a phone
number of the User, Usage Data, Cookies and unique device identifiers
for advertising (IDFA, for example). In addition, the Application collects, uses and share User location
Data in order to provide location-based services. Most devices provide
tools to opt out from this feature by default. If explicit
authorization has been provided, the User’s location data may be
tracked by this Application.
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Personal Data may be freely provided by the User, or collected
automatically when using the Application.
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Unless specified otherwise, all Data requested by the Application is
mandatory and failure to provide this Data may make it impossible for
the Application to provide the Service. In cases where the 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.
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Users who are uncertain about which Personal Data is mandatory are
welcome to contact the Owner.
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Any use of Cookies – or of other tracking tools – by the
Application or by the owners of third-party services used by this
Application serves the purpose of providing the Service required by
the User.
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Users are responsible for any third-party Personal Data obtained,
published or shared through the Application and confirm that they have
the third party's consent to provide the Data to the Owner.
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Mode of processing the Data
A. Methods of processing
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The Owner takes appropriate security measures to prevent unauthorized
access, disclosure, modification, or unauthorized destruction of the
Data.
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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 (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.
B. Legal basis of processing
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The Owner may process Personal Data relating to Users if one of the
following applies:
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provision of Data is necessary for the performance of an agreement
with the User and/or for any pre-contractual obligations
thereof;
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processing is necessary for compliance with a legal obligation to
which the Owner is subject;
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processing is necessary for the purposes of the legitimate interests
pursued by the Owner or by a third party.
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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.
C. Retention time
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Personal Data shall be processed and stored for as long as required
by the purpose they have been collected for. Therefore:
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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.
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Personal Data collected for the purposes of the Owner’s
legitimate interests and compliance with a legal obligation to which
the Owner is subject shall be retained as long as needed to fulfill
such purposes.
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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.
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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.
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The purposes of Personal Data processing
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The purposes of Personal Data processing are as follows:
- To provide the Service.
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For remarketing and behavioral targeting. This type of service allows
the Application and its partners to inform, optimize and serve
advertising based on past use of the Application by the User. This
activity is performed by tracking Usage Data that is transferred to
the partners that manage the remarketing and behavioral targeting
activity. The User may opt out of these practices by visiting the Network Advertising Initiative opt-out page. The User may also opt out from remarketing and behavioral targeting
provided by Facebook, as provided here.
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The Owner may also provide User with information of commercial or
promotional nature concerning other Owner`s products.
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Data transfer to third parties
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The Owner may share Personal Data with service providers for
analytical, advertising and other purposes so that the Owner can
better consider new features or otherwise tailor or enhance the
Service, particularly:
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Admob (Admob Google Inc.) AdMob is an advertising service provided by
AdMob Google Inc. Personal Data collected: Cookies, Usage Data and
unique device identifiers for advertising. Place of processing: United
States. In order to understand Google's use of Data, consult Google's partner policy.
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Appsflyer (AppsFlyer Ltd). Appsflyer is an analytics service provided
by AppsFlyer Ltd. Personal Data collected: Cookies and Usage Data.
Place of processing: Israel – Privacy Policy – Opt Out.
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Facebook Analytics for Apps (Facebook, Inc.) Facebook Analytics for
Apps is an analytics service provided by Facebook, Inc. Personal Data
collected: Usage Data and various types of Data as specified in the
privacy policy of the service. Place of processing: United States
– Privacy Policy.
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Facebook Audience Network (Facebook, Inc.) Facebook Audience Network
is an advertising service provided by Facebook, Inc. In order to
understand Facebook's use of Data, consult Facebook's data policy. One of the ways Audience Network shows ads is by using the
User's ad preferences. The User can control this in the Facebook ad settings. Users may opt-out of certain Audience Network targeting through
applicable device settings, such as the device advertising settings
for mobile phones or by following the instructions in other Audience
Network related sections of this privacy policy, if available.
Personal Data collected: Cookies, Usage Data, unique device
identifiers for advertising.
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Google AdSense (Google Inc.) Google AdSense is an advertising service
provided by Google Inc. This service uses the "Doubleclick"
Cookie, which tracks use of this Application and User behavior
concerning ads, products and services offered. Personal Data
collected: Cookies, Usage Data. Users may decide to disable all the
Doubleclick Cookies by clicking on: https://www.google.com/settings/ads/onweb/optout.
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Google Analytics (Google Inc.) Google Analytics is a web analysis
service provided by Google Inc. Google utilizes the Data collected to
track and examine the use of this Application, to prepare reports on
its activities. Google may use the Data collected to contextualize and
personalize the ads of its own advertising network. Personal Data
collected: Cookies, Usage Data.
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Data transfer outside the EU
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The Owner may transfer Personal Data to Data Processors around the
world in accordance with this privacy policy. Personal Data collected
by the Owner will be transferred to the United States, Israel and
Ukraine for the purposes as described in this privacy policy. These
data transfers are necessary to provide the Service to the User.
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The Owner is allowed to transfer Personal Data collected within the
EU to third countries (i.e. any country not part of the EU) only
pursuant to a specific legal basis. Any such Data transfer is based on
one of the legal bases described below:
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Data transfer abroad based on standard contractual clauses. If this
is the legal basis, the transfer of Personal Data from the EU to third
countries is carried out by the Owner according to "standard
contractual clauses" provided by the European Commission. This
means that Data recipients have committed to process Personal Data in
compliance with the data protection standards set forth by EU data
protection legislation. For further information, Users are requested
to contact the Owner through the contact details provided in the
present document.
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Data transfer abroad based on consent. If this is the legal basis,
Personal Data of Users shall be transferred from the EU to third
countries only if the User has explicitly consented to such transfer,
after having been informed of the possible risks due to the absence of
an adequacy decision and appropriate safeguards. In such cases, the
Owner shall inform Users appropriately and collect their explicit
consent via this Application.
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Data transfer from the EU to the U.S based on Privacy Shield. If this
is the legal basis, the transfer of Personal Data from the EU or
Switzerland to the US is carried out according to the EU - U.S.
Privacy Shield. In particular, Personal Data is transferred to
services that self-certify under the Privacy Shield framework and
therefore guarantee an adequate level of protection of such
transferred Data.
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Further information about Personal Data
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Users declare themselves to be adult according to their applicable
legislation. Minors may use the Application only with the assistance
of a parent or guardian. Under no circumstance persons under the age
of 13 may use the Application.
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The Application may send push notifications to the User.
- The rights of EU Users
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Users from the European Union ("EU Users") may exercise
certain rights regarding their Data processed by the Owner. In
particular, EU Users have the right to do the following:
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Object to processing of their Data. EU Users have the right to object
to the processing of their Data.
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Access their Data. EU 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.
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Verify and seek rectification. EU Users have the right to verify the
accuracy of their Data and ask for it to be updated or
corrected.
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Restrict the processing of their Data. Where Personal Data is
processed for legitimate interests, f. e. for direct marketing
purposes pursued by the Owner, EU Users may object to such processing
by providing a ground related to their particular situation to justify
the objection.
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Have their Personal Data deleted or otherwise removed. EU Users have
the right, under certain circumstances, to obtain the erasure of their
Data from the Owner.
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Receive their Data and have it transferred to another controller. EU
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 a contract which
the EU User is part of or on pre-contractual obligations
thereof.
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Lodge a complaint. EU Users have the right to bring a claim before
their competent data protection authority.
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Any requests to exercise EU User rights can be directed to the
Owner through the contact details provided in this document. These
requests will be addressed by the Owner as early as possible and
always within one month.
- Cookies
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This Application uses Cookies to save the User's session and to
carry out other activities that are strictly necessary for the
operation of this Application.
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Some of the services listed in Section 5 above collect statistics in
an anonymized and aggregated form and may not require the consent of
the User or may be managed directly by the Owner – depending on
how they are described – without the help of third
parties.
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With regard to Cookies installed by third parties, Users can manage
their preferences and withdrawal of their consent by clicking the
related opt-out link (if provided), by using the means provided in the
third party's privacy policy, or by contacting the third
party.
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Notwithstanding the above, the Owner informs that Users may follow
the instructions provided on the subsequently linked initiatives by
the EDAA (EU), the Network Advertising Initiative (US), Digital Advertising Alliance (US) and the DAAC (Canada) or other similar services.
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Since the installation of third-party Cookies and other tracking
systems through the services used within this Application cannot be
technically controlled by the Owner, any specific references to
Cookies and tracking systems installed by third parties are to be
considered indicative. In order to obtain complete information, the
User is kindly requested to consult the privacy policy for the
respective third-party services listed in this document.
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Given the objective complexity surrounding the identification of
technologies based on Cookies, Users are encouraged to contact the
Owner should they wish to receive any further information on the use
of Cookies by the Application.
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Additional information about Data collection and processing
A. Legal action
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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 the Application or the related
Service.
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The User declares to be aware that the Owner may be required to
reveal personal data upon request of public authorities.
B. System logs and maintenance
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For operation and maintenance purposes, the Application and any
third-party services may collect files that record interaction with
the Application (system logs) use other Personal Data (such as the IP
address) for this purpose.
C. How "Do Not Track" requests are handled
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The 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.
D. Changes to this privacy policy
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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 the Application and/or – as far as technically and
legally feasible – sending a notice to Users via any contact
information available to the Owner. If a User objects to any of the
changes to the policy, the User must cease using the Application and
can request that the Owner remove the Personal Data. Unless stated
otherwise, the then-current privacy policy applies to all Personal
Data the Owner has about Users.
Last updated: November 20, 2018