Privacy Policy
This Privacy Policy (“Privacy Policy”) explains the data privacy practices of “Double Star Software PRIVATE COMPANY” with seat at Voula Attikis, Greece (Company Registry no. 172225403000, email:info@doublestarsoftware.com) (“the Company” “us”, “we” or “our”) and describes the ways in which we use the information we receive from you as user (“User”) of the digital application 2Hook (the “App”). This Privacy Policy is directly linked with the applicable Terms of Use which you must accept in order to be able to use the relevant application and its related services.
1) Brief description of our services
The Company develops data analysis and mapping solutions for a number of industries using its proprietary mobile applications. This Privacy Policy concerns the application 2Hook which only requests access to data relevant to its core functionalities and collects and uses data that is required to accomplish its relevant tasks.
2) Collection of Personal Information
The types of personal information (i.e. information that relates to an identified or identifiable individual) we collect and process as data controller may include, but is not limited, to the following:
(i) Information that is necessary for you to register on the App and to use the related services. This includes at least your email address and password.
(ii) Any other personal information that you choose to provide when registering with the App (such as name, surname, photo, sex, age, weight) for the creation of a more detailed account;
(iii) Information about your use of the Services. This would include your frequency of use of the App, your responses to individual offerings, your statistics and the types of features you mostly use;
(iv) Customer service information or general account information, and
(v) Location data.
(collectively “Personal Information”).
If you encounter a screen or page that requests information you do not want to share with us, you may choose not to enter the information and not proceed with that screen. It should be noted that certain information is necessary for the correct operation of the App.
3) Legal basis and purposes of use of Personal Information
With regard to the purposes stated above, we inform you that the legal basis for the processing of your personal data under par. 2(i) and 2(iv) above, is the performance of our agreement as described in the Terms of Use accepted by you in order to conclude the App registration process.
As regards the legal basis for the processing of your data under par. 2(ii) and 2(iii) above, is our legitimate interests (i.e.; to improve our product and offerings) and our reasons for using it outweigh any prejudice to your data protection rights.
With regard to the sending of any commercial/ marketing communications, please be advised that the legal basis for such processing is your relationship with us a customer. Please note that you can opt-out any time without affecting the other processing procedures previously set out.
Specifically, as regards location data (par. 2(v)), the App accesses your location in order to feature a path or line to your area based on your specific movements. This is directly relevant to the core features and services provided by the App. This includes while the App is not open, allowing you to utilize other aspects of your phone while a trace is being recorded. In order to enable this ability, the App collects location data (also in the background) only subject to your consent. If you do not provide your consent for the use of location data, the App is not able to operate properly, thus we advise not to use it at all.
In the event you submit Personal Information to the public or to other platforms/ forums that are accessible by the public at large, such information becomes publicly available and we are not responsible for the Personal Information you choose to submit to these platforms, forums or other Users.
4) Non-personal information
By using the App, you explicitly consent to allowing us to share or exploit specific types of non-personal information as set forth herein which we obtain through your use of the App. This information includes but is not limited to technical details, statistics, weather and location information, type of equipment, game, achievements and various other data listed through your use of the App.
To be clear, we do not consider this specific type of information to be Personal Information and therefore, in additional to the uses described above, we may use this information for our own internal or external analytics purposes. We may also share with others the information you provide. We take all necessary measures to ensure such information is fully anonymized and/or presented to any third parties in an aggregate format.
5) Data retention period
We will retain your Personal Information for as long as it is necessary for the provision of the services and for the fulfilment of the relevant purpose. Afterwards we permanently delete your Personal Information. In particular, Personal Information will be retained for the duration of your contractual relationship as a User of the App and, after its expiration, for as long as may be required by the applicable legislation for the fulfilment of civil, tax and other legal obligations of the Company (if any), as well as for as long as necessary for the exercise, establishment and support of legal claims before the Courts or any other authority and until the expiry of the limitation period of these claims.
6) Email Communications
Your email address is used to communicate notification emails about important information regarding the Services or to communicate with you for App administration purposes. We may also email you information regarding updates to the services and to send information regarding our promotions, contests and events.
You may opt out of being contacted by for marketing or promotional reasons us, at any time by sending an email to info@doublestarsoftware.com .
We reserve the right to email you regarding your account status.
7) Disclosures and Transfers of Personal Information - Other recipients
We do not share with or disclose Personal Information to third parties, except when one or more of the following conditions is true:
· We have your permission to make the disclosure;
· The disclosure is permitted by relevant law;
· The Personal Information to be disclosed is otherwise publicly available in accordance with the applicable law;
· The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets;
· The disclosure is for our own marketing purposes, or, with your authorization, for the marketing purposes of third parties;
· The party to whom the disclosure is made controls, is controlled by, or is under common control with us;
· The disclosure is in our sole discretion necessary for the establishment or maintenance of legal claims or legal compliance, to satisfy any law, regulation, or government request, or in connection with litigation;
· The disclosure is in our sole discretion about Users who we believe are engaged in illegal activities or are otherwise in violation of our Terms, even without a decision, warrant or court order;
· The disclosure is to outside businesses to perform certain services for us, such as maintaining our App, providing marketing assistance, customer service and data analysis (“Service Providers”), including Service Providers outside the country or jurisdiction in which you reside.
· The disclosure is to our credit card service provider in order to fulfill and carry out the any purchase and provision of services requested by you.
If we need to use any Service Providers that process data on our behalf, such will be checked by us to guarantee an adequate level of data protection on the same or similar level provided under this policy. These third parties that may be required to have access to your Personal Information, will be always acting in the name and on our behalf, following our instructions and being bound by a written contract, in accordance with GDPR Article 28, to the strict observance of the requirements of applicable legislation. Under no circumstances will they have access to your Personal Information for their own purposes.
As a general rule we do not transfer your data to any third counties, unless as specifically provided in this policy.
Google Maps / Apple Maps
On our application, we use Google / Apple Maps (depending on software provider) so that you can access interactive maps. We use this feature to present the service areas on a map, for example.
For more information about how Google processes data, see: https://myaccount.google.com/yourdata/maps?hl=el . You can find Google’s privacy policy on this page: https://policies.google.com/privacy?hl=el
For more information about how Apple processes data, see: https://gspe21-ssl.ls.apple.com/html/attribution-221.html. You can find Apple’s privacy policy on this page: https://www.apple.com/legal/privacy/en-ww/
Our App may include links to other platforms whose privacy practices may differ from those of Double Star Software. If you submit Personal Information to any of those platforms, your information is governed by their privacy statements. We encourage you to carefully read the privacy policy/ statement of any platform you use.
8) Confidentiality and Security
We restrict access to information collected about our Users to a very minimum number of employees who need to know that information to provide services to our Users or in the course of conducting our normal business operations. Double Star Software protects its databases with various physical and procedural measures and we restrict unauthorized access to our Users’ information.
We guarantee the confidentiality and the security of your personal data, take appropriate and adequate technical and organizational measures to protect personal data against accidental or unlawful loss, destruction, damage, alteration, unauthorized dissemination or access in accordance with the applicable legislation, and fully complies with the applicable legal and regulatory.
9) Children’s Privacy
We do not intend our services to be used by individuals under the age of 13. We do not seek or knowingly collect any Personal Information about children under 13 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.
10) Your rights as data subject
As a data subject, you may exercise the following rights and notify the relevant request to us:
· Right of access: you have the right to be informed whether your data are being processed by us, and if so, to be informed in detail about anything related to the processing of your data and to receive a copy of your data, which is being processed (Article 15 GDPR)
· Right to correction: you have the right to request correction of inaccurate or incomplete data (Article 16 GDPR)
· Right to restriction: you have the right to ask the company to restrict processing, if the legal conditions apply (Article 18 GDPR)
· Right to object: you have the right to object to the processing (Article 21 GDPR)
· Right to erasure: you have the right to request the erasure of your data, if the legal conditions apply (Article 17 GDPR)
· Right to portability: you have the right to request the transfer of your data to another controller, if the legal conditions apply (Article 20 GDPR)
· Right to withdraw consent: you have the right, at any time, to withdraw your consent, in the case the processing is based on consent (Article 7 par.3 GDPR)
You can exercise your rights by sending an e-mail to info@doublestarsoftware.com clearly indicating the right you want to exercise. We note that the exercise of the right to object or delete does not imply the immediate deletion of data or modification of the processing. In any case we will reply to you in detail as soon as possible, within the deadlines set by applicable legislation. The exercise of these rights is free of charge, unless it proves excessive or unjustified to exercise your rights.
If you consider that the processing of your data contravenes the applicable legal framework for the protection of personal data, you have the right to file a complaint with a supervisory authority. Competent supervisory authority for Greece is the Data Protection Authority, 1-3 Kifissias street, P.C. 115 23, Athens, https://www.dpa.gr/, tel: 210 6475600.
11) Use of Cookies/ Google Analytics
Our App uses cookies which is a piece of information which a web server may place on your device when you visit a website/ web platform. Cookies are commonly used by websites/ web platforms to improve the user experience. You can decide if and how your device will accept a cookie by configuring your preferences or options.
Our App uses Google Analytics, which is a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyze how individuals use the services. The non-personal information generated by the cookie about your use of the App will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the App, compiling reports on the App activity for our purpose, evaluation and providing other services relating to the App activity and Internet usage. Google will not associate your IP address with any other data held by Google.
You may disable cookies within your device as described above or can opt out for Google Analytics here, however please note that if you do this you may not be able to use the full functionality of the App.
12) Social Media Platforms and Websites
Any information, communications, or material of any type or nature that you submit to any of our pages contained on a social media platform or website such as Facebook or Twitter or Instagram by posting, messaging , uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy. Double Star Software PRIVATE COMPANY cannot control the actions of other users of any social media platform or website and we are therefore not responsible for any content or Submissions contained on such sites and platforms. By visiting any of our pages contained on a social media platform or website, you are representing and warranting that you have reviewed the applicable privacy policy and terms of use of such platform or website and that you will abide by all such provisions contained therein.
Additionally, in the event that our App offers a message board or any other interactive or social-type feature on a website administered directly by us, please be aware that these areas may allow you to publicly post, and share with other users, certain messages, content, or other information (eg, stories, pictures, ingredients, tips, etc.). Although we may take certain precautions to protect those who use these areas of our App, we encourage you to be of giving out any personal information in such public forums. The information you post can be collected and used by people you don’t know. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post in public areas. Your use of these features is fully at your own risk.
13) Correcting & Updating Your Information
To update any of your information or discontinue service please email info@doublestarsoftware.com.
14) Updates and Notice of Material Change in the Use of Your Personal Information
We may update this Privacy Policy from time-to-time in our sole discretion. We reserve the right to change this Privacy Policy at any time but will provide you a notification of the change at least thirty (30) business days prior to the change taking effect. It is your responsibility to review this Privacy Policy for any changes each time that you use the Services.
In the event we materially change the way in which we use your Personal Information, we will provide you with notice and ask you to affirmatively accept the changes to a new Privacy Policy.
*****************