THE WEBSITE PRIVACY NOTICE

Welcome to Heartcount’s Website Privacy Notice!

Effective as of February 11th

Heartcount d.o.o. Beograd-Novi Beograd, with registered seat at Dušana Vukasovića Street no. 57, 11000 Beograd (Novi Beograd), the Republic of Serbia, CIN 21504254, TIN 111572621, (hereinafter: “Heartcount”, “we” or “us”), as a data controller, collects and processes personal data relating to interactions on the Website.

This Website Privacy Notice (hereinafter: “Privacy Notice”) describes how Heartcount uses and protects any information that you give us. Heartcount understands that personal data protection is of great importance to you and due to that we are committed to ensuring that your privacy is protected.

We strongly urge you to read this Privacy Notice and make sure that you fully understand and agree with it. If you do not agree to this Privacy Notice, please do not access or otherwise use the Website.

This Privacy Notice applies to all individuals who access our website at https://www.heartcount.com/ (hereinafter: “Website”), send us inquiries via the Website, or apply for our partnership programme.

This Privacy Notice DOES NOT apply to the processing of personal data when you use our Service, i.e. to the Heartcount Application users.

Please read this Privacy Notice given that, along with our Cookie Policy, it constitutes an agreement that applies to you.

For any questions regarding this Privacy Notice, please contact us at contact@heartcount.com.
Any capitalized but undefined term in this Privacy Notice shall have the meaning given to it in the Definitions section.

1. DEFINITIONS
2. PERSONAL DATA THAT WE COLLECT
3. WHY DO WE COLLECT PERSONAL DATA?
4. NO INFORMATION ABOUT PERSONS UNDER THE AGE OF 15
5. HOW DO WE USE YOUR PERSONAL DATA?
6. KEEPING YOUR PERSONAL DATA
7. SHARING YOUR PERSONAL DATA
8. YOUR RIGHTS
9. DO WE KEEP YOUR PERSONAL DATA SECURE?
10.CHANGES TO OUR PRIVACY NOTICE
11. HOW TO CONTACT US?

1. DEFINITIONS

When we say “Personal data” or “data” we mean any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Therefore, data about a company or any legal entity is not considered to be personal data but registering on behalf of a legal entity may include sharing personal data. For example, the information in relation to one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company or organization, business e-mail addresses like “firstname.surname@company.com”. This Privacy Notice does not apply to information from which no individual can reasonably be identified (anonymized information).

When we say “You” or “Data subject” we mean any natural person who shares data with us.

When we say “Cookies” we mean small pieces of data stored on your device (computer or mobile device). This information is used to track your use of the Website and to compile statistical reports on website activity. For further information about the use of cookies and how you can manage them, please read our Cookie Policy.

When we say “Data Processors” we mean any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

When we say “processing” we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

When we say “Service” we mean a cloud-based service, whereby Heartcount is making available the Software, the User Accounts and the Content (including the related mobile apps, desktop apps and extensions as well as other computer programs Heartcount makes available in conjunction therewith), in full or in part, including any updates, upgrades, enhancements, modifications, new features, programs and tools.

When we say “consent” we mean your explicit consent on the processing of personal data. Persons who are 15 years of age or older may give free consent to the processing of their personal data.

2. PERSONAL DATA THAT WE COLLECT

We may collect and receive information about you in various ways:

i.  Information you provide through the use of the Website.
ii.  Information you decide to provide through getting in touch with us via our Contact page.
iii.  Information you decide to provide through getting in touch with us via our Become a partner page.
iv.  Information we collect through the use of cookies in accordance with our Cookie Policy.

Data we collect about you may be divided into two groups:

A. Information You Provide

E-mail

When you sing up for our Newsletter, it would be necessary to share with us your e-mail address.
If you contact us at our Become a partner page in the process of applying for our partnership programme we will ask you to leave some personal information such as your email address.

If you contact us via Contact page on our Website, or by sending us an inquiry via our Contact page or at any other e-mail address available at the Website, we will ask you to leave your e-mail address.

Additional Information

If you contact us via Contact page on our Website, or by sending us an inquiry via our Contact page or at any other e-mail address available at the Website, we may receive additional information about you, such as business address, your profession, content of the messages or attachments you may send us, or any other information you decide to share with us.

If you contact us at our Become a partner page in the process of applying for our partnership programme we will ask you to leave some personal information such as your email address. We may also receive additional information about you, such as content of the messages or attachments you may send us, or any other information you decide to share with us. These rules only apply to personal data about individuals, they don’t govern data about companies or any other legal entities. However, the information in relation to one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company/organization, business email addresses like ‘forename.surname@company.eu’ or employees’ business telephone numbers.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

B. Information We Collect Automatically When You Use Website

Technical Data

The information we collect automatically may include information like your IP address, device type, unique device identification number, browser type, broad geographic location (e.g. country or city-level location) and other technical information. Some of this information may be collected using cookies and similar tracking technology, as explained further in our Cookie Policy.

We use analytic tools to help us measure traffic and usage trends for the Website. These tools collect information sent by your device or our Website, including the web pages you visit, add-ons, and other information that assists us in improving the Website. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

Your Usage Data

We collect and record data and sessions about how you are accessing and using the Website. Such information may include personal data.

Mobile Device Data

We collect limited data from your mobile device in order to provide the best performance of our Website and analyze our performance. Such data includes your mobile device type, mobile device id, and the date and time stamps of Website use. In addition, we deploy tracking technologies within the Website to help us gather aggregate, non-personal statistics.

3. WHY DO WE COLLECT PERSONAL DATA?

We do not process data outside the specified purposes, and, especially, we do not:

• Sell any kind of personal data,
• Disclose this information to other marketers,
• Provide your personal information to any third-party individual, government agency, or company at any time unless strictly compelled to do so by law.

4. NO INFORMATION ABOUT PERSONS UNDER THE AGE OF 15

The Website is not intended for children, and we do not knowingly collect data relating to children. If you are under the age of 15, please do not provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 15, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 15, please contact us at contact@heartcount.com.

5. HOW DO WE USE YOUR PERSONAL DATA?

We will only use your personal data if we have your consent or if some other legally permitted reason applies.
Your personal data will be used only for purposes we collected it for. We will use your personal data only when we have a reasonable and lawful reason to do so.

Our staff is legally bound by professional secret and we use all legal, technical and organizational measures to prevent any disclosed information is revealed outside the purpose for which was collected.

6. KEEPING YOUR PERSONAL DATA

We do not keep your personal data longer than the time it takes to fulfil the purpose for which is collected, or no longer than the time for which we have your consent.

For example, if you unsubscribe from our Newsletter, your data will be erased automatically.

If you have submitted your application for a partnership programme, we will erase your personal data within a year after your application has been received, unless you become one of our partners.

7. SHARING YOUR PERSONAL DATA

Heartcount utilizes external processors for certain processing activities. We use information audits to identify, categorize and record all personal data that is processed outside of the company, so that the information, processing activity, processor and legal basis are all recorded, reviewed and easily accessible. Such external processing includes (but is not limited to):

• IT Systems and Services,
• Legal Services,
• Human Resources,
• Direct Marketing Services.

We may be legally required to share certain information, including your personal data, with e.g. public authorities or governmental bodies; in such case, we will not require your further consent in order to share your personal data in such circumstances.

This is the list of processors and sub-processors with whom we share your personal data:

8. YOUR RIGHTS

As a data subject whose personal data we hold, you have the following rights:

• right to be informed about collecting and using your personal data,
• right to access the personal data we hold about you,
• right to have your personal data rectified if any of them is incomplete or inaccurate,
• right to be forgotten, i.e. the right to ask us to delete or dispose of any of the personal data that we have,
• right to the restriction of processing of your personal data,
• right to data portability, in the case you have provided your personal data
• to us and that data is processed using automated means, your right is to ask us for a copy of that personal data,
• right to object to using your personal data for a particular purpose.

To exercise these rights, please contact us at contact@heartcount.com.

9. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?

We use appropriate technical and organizational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Website or Service, you can contact us at contact@heartcount.com.

10. CHANGES TO OUR PRIVACY NOTICE

We reserve the right to change Privacy Notice from time to time at our sole discretion.

Any changes shall enter into force upon being published on our Website. You are cautioned to review our Privacy Notice periodically.

If we have your e-mail address, we may send you the notice of these changes.

If you do not agree to our Privacy Notice, please stop using our Website immediately.

11. HOW TO CONTACT US?

Should you wish to exercise any of the rights you have as a data subject, or you have a question for us regarding this Privacy Notice, please contact us at contact@heartcount.com.