GPX Viewer PRO Privacy Policy

Last updated: December 4, 2019

Vectura Games OÜ (hereinafter “the Company”, “We”, “Us”, or “Our”) is the owner and operator of GPX Viewer PRO mobile application (“App”). Any reference in this Privacy Policy to “You”, “Your” or “User” refers to the User who installs and uses the App.

1. Acceptance of this Privacy Policy

Please read this Privacy Policy before you proceed to use the App. This Privacy Policy informs you: what information we and the third-party services we use collect from you; and how we and these third-party services use and share your information. We do not use or share your personal information with anyone except as described hereunder. By installing the App and making use of our services, you give us your full consent to the collection and use of your Information as outlined hereunder. If you have any questions about this Privacy Policy, please contact us at .

2. Amendments to this Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time. We will notify you of any changes to the Privacy Policy by changing the last updated date on this page. You are advised to review this Policy periodically. Please take note that any changes will be effective when posted on this page.

3. Data Controller

Vectura Games OÜ is the data controller for all personal data that we collect from you. If you are in the European Union and you wish to exercise your rights as set out in this Privacy Policy, please contact us at alternatively you can write to us at:

Vectura Games OÜ
Sepapaja 6, Tallinn 15551,
Estonia

4. Personal data we collect and use

Article 4 of the General Data Protection Regulation defines "Personal data" as "Any information relating to an identified or identifiable natural person; 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".

Personal data you provide us voluntarily

We do not require Users to submit any personal data as a prerequisite to using the App, however, you may voluntarily provide us with your personal data when you send us inquiries, or when you send us any support requests.

Personal data you provide us voluntarily includes your:

  • Your Name;
  • Your E-mail Address; and
  • Content of your message

We process this personal data to respond to your inquiry or support requests and to keep a record of our past communication with you. The legal basis of our processing is our legitimate interest as we are unable to perform our obligations towards you without processing your personal data and such use does not override your personal data rights.

We do not retain this personal data on our database for longer than two years from the date of our last communication with you, unless we are required to retain this personal data for defending any claims or actions involving you.

Information we receive from third-parties
Firebase Performance Monitoring

We use Firebase Performance Monitoring provided by Google to enable our users to use our App in a seamless manner and to prevent/address any service errors or technical issues. To learn more please visit Privacy and Security in Firebase and Google’s Privacy Policy.

Google Analytics for Firebase

We also use Google Analytics for Firebase. Google Analytics uses the data to provide analytics and attribution information. The type of information collected through the Google Analytics for direbase includes:

  • Number of users and sessions,
  • Session duration
  • Operating systems
  • Device models
  • Geography
  • First launches
  • App opens
  • App updates

Google Analytics retains Instance ID-associated data for 60 days, and retains aggregate reporting and campaign data in accordance with the retention preferences set by us. To learn more about Google’s use of data please visit Google’s Partner Policy, Privacy and Security in Firebase as well as Google’s Privacy Policy.

Opt-out of Google Analytics for Firebase

You can disable collection of your information by Google Analytics for Firebase by selecting the miscellaneous option in the App Settings and unchecking the Google Analytics for Firebase option.

Firebase Crashlytics

When you use our App, it may automatically collect certain information from users who access or use our App. This data includes, but is not limited to, device state information, unique device identifiers, device hardware and operating system information, information relating to how our app functions, and the physical location of a device at the time of a crash. Please note that Firebase Crashlytics may use aggregate and anonymised data to improve their service. To learn more about Firebase Crashlytics privacy policy please visit Privacy and Security in Firebase.

Opt-out of Firebase Crashlytics

You can disable collection of your information by Crashlytics by selecting the miscellaneous option in the App Settings and unchecking the Crashlytics data collection.

Privacy-relevant Android permissions requested by this app
Location Data

Our App may request Users to provide us with their location data. We use this location data to provide features of our App. You have the choice to refuse collection of location data when requested. Please note that when you disallow our access to your location data, it may restrict your ability to use certain features and functionality of the App.

Our legal basis for processing this data is your consent which may be withheld or withdrawn by you at anytime.

Storage

Used for runtime permissions related to the shared external storage. This permission allows this application opening gpx, gpz, kml and loc files. It also allows Users to save app screenshots on their device as well as compressing gpx and kml files.

Our legal basis for processing this data is performance of contract with you.

5. Sharing your personal data

We do not sell or rent your personal information to any third-party. We may disclose your personal information in the following circumstances:

  • For our compliance with applicable laws and upon reasonable requests from government bodies or regulatory authorities;
  • To our employees to enable them to perform their duties during the course of their employment;
  • To our third-party processors such as Google who process this data on our behalf to provide their services to us.
  • In the future, if we undergo a merger or acquisition, your personal data that we hold may be transferred to the new business entity as a result of such transaction. Please note any such transfer of your personal data to the new entity will not change how your personal data is collected, used, and secured or any data rights that you have under this Privacy Policy;
  • We may disclose your personal data to:
    • Prevent or investigate possible wrongdoing in connection with the App;
    • Protect the personal safety of users of the App or the public; and/or
    • Protect against legal liability.

6. Transfering your data outside of the EEA

Although the Company is located in Estonia, we make use of third-party applications and services that have servers located outside of the Eurpoean Economic Area (EEA) including United States of America where the data protection laws are significantly different from those within the EEA. When you use our App your information may be transferred outside the EEA for the purposes of processing as set out in this Privacy Policy. Please note that despite such transfer of data outside of the EEA, your personal information will always be handled in accordance with this Privacy Policy and you will retain all rights outlined in this Privacy Policy.

7. Your Data Rights

Your right to access your personal information

You have the right to access your personal data that we collect and process. This right is only available to the extent that your access does not negatively affect the rights of other individuals and is not excessive or manifestly unfounded. Please note, we may be required to verify your identity before we provide you with any personal data.

Your right to edit your personal information

Where your personal data that we hold is incorrect, outdated or inaccurate, you have the right to rectify such inaccuracies and update your data. Please note, we may be required to verify your identity before providing any access to personal data to you. This is to ensure that your personal information is not accessed by any unauthorized person resulting in a security breach. We will respond to rectification requests within one month provided the request is not excessive or manifestly unfounded.

Your right to erasure of your personal information

You have the right to request erasure of your personal information from our records under the following circumstances:

  • Your personal information is no longer required for the purpose for which it was initially collected;
  • You withdraw your consent that you previously granted;
  • Where you object to the processing of your data and there is no overriding legitimate interest to continue processing;
  • Where your personal data is unlawfully processed (originally in breach of the GDPR);
  • Where your personal data is used for direct marketing purposes.

If you wish to exercise your right to access, edit or erase your personal information, please contact us at and we will respond to your request within thirty days.

Your right to restrict processing of your personal data

You may under certain circumstances request us to restrict processing your personal data including where:

  • You dispute the accuracy of your personal information that we hold;
  • The processing of your personal information is unlawful but you are not authorizing us to erase it;
  • We no longer require your personal data for the purposes for which it was obtained but you require the personal data for establishing, exercising or defending legal claim and you have objected to processing of such personal information in the interim.

Please note that we will continue to retain your personal data in the aforementioned circumstances and we will only process your personal information under these circumstances if:

  • We have your consent;
  • Where such processing of personal information will be in the public interest; or
  • We need to process your personal information to establish, exercise or defend a legal claim.
Your right to file a complaint

If you are of the view that our processing of your personal data is infringing your privacy rights or any applicable privacy laws governing your personal data, you may file a complaint with a supervisory authority responsible for data protection in your country of residence (if you are living in EEA) or in Estonia at:

Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Väike-Ameerika 19
10129 Tallinn
Tel.: +372 6274 135
Fax: +372 6274 137
e-mail: info@aki.ee
Website: http://www.aki.ee/en

Your right to withdraw your consent

Where we use consent as the legal basis for processing your personal information, you have the right to withdraw your consent anytime by giving us a written notice of your withdrawal at .

8. Security of your data

We endeavour to keep all your personal data secure and we use all reasonable and commercially viable methods and techniques to protect your data. However, as with most online storage and transmission of data, there may be vulnerabilities that we are not aware of therefore we are unable to offer any guarantees as to the security of your data. As you are not required to provide any personal information to use the App, the risk is limited.

9. Third-party website links

Our App may contain links to third party websites that are neither owned nor operated by us. Should you decide to click on any such third party links, you will be directed to such third party website. These third-party sites have their own Terms of Service and Privacy Policy and we encourage you to review their Terms and Privacy Policy prior to using their site or any services offered by them.

We disclaim all liability with regards to your use and access of such third-party sites. We cannot be held responsible for any content made available by these third-party sites or their practices. Your access and use of these sites solely at your own risk.

10. Protection of Children’s Privacy

Our App is not aimed at persons who are under the age of eighteen (18) years ("Children"). If you are the parent / legal guardian of a Child who you believe has provided us with his/her personally identifiable information, please contact us with the relevant information and we will investigate the matter and take appropriate action. We do not knowingly collect any personal information from children.

11. Contact us

If you have any questions regarding this Privacy Policy, please contact us at the details provided hereunder:

Email:
Address: Sepapaja 6, Tallinn 15551, Estonia