Privacy Policy

introduction

This Privacy Policy is a legally binding contract between Grotem Limited, a Limited Liability Company incorporated and registered in the Republic of Cyprus under registration number, HE 428814 having its registered address at Cyprus,Nicosia, 2350, Agiou llarionos 5, Anthoupoli, Nicosia (referred to as "we," "us," or "our"), and users of the Plantyx - Plant Identification application, which is distributed via application stores (referred to as the "App") and Website.

general

Regarding the Services: Grotem Limited ("Grotem Limited", "we", "us" or "our") is the Data Controller within the meaning of the General Data Protection Regulation ("GDPR").

This privacy policy shall inform you on how we collect, process and use ("Use") personal data in connection with the Services.

what information do we collect?

When you use the Services, we collect certain personally identifiable information that can be used to identify you (“Personal Data”). Our Services are designed to avoid collecting information such as your name, address, email address or other similar contact data. However, in certain cases we may process such data, if you provide them to us (for example, if you resort to our support team).

We will ask you to provide the following personal information about you:

Information you give us: This is information about you that you give us by filling in your details when using our app for the first time. The information you give us may include your: name, gender, relationship status, place of birth, date of birth, time of birth, a line/shape model of your left and right palm and, if you lodge a customer query, your email address and any other information about yourself you choose to provide to use us when you lodge a customer query with us.

We do not collect or store the above personal information.

Information we collect about you: We will collect a non-personally identifying device ID from Apple in order to link your use of the app for billing through iTunes.

Information collected by third parties: This is information collected by third party SDKs on the app and our website providers. They will collect the following data related to your usage: your IP address, cookies, unique device identifiers, URL, and the sequence of pages visited. We do not collect this information ourselves and it is collected by the relevant third parties as data controllers. This information is only shared so as to allow the app to operate. To see how they use this information please refer to their privacy policies. We have provided links to these. If you do not want to share this information you should adjust your device privacy settings to “do not track”. We have set out how to do that below.

do we process your payment information?

Our Services include in-app purchases, e.g. subscriptions. If you want to make an in-app purchase, you may do this with the help of in-app payment system provided by the Platform and integrated in the Services. The in-app payment system is managed by the Platform administration or its authorized partner. Under no circumstances does Grotem Limited collect or process any information related to your payment instrument, such as bank card number, its validity term or your name as written on it.

do we provide third parties with personal data or get personal data from third parties?

Yes. For the purposes of analytics and advertising, we use services and solutions provided by third parties. Such parties process data on our behalf and the respective technical solutions represent a part of the Services. Any transfer of your Personal Data is based on a written agreement, and we make sure such a third party complies with the applicable data protection regulations. Such third parties process Personal Data in accordance with their own privacy policies.

In certain cases we may transfer information about you to other third parties (for example, independent personal data controllers), if we are obliged or allowed to do so by applicable laws. If it is the case, we transfer such information while adhering to applicable personal data protection laws.

If Grotem Limited is involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control, we may transfer Personal Data, together with business assets, to another company. In this case the respective notification will be available on the web-page of the Privacy Policy.

We also may transfer your Personal Data to a third party in the following cases:

• if we need so to protect legal rights of Grotem Limited, our end users, business parties or other interested parties;
• if we need so to enforce our agreements with you;
• if we need so to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

for what purposes do we process personal data?

We process Personal Data for the following purposes:

• to provide and maintain the Services, make the Services available to you if you switch devices or temporarily stop using the Services, as well as to manage everyday business activity related to the Services.
• to manage and protect the Services (e.g. to collect analytics, test, support end users, report illegal activity, etc.).
• to communicate with you with regard to your inquiries submitted to our support team.
• to analyze how you use the Services in order to plan further development of the Services, keep the Services updated and improve them.
• to advertise our Services.

for how long do we retain personal data?

We retain all Personal Data for as long as you use the Services and 24 months after you stop using the Services. If you do not use the Services for 24 continuous months, we erase your Personal Data from our data base, as well as request the same erasure from any third party, whom your Personal Data may have been transferred to. We may erase your Personal Data earlier if we do not need to process such data anymore.

If it is legally required that we retain your Personal Data for longer period for whatever purpose as stated in the applicable law, we will retain your Personal Data for the period determined by the law. We will immediately erase your Personal Data after such period expires or if the legal duty to retain such Personal Data is repealed.

We may retain your Personal Data longer only in case such Personal Data have been duly anonymized. After anonymization the data are not considered Personal Data, as the end user (the data subject) is no longer identifiable.

Please, take into account that erasure of Personal Data is irretrievable. After your Personal Data have been erased, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.

do we process any personal data of children?

The Services are intended to be used by end users older than 16 years old.

We do not use the Services to knowingly solicit data from or market to children under the age of 13.

If you believe that we process Personal Data of a child below 13 years old, please, contact us and we will make all reasonable efforts to stop processing such data and erase it as soon as possible.

what rights do you have with regard to your personal data?

Under the applicable data protection regulation, if you are a citizen of the EU and fall within the scope of a data subject, you are entitled to the following rights: right of access, right to rectification (correction), right to erasure (deletion), right to data portability, right to object, right to restriction of processing.

• right of access. You have the right to access your Personal Data, which we process;
• right of rectification (correction). You have the right to ask us to replace any inaccurate data about you with accurate data. If you think that the data we process are incomplete for the purpose of processing as stated in this Privacy Policy, you may ask us to complete your Personal Data accordingly;
• right to erasure (deletion). You have the right to ask us to completely delete your Personal Data;
• right to object. You have the right to object to processing of your Personal Data for the purpose of direct marketing;
• right to restriction of processing. Please, be informed that this right may be exercised only in a situation set forth in Article 18 of General Data Protection Regulation 2016/679;
• right to data portability. You have the right to ask us to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

do we control third-party web-sites?

This Privacy Policy may contain links to other web-sites that are not operated by us. If you click on such a link, you will be directed to that third party's site. We strongly recommend you to review the privacy policy and terms of use of every web-site you visit. Under no circumstances do we control third parties’ web-sites or assume any responsibility for the content, privacy policy, terms of use or practices of any third-party web-sites or services.

how do we advertise in the services?

We show advertisements in the Services with the help of third-party advertising partners. We integrate their technologies into the Services, which are then used by our partners to select the advertisements that meet your interests in the best way.

If you do not want to receive targeted advertisements, please, adjust settings of your device as instructed below.

how can you adjust privacy settings of your device?

If you want to adjust the privacy settings of your device, please, take the following steps:

• iOS operating system: enable Limit Ad Tracking on iOS by opening “Settings,” then tapping on “Privacy,” then “Advertising”, and sliding the Limit Ad Tracking switch to “On”.

how do we collect and process data for analytical purposes?

In order to analyze various aspects of the Services functioning, we need to collect and process certain information with regard to your interaction with the Services. Such information includes your location data, information about your device and advertising data. It may also comprise information about errors of the Services functioning. For this purpose we use technologies and solutions provided by third parties – our analytical partners. We integrate such technologies into the Services and our partners process the data on our behalf to provide us with analytics.

Processing data for analytical purposes is based on a legitimate interest of Grotem Limited – analyzing data about the Services for commercial purposes. Analytics helps us to provide better services to users, update and develop the Services. For example, we may use such information in order to fix errors of the Services, evaluate demographic composition of our users, determine what features to add to the Services or whether we need to translate the Game into another language.

changes to this privacy policy

We may need to change the Privacy Policy from time to time, and we encourage you to review it at least once per month. If you continue to use the Services after changes have been introduced to the Privacy Policy, this will mean that you have accepted such changes to the Privacy Policy.

In some cases, we may notify you of changes to the Privacy Policy with a prominent notice on the Services (for example by way of a notification or pop-up), before the changes become effective and update the "effective date" at the top of this Privacy Policy.

how to contact us

If you have any questions about this Privacy Policy, please feel free to contact us at [email protected]

Last Updated: August 21, 2024