Indoorway sp. z o.o. (limited liability company registered under Polish law with its registered seat in Lublin (address: Tomasza Zana 39, 20-634 Lublin), Poland; entered into the register of entrepreneurs of the National Court Register with its registration no. 0000660847; “Indoorway”) is a software provider of development tools and services for developers of mobile applications that use our positioning technology (“Developer”; “you”). We provide you with our software development kit (“SDK”) supplemented by our applications and services associated therewith (“Services”). Indoorway is the controller of your personal data processed as described in this Privacy Policy.

This Indoorway Developer Privacy Policy applies to you if you use our products and services in order to develop and/or distribute an application integrated with our positioning technology and Services (“Application”) that support such application in obtaining and processing end-user’s location data and to provide other services such as push messages. This Developer Privacy Policy applies to all personal data that we receive from you and is collected and processed by our Services and SDK for and within Application.

By accessing or using the Services you agree to be bound by all terms and conditions of this Indoorway Developer Privacy Policy and that you are of legal age in your country of residence.

Information that we collect

We collect information on you which is necessary for the use of all features of our Services within Application. We strive to provide you the highest level of our Services hence we may process your data:

• for registration purposes, maintenance of your user’s account,
• for payment settlement,
• to communicate with you,
• for the purposes of provision, development, improvement and support of the Services,
• for statistical purposes and market research,
• for preparing reports based on aggregated data
• for direct marketing within the limits of applicable law after receiving you consent, and
• in execution of any obligations arising under a provision of law.

We may collect and process all data you will provide us with in order to use our Services, in particular:

• your compulsory account information (username, password, company name, name and surname, e-mail address, phone number, information whether the user is a natural person or a company, address for correspondence (street, building and premises number, city, postal code, country), name and surname of all sub-users within your account, VAT identification number),
• history of your Indoorway account (payments; accepted terms of use of our Services; reports and actions registered in connection with Application and Indoorway account; history and content of correspondence with us; IP addresses; version of software; information on which tools are being used and how they are used; end-users’ data gathered through the Application and Services).
• other information you provide us with in connection with Application and the use of our Services;
• device-specific information.

Provision of the above data is in principle voluntary, however non-provision will make it impossible to perform the contract with you and to provide you with our Services or enable the use of Application by you.

Please note the above applies to the data of Admin, Manager, Editor or Analyst added by you to the Services.

We process your personal data based on the following legal grounds:

• processing of your data is necessary for the performance of the contract between Indoorway and you (this relates to the compulsory account information, history of your Indoorway account and other information you provide us with in connection with the Application and the use of our Services);
• by processing your personal data, we pursue our legitimate interest in (i) direct marketing of our services (your name, surname and contact details) and (ii) improving the way our Application and Services function (this relates to history of your Indoorway account, device-specific information).

We may also process your data based on explicit consent in some circumstances. In the event that we obtain consent from you in order to process your personal data, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing conducted prior to such withdrawal.

Indoorway may prepare and share reports based on aggregated, non-personally identifiable information. The reports may be shared publicly and with our partners.

Please also note that certain information is collected by us automatically through the use of cookies which may be used:

• to adapt our website content to your preferences and to optimize our website and Services performance (cookies helps us to recognize your device and provide it with a proper tailored content),
• to assess your use of our website and Services and for statistical purposes in order to improve their content and structure,
• to maintain your login session (hence you do not need to login on every subpage),
• to provide you with advertising content adapted to your preferences.

We use cookies such as:

• session cookies (including authentication cookies),
• secure cookies (for safety purposes, including detection of any authentication fraud of user account,
• performance cookies (they gather information on the way you use our website and Services),
• functional cookies (they help us with personalization of website and Services by remembering data such as language, your localization, size of font, look of the website and others),
• advertising cookies (they help us with personalization of advertisements).

Apart from the above we collect automatically also all data recorded in connection with your use of Services and your Indoorway account such as login data, time of use, IP address, technical data of web browser, operational system, data of your Internet providers, your habits and all marketing preferences, behavioural data and other provided within Google Analytics (for more information please visit Google Analytics website)

How to opt out from cookies - you can learn more about cookies and ways to disable or clear them by visiting the following website: http://www.allaboutcookies.org/manage-cookies/.

Protection of the information we collect

We attach utmost attention to proper protection of your personal data that is collected by us in connection with the Services from any unauthorized access, use or disclosure. Please note that we cannot guarantee that an unauthorized access shall not occur as a result of illegal actions taken by hackers. If such infringement occurs we will take all necessary steps to minimize the use, loss or alteration of your data.

We also make sure that your data is processed only for as long as necessary, in accordance with principles of adequacy and minimization of personal data. We process your data for the entire duration of our contractual relationship with you. We can also process your personal data after termination of the contract, for the purpose of exercise or defence of potential legal claims, as well as for tax and accounting purposes. In such case document retention and limitation periods provided by Polish law apply.

For the provision of Services we may share your data with third parties such as:

• our contractors by which we provide and manage our Services, in particular any services providers,
• our advertising partners,
• our present or future subsidiaries, affiliated companies or other entities in our capital group,
• public authorities or
• third parties when such share of data is required or permitted by law.

As to provide you with proper Services and for our internal or industry analysis we may also share aggregated and statistical information with third parties.

We store and process your data on our servers maintained in Poland. However, when such necessity occurs and to ensure the quality of our Services we reserve the right to transfer your data to servers located on the territory of European Economic Area or other countries in the world. In such case, we assure you that your data is being processed in accordance with high standards of personal data protection and in compliance with applicable EU and national legislation. Prior to any transfer of your data outside the European Economic Area, we will make sure that we have appropriate safeguards in place (either an agreement based on European Standard Contractual Clauses, appropriate certification or adherence to a code of conduct, or Privacy Shield certification in case of transfer to USA). If such transfer requires your consent we will ask you for permission for such transfer.

Your rights

You have the right to request access to your data and to have it corrected or erased. You also have the right to temporary restriction of processing and you can object to the processing of your data when it is processed by Indoorway based on our legitimate interest. In particular can object to the processing of your data for marketing purposes, which in practice means that you can resign at any time from receiving our electronic direct marketing communications. You can also request that we transfer your personal data to a different controller (right to data portability).

If you wish to exercise your rights or if you have any questions on how we process your data, you can contact our appointed data protection officer at [email protected]. You also have the right to lodge a complaint with the Polish data protection authority.

Changes

We may modify or revise this Indoorway Developer Privacy Policy at any time. Any change to this Privacy Policy will be notified to you by making available a new version of this Privacy Policy on our website and in Services or via e-mail.

2019 Indoorway sp. z o.o. All rights reserved.