Last updated March 21, 2021
Digital Growth Marketers Oü (“Digital Growth Marketers,” “Puro”, “us,” “we,” or “our”) is committed to protecting and respecting your privacy in connection with your use of our website, www.puromeditation.com (the “Website(s)”), applications (“Apps”) and other products, services and features thereof (the Website, the Apps and such other products, services and features are collectively referred to herein as the “Service” or “Services”). This privacy statement (“Privacy Statement”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Services will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data.
Digital Growth Marketers processes personal data of the users of the Puro app (“Puro App”) and the visitors of the website puromeditation.com (“Website”).
In this Privacy Statement, the word “Puro Services” refers jointly to the Website and the Puro App. In this Privacy Statement, the word “User” or “you” refers jointly to our customers, potential customers and the users of the Puro Services.
Our Privacy Statement explains, for example, the types of personal data we process, how we process the personal data and how you may exercise your rights as a data subject (e.g. right to object, right of access).
This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy Statement or reduce the rights of the Users under this Privacy Statement without providing a notice thereof.
1. DATA CONTROLLER
This Privacy Statement applies to processing of personal data carried out by Puro. In relation to the processing of personal data of Users, Puro is acting as the data controller.
2. CONTACT DETAILS
Name: Digital Growth Marketers Oü
Business ID: 16157100
Correspondence address: Telliskivi 60 10412 Tallinn
E-mail address: [email protected]
3. PERSONAL DATA PROCESSED AND SOURCES OF DATA
The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.
3.1 User Data
User Data is personal data collected directly from you. We may collect User Data from our Users in a variety of ways, including, when Users register to the Puro Services, subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments you carry out through the Puro Services.
- User Data that is necessary in order to use the Puro Services
The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us and for the compliance with our legal obligations.
When you register to the Puro Services and create a user account, you need to provide us with the following information:
When upgrading to a paid subscription: information relating to your payment instrument(s) such as the number of your payment instrument(s) and the expiration date of your payment instrument(s) (required for the purposes of purchasing a paid subscription on the Puro Services, however not stored by Puro, since Puro uses a third party payment service provider for processing of payments)
- User Data you give us voluntarily
We may also process other information provided by you voluntarily such as:
- information you provide when rating our services
- marketing opt-ins and opt-outs
- information you provide by phone or in email or chat correspondence with us, including call recordings of your calls with our customer service
In addition to User Data collected from you and the Customer Organization, we process certain personal data third party service providers provide about you.
If you connect or login to your account with Facebook, Facebook shares with us personal information about you such as your profile picture, a sample of your Facebook friends and your Facebook ID.
3.2. Analytics Data
Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
- We may automatically collect the following Analytics Data when you visit or interact with the Puro Services:
- We collect the following information relating to the technical device you use when using the Puro Services:
device and device identification number, device IMEI
browser type and version
Internet service providers
advertising identifier of your device
- Usage Information. We collect information on your use of the Puro Services, such as:
time spent on the Puro Services
interaction with the Puro Services
the URL of the website you visited before and after visiting the Puro Services
the time and date of your visits to the Puro Services
the sections of the Puro Services you visited
the content you searched for while using the Puro Services
We use various technologies to collect and store Analytics Data and other information when the Users visit the Puro Services, including cookies and web beacons.
A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.
Web analytics services
The Puro Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Puro Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
Advertising and visitor identifiers
The Puro Services use pseudonymized identifiers to track and predict your app and service usage and preferences.
4. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
There are several purposes of the processing of your personal data by Puro:
- To provide the Puro Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
Puro processes your personal data to be able to offer the Puro Services to you under the contract between you and Puro.
We use the data for example to answer your questions or requests for information or handle your complaints. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
- For our legal obligations (legal ground: compliance with a legal obligation)
Puro processes data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
- For claims handling and legal processes (legal ground: legitimate interest)
Puro may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
- For customer communication and marketing (legal ground: legitimate interest)
Puro processes your personal data to contact you regarding the Puro Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Puro Services to you.
- For quality improvement and trend analysis (legal ground: legitimate interest)
We may also process information about your use of the Puro Services to improve the quality of the Puro Services e.g. by analyzing any trends in the use of the Puro Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
Puro processes your personal data to perform our contractual obligations towards you and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
In some parts of the Puro Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
5. TRANSFER TO COUNTRIES OUTSIDE EUROPE
Puro stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards.
More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.
We only share your personal data within the organization of Puro if and as far as reasonably necessary for the purposes of this Privacy Statement.
We do not share your personal data with third parties outside of Puro’s organization unless one of the following circumstances applies:
- For the purposes set out in this Privacy Statement and to authorized service providers
- To the extent that third parties need access to personal data in order for us to perform the Puro Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales and marketing) to process it for us and to payment service providers to process your payments to us.
When data is processed by third parties on behalf of Puro, Puro has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.
Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Puro Services, the processing is typically based on their policies and standards.
- For legal reasons and legal processes
We may share your personal data with third parties outside Puro if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Puro, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
- For other legitimate reasons
If Puro is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different privacy statement.
- With your explicit consent
We may share your personal data with third parties outside Puro when we have your explicit consent to do so. You have the right to withdraw this consent at all times free of charge by contacting us.
7. STORAGE PERIOD
Puro does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Puro Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.
Most personal data relating to a User’s user account with the Puro Services will be deleted after a period of 90 days have lapsed after the User has deleted its user account with the Puro Services. Thereafter, a part of the personal data relating to a User’s user account with the Puro Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a User’s user account with the Puro Services will be deleted within a period of 10 years after the User has deleted its user account with the Puro Services, with the exception of personal data required in certain rare situations such as legal proceedings.
We will store Analytics Data of Users that do not have an account with the Puro Services for a period of 90 days.
8. YOUR RIGHTS
Right of access
You have the right to access and be informed about your personal data processed by us. We give you the possibility to view certain data through your user account with the Puro Services or request a copy of your personal data.
Right to withdraw consent
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use the Puro Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the Puro Services.
Right to erasure
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Puro Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Puro Services.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Puro Services.
Right to data portability
You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
How to use your rights
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject or charge requests that are unreasonably repetitive, excessive or manifestly unfounded.
9. DIRECT MARKETING
The User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the Puro Services or the unsubscribe possibility offered in connection with any direct marketing messages.
10. LODGING A COMPLAINT
In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, the User may lodge a complaint with the local supervisory authority for data protection in Estonia, the Data Protection Officer (https://www.aki.ee/en/data-protection-officer/data-protection-officer). Alternatively, the User may lodge a complaint with the local supervisory authority for data protection of the User’s country of domicile.
11. INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Puro Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.