Privacy Policy

SIMPLIFIED SUMMARY

Controller of personal data: STRV s.r.o. (“STRV"), with its registered office at STRV s.r.o., Rohanské nábřeží 678/23, Karlín, 186 00 Praha, Czechia.

Personal data processed: We process data necessary for proper functioning of the Enter App, i.e. all data that you enter into your profile (such as your name). We also collect information about your use of our services, such as access log that are necessary for the proper functioning of the Enter App and performance of our contract.

You have a right to delete or modify data provided to the Enter App or delete your account at any time.

Purposes of personal data processing: We are processing your data mainly for providing our services and for the right functioning of the Enter App and performance of our contract with you.

Legal basis for processing: We are processing your data mainly with respect to performance of a contract with you, further based on legitimate interests, for complying with applicable laws.

Our legitimate interests: The main reasons for collecting data based on legitimate interests are improvement of our service, the safety of our users and enforcement of our rights.

Categories of recipients of the personal data: We provide information that we process, including personal data, only in the necessary scope to third parties that provide us with services, in particular, cloud data centers, communication, data hosting and maintenance providers, services for payment process, security operations, analytics suppliers, application developers and customer care center service.

Transfer of personal data: Your personal data might be transferred to other countries. In this process, we pay attention to the highest possible data protection in compliance with the General Data Protection Regulation (GDPR).

Storage period: Your personal data are stored only as long as we need it for legitimate reasons and as it is required by applicable law. In most cases, we will delete your data within 6 months of receiving your request for their deletion or after you deleted your account in the application.

Your rights: You have the right to request us to change, delete or update (correct) your personal data. You also have the right to limit their processing, to object to the processing of personal data or/and to receive a copy of your data.

Right to lodge a complaint: You also have the right to lodge a complaint with respective supervisory authority.

FULL WORDING OF PRIVACY POLICY

STRV s.r.o., with its registered office at STRV s.r.o. Rohanské nábřeží 678/23, Karlín, 186 00 Praha, Czechia. (“we” or the STRV), is controller of personal data and operator of the Enter application (“Enter application”, “Enter App” or “Application”).

When you use the Enter application (“Services”) you entrust your data to us, including your personal data.

This privacy policy will inform you of the data we collect, why we collect the data, how long we store the data, and what we do with the data.

If you want to use the Enter application, please thoroughly acquaint yourself with the content of this privacy policy. By signing up you agree with the privacy policy and you acknowledge the processing of personal data by the company STRV as the controller of the personal data.

What data do we collect and process?

The Enter App collects and processes personal data (such as your email or name) and other types of data. All personal data that you provide to us are optional except your e-mail address. We also collect information about your use of our Services, access log and activity.

Information you provide

When registering on the Application, you use the registration form. In this form you provide us the following information (if your profile is complete): your name, e-mail address, age, sex (gender), your height and weight.

When you subscribe to a paid service, you provide to our payment service provider (Apple, Google) payment information (card number and other payment information) in accordance with the Privacy Policy of these providers.

When you contact our support team, we collect the information provided in this communication.

Sensitive personal data
We do not process sensitive personal data.

Information from social sites
We do not process information from social sites.

Localization data
We do not process localization data.

Information we collect when you use the Enter application

We collect and process information about how you use the Enter application and what type of devices you use.

This information includes the language setting of your mobile device or information about how you have used our services, time when you joined, when you did a specific exercise and its result, time you spend using the Application, the features you use.

We also collect other information about the device you use including information about software and hardware (IP address, device type and ID).

Voluntary nature of personal data

Providing any personal data is completely voluntary. The only mandatory information is your e-mail address. Providing other information is completely voluntary for the user.

“Information we collect when you use the Enter application” is always collected only when you use the Enter application.

How we use the information we collect

We use the information we collect for operating the Enter application (i.e., for performing the contract that you have with us) and in this connection for improving and developing new services, and for protecting our company, you and other users of the Enter application.

In addition, we use this information for marketing and commercial purposes so that we can offer you relevant products and services from our company. Thus, we can send you a commercial communication (such as an SMS, MMS, e-mail, etc.) using the electronic contact you provided to us. You are entitled at any time, even when sending individual messages, to decline any other commercial communication.

We can use the data we collect for the following purposes, in particular for:

Legal bases for process your information
We process your information using the following legal basis:

To whom do we disclose the information we collect?

Disclosure to other users of the Enter application

Your profile in the Enter application is not visible to other Enter application users. If you use the data sharing feature, the application will provide your activity data to other users as well. You can deactivate this feature at any time.

Third-party disclosure – personal data processors

We provide information that we process, including personal data, only in the necessary scope to third parties that provide us with services, in particular, cloud data centers, communication, data hosting and maintenance providers, services for payment process, security operations, analytics suppliers, application developers and customer care center service. When choosing third parties, we pay attention to the reputation of these subjects and require their strict adherence to personal data protection requirements, corresponding to the high standards of regulations in the European Union.

We never provide your data to third parties for any marketing or commercial purpose.

Other disclosure

We could be required to provide your personal data under law or for fulfilling mandatory duties (e.g. for criminal, court, or administrative proceedings). In this case we are authorized, if necessary, to disclose your personal data in order to protect our rights or the rights of third parties or in order to protect users of the Enter application.

We are authorized, if necessary, to disclose your personal data in order to enforce our agreements with you and to mitigate the liability of the STRV.

Your rights (Access to and updating personal data)

We provide you access to your personal data each time you use the Enter application.

You have control over your personal data. You may change, delete or update any of the personal data at any time in the Settings section.

Whilst respecting limits and rules of the applicable regulation, you have the following rights:

In this respect, you may change the settings on your device as access to other applications (as Apple Health App), notifications etc. Please note that if you disable certain accesses, our Service may not be complete and lose functionality or part thereof.

You may also request information or change the settings by sending a request to the e-mail address: team@enter.xyz or cancel your profile in the Enter application at any time in Profile – Settings – Delete Account. Please note that uninstalling the application from your device will not delete your Account.

For the purpose of your safety, we may ask you to provide us with proof of your identity. We may also reject your requests in the case that the request is unlawful.

Storage period of your information

Your personal data are stored only as long as we need it for legitimate reasons and as it is required by applicable law. We store your personal data for the duration of your profile in the Enter application, unless stated otherwise.

After you delete your profile in the Enter application, some of the data may still be stored by us, for legitimate or technical reasons, in our databases or the databases of our partner(s) for a limited period of time.

We will delete your personal data as follows:

If you require deletion or if you delete your Account all personal data, including your profile, are deleted within 6 months of receiving the request – this period is set to protect us and may further be prolonged in justified cases.

Protection and security of personal data

We make every effort to protect you from unauthorized access or unauthorized changes, publication, or deletion of the information we collect.

We disclose personal data only to employees and contractual partners who need to process the data on our behalf. All employees and contractual partners are bound by the duty to uphold confidentiality.

We protect personal data to the maximum extent possible with the help of advanced encryption technologies.

We regularly inspect and update the process of collection, storage, and processing of information in order to prevent unauthorized access to our systems.

However, we are not liable for any unauthorized infringement by third parties, as a result of which these parties obtain unauthorized access to your profiles or personal data and misuse these data or disclose them to third parties, if such infringement took place as a result of circumstances which we are not able to influence.

If, despite all our efforts, an unauthorized leak of personal data will take place, we might need to notify the relevant supervisory authority and follow procedure prescribed by law in this respect.

Where are your data collected?

Your personal data are collected and processed mainly at our headquarters in the Czech Republic.

In view of the fact that we use cloud services for the Enter application and your personal data may be stored in data centres of these providers, your personal data may also be transferred to other EU countries and to the USA or other jurisdictions that have different privacy laws. All processors of personal data with a processing location in the USA are bound under the SCC („Standard contractual clauses for data transfers between EU and non-EU countries“) or another transfer mechanism that the competent

authorities consider adequate. All our providers ensure the protection of personal data in compliance with the General Data Protection Regulation (GDPR) applicable in the European Economic Area.

Changes to the privacy policy

Our privacy policy may be amended from time to time.

The current version of the privacy policy, all changes, and all previous versions will be available on these web pages. If it involves significant changes, we will prepare for you a summary and explanation.

You acknowledge these changes to the privacy policy by continuing to use the Enter application after being notified of the changes and their effective date. If you do not agree to the changes, discontinue your use of the Enter application and delete your profile from the Enter application.

How to contact us

Should you have any questions or comments relating to the privacy policy, please contact us at the following e-mail address: team@enter.xyz or to the address STRV s.r.o., Rohanské nábřeží 678/23, Karlín, 186 00 Praha, Czechia.

Version 1.0, valid on 1 July 2022