By downloading, installing and using the Mobile application you (hereinafter also referred to as "User") with your own free will and for your benefit give your written consent to the processing of User's Personal Information for the purposes and under the terms and conditions stipulated by this Policy.
1. General Provisions
1.1. This Policy is an integral part of the End User License Agreement for the Mobile application (hereinafter referred to as the "EULA"). Therefore, when executing the above said EULA by methods defined therein including by downloading, installation and using the Mobile application you fully accept the terms of this Policy.
1.2. Methods of processing of Personal Information include any action (operation) or a combination of actions (operations) with Personal Information including collection, recording, systematization, storage, updating (refreshment, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction in the purposes established by this Policy with/without the use of automated facilities.
1.3. The terms and definitions provided for by the EULA are used herein, as well as other agreements entered into with the User, unless otherwise provided for by this Policy or follows from the merits thereof. In other cases, the terms used in the Policy shall be interpreted in accordance with the applicable laws, the business practice, or scientific doctrine.
2. Personal Information
2.1. When using Mobile application for its intended purpose User does not actively provide any information about him/her. Ylee Studio Ltd does not collect and store the data that enables identification of User (personal data).
2.2. Personal Information in this Policy means as follows:
2.2.1. User's e-mail or Instagram account that User provides when agreeing to complete product survey that can be offered only to Users who made purchase in the Mobile application.
2.2.2. Data transmitted in a depersonalized form in automatic mode, depending on the settings of the User's software including operating system of User's device.
2.3. User acknowledges and accepts the possibility of using third party software in the Mobile application; as a result, such third parties can receive and transmit the data in a depersonalized form as stipulated in the paragraph 2.2.2 hereof.
The aforementioned third party software may includefollowing analytic systems:
Facebook SDK', that is software product of Facebook and that collects and processes data according to data use policy available at: https://web.facebook.com/full_data_use_policy;
'Firebase', that is software product of Google and that collects and processes data according to data use policy available at: https://policies.google.com/privacy;
Such data collected with third party software may include:
User's device data, including unique identifiers of User's device, its location (country and city), operating system data (type, version, screen resolution) and so on;
query data (time, source, IP address);
other information about User's activity in the Mobile application.
The scope and conditions for collection and use of impersonal data by such software's titleholders are determined directly by its titleholders and governed by documents available at their websites.
Accepting this Policy as well applying certain setting in his/her software including device's operating system, the User agrees with conditions for collection and use of data by the titleholders of above listed software.
2.4. Ylee Studio LTD will not verify the reliability of the provided Personal Information and whether the User has the necessary consent for the processing thereof in accordance with this Policy, believing that the User acts in good faith, carefully and makes every effort to keep such information up to date and obtain all necessary agreements of the subjects of personal data.
2.5. User acknowledges and accepts that Ylee Studio LTD collects and stores for short time audiovisual works (Instagram stories) created by User in Mobile application. Such works are not Personal Information. User grants Ylee Studio LTD with limited non-exclusive royalty-free right to collect, store and analyze such works for not longer than a week and solely for the purposes of improvement and further development of Mobile application.
3. Legal basis of processing of Personal information
The legal basis on which Klimin Marketing SpA relies for the use of Personal information includes:
3.1. Processing of Personal information where User has given consent for one or more specific purposes;
4. Policy with regard to children
4.1. Ylee Studio LTD does not intentionally collect personal data from children younger than 16, it does not request it and does not allow them to use the Mobile application. If Ylee Studio LTD gets to know that the information was collected from a child under 16, Ylee Studio LTD shall immediately delete such information. If you think we could have obtained any information from a child or about a child under 16, please, contact us through e-mail: email@example.com.
5. Purposes for Personal Information Processing
5.1. Klimin Marketing SpA is entitled to use the Personal Information for the following purposes:
5.1.1. Communication with the User by email or Instagram for the purpose of information services and marketing of the Mobile application. At any time, you can give up on this service following the instructions through a link in a letter or you can write to us at firstname.lastname@example.org to ask to remove your data from the mailing list.
5.1.2. Marketing, statistical and other research based on depersonalized data from the analytics systems stipulated in the paragraph 2.3 hereoffor the purpose of improvement of Mobile application.
5.1.3. Targeting of advertising and/or informational materials based on depersonalized data from the analytics systems stipulated in the paragraph 2.3 hereof.
6. User's Rights to User's Personal Information
6.1. Subject to specific provisions of applicable law, the User has the right:
6.1.1. to be informed about the collection and use of his/her personal data.
6.1.2. to access his/her personal data and have it corrected if it is wrong or incomplete.
6.1.3. to restrict the processing of his/her personal data where the accuracy of the personal data is contested, where the processing is unlawful, and where Klimin Marketing SpA no longer needs the personal data for the purposes for which Klimin Marketing SpA has processed it.
6.1.4. to object to the processing of his/her personal data and also restrict its processing in those instances where Klimin Marketing SpA undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing.
6.1.5. to withdraw consent that User had given to the collection and processing of his/her personal data at any time. If User does withdraw his/her consent to the collection and processing of personal data, that withdrawal shall not affect the lawfulness of any processing by Klimin Marketing SpA that is based on the consent User had given before he/she withdrew it.
6.1.6. to obtain the deletion of his/her personal data when it is no longer relevant to the purposes for which it was collected or processed, when User has withdrawn consent and there is no basis for us to continue processing, when User has objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.
6.1.7. not to be a subject to a decision based solely on automated processing, including profiling, which produces legal affects concerning User or similarly affecting User, except where there is a lawful basis for continued processing.
6.1.8. to receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where Ylee Studio LTD processes by automated means personal data that User has provided.
6.2. These rights may be exercised by contacting Klimin Marketing SpA with specific request through the methods described below. Klimin Marketing SpA will address any such requests in a timely manner and according to applicable law. In certain cases, Klimin Marketing SpA may ask User to verify identity before acting on User's request. If User is unsatisfied with Klimin Marketing SpA's response, User may refer his/her complaint to the relevant supervisory authority in User's jurisdiction.
7. Personal Information Storage Retention
7.1. All Personal Information that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, or as long as is permitted or required by applicable law. Periodically, Klimin Marketing SpA will review its data processing systems to determine whether or not the purposes for the collection and processing of User's personal data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with Klimin Marketing SpA, whether or not any requests made by User from Klimin Marketing SpA have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and Klimin Marketing SpA, and whether or not there is a contractual or legal basis for continuing to retain User's personal data. Based on that review and any notifications received from data subjects, Klimin Marketing SpA will update its systems.
8. Requirements for the Personal Information Protection
8.1. Klimin Marketing SpA stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.
8.2. Klimin Marketing SpA keeps User's Personal Information confidential.
9. Transfer of the Personal Information
9.1. Klimin Marketing SpA is entitled to transfer Personal Information to third parties in the following cases:
9.1.1. The User expressed his/her consent to such actions, including when the User applies the settings of the used software that do not limit the provision of certain information;
9.1.2. The transfer is necessary in the context of the User's use of the Mobile application's functionality;
9.1.4. In connection with use in Mobile application of third party software for collection and processing of User's data. Specifically, Klimin Marketing SpA may use the third party software for collection and processing of User's data according to clause 2.3. of this Policy.
9.1.5. Due to whole or partial transfer of Klimin Marketing SpA's assets to the third party, including assignment of rights under agreements concluded with the User in benefit of such third party;
9.1.6. Upon request of a court or other state authority within the procedure established by law;
9.1.7. To protect the rights and legitimate interests of Klimin Marketing SpA in connection with failure to comply with the agreements entered into with the User.
10. Amendments to and deletion of the Personal Information
10.1. Any questions related to this Policy, use, amendment, deletion of the User's and/or exercising of any User's rights with respect to the Personal Information can be mailed to Klimin Marketing SpA at the address: email@example.com
11.1. This Policy may be amended or terminated unilaterally by Ylee Studio LTD without prior notice to the User. The User is recommended to read this Policy in the current version regularly.
11.2. The new version of the Policy becomes effective upon its placement, unless otherwise provided for by the new version of the Policy.
11.3. The current version of the Policy is available at: https://klimin.marketing/pages/privacy-policy.
Klimin Marketing SpA
Address: 13 Norte 853, Oficina 803, Viña Del Mar, Chile
The current version of the Policy of 01.10.2023