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Privacy policy

Last updated September 04, 2023
This privacy notice for Apiir AS ("we," "us," or "our"), describes how and why we might
collect, store, use, and/or share ("process") your information when you use our services
("Services"), such as when you:
● Visit our website at https://www.apiir.tech/ , or any website of ours that links to this
privacy notice
● Download and use our mobile application (Apiir Bike Fit), or any other application of
ours that links to this privacy notice
● Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy
rights and choices. If you do not agree with our policies and practices, please do not use our
Services. If you still have any questions or concerns, please contact us at hello@apiir.tech.
SUMMARY OF KEY POINTS
What personal information do we process? When you visit, use, or navigate our
Services, we may process personal information depending on how you interact with us and
the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We may process sensitive personal
information when necessary with your consent or as otherwise permitted by applicable law.
Do we receive any information from third parties? We do not receive any information
from third parties.
How do we process your information? We process your information to provide, improve,
and administer our Services, communicate with you, for security and fraud prevention, and
to comply with law. We may also process your information for other purposes with your
consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third parties.
How do we keep your information safe? We have organizational and technical processes
and procedures in place to protect your personal information. However, no electronic
transmission over the internet or information storage technology can be guaranteed to be
100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by contacting
us at hello@apiir.tech. We will consider and act upon any request in accordance with
applicable data protection laws.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and Services,
when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends
on the context of your interactions with us and the Services, the choices you make, and the
products and features you use. The personal information we collect may include the
following:
● names
● email addresses
● mailing addresses
● usernames
● passwords
Sensitive Information. When necessary, with your consent or as otherwise permitted by
applicable law, we process the following categories of sensitive information:
● health data
● biometric data
● information revealing race or ethnic origin
● data about a person's sex life or sexual orientation
Payment Data. We may collect data necessary to process your payment if you make
purchases, such as your payment instrument number, and the security code associated with
your payment instrument. All payment data is stored by App Store and Google Play. You
may find their privacy notice link(s) here:
https://www.apple.com/legal/privacy/data/en/app-store/ and
https://play.google.com/about/play-terms/.
Social Media Login Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, Twitter, or other social media
account. If you choose to register in this way, we will collect the information described in the
section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
Application Data.
If you use our application(s), we also may collect the following information if you choose to
provide us with access or permission:
● Mobile Device Access. We may request access or permission to certain features
from your mobile device, including your mobile device's camera, microphone,
storage, and other features. If you wish to change our access or permissions, you
may do so in your device's settings.
● Mobile Device Data. We automatically collect device information (such as your
mobile device ID, model, and manufacturer), operating system, version information
and system configuration information, device and application identification numbers,
browser type and version, hardware model Internet service provider and/or mobile
carrier, and Internet Protocol (IP) address (or proxy server). If you are using our
application(s), we may also collect information about the phone network associated
with your mobile device, your mobile device’s operating system or platform, the type
of mobile device you use, your mobile device’s unique device ID, and information
about the features of our application(s) you accessed.
● Push Notifications. We may request to send you push notifications regarding your
account or certain features of the application(s). If you wish to opt out from receiving
these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our
application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and
you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser
and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services.
This information does not reveal your specific identity (like your name or contact information)
but may include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name,
country, location, information about how and when you use our Services, and other technical
information. This information is primarily needed to maintain the security and operation of
our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
● Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use
our Services and which we record in log files. Depending on how you interact with us,
this log data may include your IP address, device information, browser type, and
settings and information about your activity in the Services (such as the date/time
stamps associated with your usage, pages and files viewed, searches, and other
actions you take such as which features you use), device event information (such as
system activity, error reports (sometimes called "crash dumps"), and hardware
settings).
● Device Data. We collect device data such as information about your computer,
phone, tablet, or other device you use to access the Services. Depending on the
device used, this device data may include information such as your IP address (or
proxy server), device and application identification numbers, location, browser type,
hardware model, Internet service provider and/or mobile carrier, operating system,
and system configuration information.
● Location Data. We collect location data such as information about your device's
location, which can be either precise or imprecise. How much information we collect
depends on the type and settings of the device you use to access the Services. For
example, we may use GPS and other technologies to collect geolocation data that
tells us your current location (based on your IP address). You can opt out of allowing
us to collect this information either by refusing access to the information or by
disabling your Location setting on your device. However, if you choose to opt out, you
may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
● To facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
● To deliver and facilitate delivery of services to the user. We may process your
information to provide you with the requested service.
● To respond to user inquiries/offer support to users. We may process your
information to respond to your inquiries and solve any potential issues you might
have with the requested service.
● To send administrative information to you. We may process your information to
send you details about our products and services, changes to our terms and policies,
and other similar information.
● To request feedback. We may process your information when necessary to request
feedback and to contact you about your use of our Services.
● To send you marketing and promotional communications. We may process the
personal information you send to us for our marketing purposes, if this is in
accordance with your marketing preferences. You can opt out of our marketing
emails at any time. For more information, see "WHAT ARE YOUR PRIVACY
RIGHTS?" below.
● To deliver targeted advertising to you. We may process your information to
develop and display personalized content and advertising tailored to your interests,
location, and more.
● To protect our Services. We may process your information as part of our efforts to
keep our Services safe and secure, including fraud monitoring and prevention.
● To identify usage trends. We may process information about how you use our
Services to better understand how they are being used so we can improve them.
● To determine the effectiveness of our marketing and promotional campaigns.
We may process your information to better understand how to provide marketing and
promotional campaigns that are most relevant to you.
● To save or protect an individual's vital interest. We may process your information
when necessary to save or protect an individual’s vital interest, such as to prevent
harm.
● To enhance the accuracy and effectiveness of our app's functionality.. We
collect videos of users to facilitate the training of machine learning models. These
models are designed to automatically detect exercise state, movement
characteristics, body pose, environmental factors, as well as other anatomical
factors. By connecting the video records to data collected within the app, we aim to
improve the overall user experience and provide more personalized and valuable
insights to our users.
● To improve the accuracy and functionality of our machine learning models for
the benefit of our users.. We conduct reviews and annotations of recordings,
including videos, to gather valuable data regarding exercise states, movement
characteristics, body pose, other anatomical features, and environmental factors that
may affect body detection. This meticulous process aids in refining the performance
of our machine learning models, allowing them to provide more precise insights and
recommendations to users. It also contributes to the overall enhancement of our
app's functionality.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and
we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or fulfill our
contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the
valid legal bases we rely on in order to process your personal information. As such, we may
rely on the following legal bases to process your personal information:
● Consent. We may process your information if you have given us permission (i.e.,
consent) to use your personal information for a specific purpose. You can withdraw
your consent at any time.
● Performance of a Contract. We may process your personal information when we
believe it is necessary to fulfill our contractual obligations to you, including providing
our Services or at your request prior to entering into a contract with you.
● Legitimate Interests. We may process your information when we believe it is
reasonably necessary to achieve our legitimate business interests and those
interests do not outweigh your interests and fundamental rights and freedoms. For
example, we may process your personal information for some of the purposes
described in order to:
● Send users information about special offers and discounts on our products and
services
● Develop and display personalized and relevant advertising content for our users
● Analyze how our Services are used so we can improve them to engage and retain
users
● Support our marketing activities
● Diagnose problems and/or prevent fraudulent activities
● Understand how our users use our products and services so we can improve user
experience
● In order to enhance the app's functionality and provide users with more precise and
customized feedback and recommendations, we have a legitimate interest in
collecting and analyzing user videos to train and improve our machine learning
models. This helps us offer a more effective and tailored service to our users.
● In order to fulfill our legitimate interest in providing a superior user experience and
delivering more accurate insights to our users, we engage in the review and
annotation of recordings. This process involves both our dedicated employees and
official sub-processors, as defined under Article 28 of the GDPR. Our commitment to
data protection and privacy ensures that this valuable data is handled with the utmost
care and in compliance with relevant regulations.
● Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate with a law
enforcement body or regulatory agency, exercise or defend our legal rights, or
disclose your information as evidence in litigation in which we are involved.
● Vital Interests. We may process your information where we believe it is necessary to
protect your vital interests or the vital interests of a third party, such as situations
involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express
consent) to use your personal information for a specific purpose, or in situations where your
permission can be inferred (i.e., implied consent).
In some exceptional cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:
● If collection is clearly in the interests of an individual and consent cannot be obtained
in a timely way
● For investigations and fraud detection and prevention
● For business transactions provided certain conditions are met
● If it is contained in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim
● For identifying injured, ill, or deceased persons and communicating with next of kin
● If we have reasonable grounds to believe an individual has been, is, or may be victim
of financial abuse
● If it is reasonable to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is reasonable for
purposes related to investigating a breach of an agreement or a contravention of the
laws of Canada or a province
● If disclosure is required to comply with a subpoena, warrant, court order, or rules of
the court relating to the production of records
● If it was produced by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for which the information
was produced
● If the collection is solely for journalistic, artistic, or literary purposes
● If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or
with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your
data with third-party vendors, service providers, contractors, or agents ("third parties") who
perform services for us or on our behalf and require access to such information to do that
work. We have contracts in place with our third parties, which are designed to help
safeguard your personal information. This means that they cannot do anything with your
personal information unless we have instructed them to do it. They will also not share your
personal information with any organization apart from us. They also commit to protect the
data they hold on our behalf and to retain it for the period we instruct. The categories of third
parties we may share personal information with are as follows:
● Affiliate Marketing Programs
● Performance Monitoring Tools
● Sales & Marketing Tools
● Cloud Computing Services
● Data Storage Service Providers
We also may need to share your personal information in the following situations:
● Business Transfers. We may share or transfer your information in connection with,
or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
● Affiliates. We may share your information with our affiliates, in which case we will
require those affiliates to honor this privacy notice. Affiliates include our parent
company and any subsidiaries, joint venture partners, or other companies that we
control or that are under common control with us.
● Business Partners. We may share your information with our business partners to
offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to
access or store information. Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we
may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media
account details (like your Facebook or Twitter logins). Where you choose to do this, we will
receive certain profile information about you from your social media provider. The profile
information we receive may vary depending on the social media provider concerned, but will
often include your name, email address, friends list, and profile picture, as well as other
information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this
privacy notice or that are otherwise made clear to you on the relevant Services. Please note
that we do not control, and are not responsible for, other uses of your personal information
by your third-party social media provider. We recommend that you review their privacy notice
to understand how they collect, use, and share your personal information, and how you can
set your privacy preferences on their sites and apps.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your
own.
Our servers are located in EU, Belgium, Netherlands, and Finland. If you are accessing our
Services from outside EU, Belgium, Netherlands, and Finland, please be aware that your
information may be transferred to, stored, and processed by us in our facilities and by those
third parties with whom we may share your personal information (see "WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in EU, and other
countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or
Switzerland, then these countries may not necessarily have data protection laws or other
similar laws as comprehensive as those in your country. However, we will take all necessary
measures to protect your personal information in accordance with this privacy notice and
applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the
European Commission's Standard Contractual Clauses for transfers of personal information
between our group companies and between us and our third-party providers. These clauses
require all recipients to protect all personal information that they process originating from the
EEA or UK in accordance with European data protection laws and regulations. Our Standard
Contractual Clauses can be provided upon request. We have implemented similar
appropriate safeguards with our third-party service providers and partners and further details
can be provided upon request.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined
in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is required or permitted by law
(such as tax, accounting, or other legal requirements). No purpose in this notice will require
us keeping your personal information for longer than the period of time in which users have
an account with us.
When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further processing until
deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational
and technical security measures.
We have implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic transmission
over the Internet or information storage technology can be guaranteed to be 100% secure,
so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security and improperly collect, access, steal, or modify
your information. Although we will do our best to protect your personal information,
transmission of personal information to and from our Services is at your own risk. You should
only access the Services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using
the Services, you represent that you are at least 18 or that you are the parent or guardian of
such a minor and consent to such minor dependent’s use of the Services. If we learn that
personal information from users less than 18 years of age has been collected, we will
deactivate the account and take reasonable measures to promptly delete such data from our
records. If you become aware of any data we may have collected from children under age
18, please contact us at hello@apiir.tech.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom
(UK), Switzerland, and Canada, you have rights that allow you greater access to and control
over your personal information. You may review, change, or terminate your account at any
time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to request access and obtain
a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; (vi) if applicable, to data portability; and (vii) not to
be subject to automated decision-making. In certain circumstances, you may also have the
right to object to the processing of your personal information. You can make such a request
by contacting us by using the contact details provided in the section "HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection
laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your Member State data
protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable law,
you have the right to withdraw your consent at any time. You can withdraw your consent at
any time by contacting us by using the contact details provided in the section "HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from
our marketing and promotional communications at any time by clicking on the unsubscribe
link in the emails that we send, or by contacting us using the details provided in the section
"HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed
from the marketing lists. However, we may still communicate with you — for example, to
send you service-related messages that are necessary for the administration and use of your
account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate
your account, you can:
● Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our files
to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal
terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by
default. If you prefer, you can usually choose to set your browser to remove cookies and to
reject cookies. If you choose to remove cookies or reject cookies, this could affect certain
features or services of our Services. You may also opt out of interest-based advertising by
advertisers on our Services.
If you have questions or comments about your privacy rights, you may email us at
hello@apiir.tech.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected. At this stage
no uniform technology standard for recognizing and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future, we will inform you
about that practice in a revised version of this privacy notice.
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding
access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our
users who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar year. If you are
a California resident and would like to make such a request, please submit your request in
writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with
Services, you have the right to request removal of unwanted data that you publicly post on
the Services. To request removal of such data, please contact us using the contact
information provided below and include the email address associated with your account and
a statement that you reside in California. We will make sure the data is not publicly displayed
on the Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory
purpose and
(2) every individual who is domiciled in the State of California who is outside the State of
California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations
regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12)
months:
Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal
address, telephone or mobile contact number,
unique personal identifier, online identifier,
Internet Protocol address, email address, and
account name
YES
B. Personal information
categories listed in the
California Customer
Records statute
Name, contact information, education,
employment, employment history, and financial
information
YES
C. Protected classification
characteristics under
California or federal law
Gender and date of birth YES
D. Commercial
information
Transaction information, purchase history,
financial details, and payment information
YES
E. Biometric information Fingerprints and voiceprints YES
F. Internet or other similar
network activity
Browsing history, search history, online behavior,
interest data, and interactions with our and other
websites, applications, systems, and
advertisements
YES
G. Geolocation data Device location YES
H. Audio, electronic,
visual, thermal, olfactory,
or similar information
Images and audio, video or call recordings
created in connection with our business activities
YES
I. Professional or
employment-related
information
Business contact details in order to provide you
our Services at a business level or job title, work
history, and professional qualifications if you
apply for a job with us
NO
J. Education Information Student records and directory information NO
K. Inferences drawn from
other personal
information
Inferences drawn from any of the collected
personal information listed above to create a
profile or summary about, for example, an
individual’s preferences and characteristics
NO
L. Sensitive Personal
Information
Sex life or sexual orientation, biometric data and
account login information
YES
We will use and retain the collected personal information as needed to provide the Services
or for:
● Category A - As long as the user has an account with us
● Category B - As long as the user has an account with us
● Category C - As long as the user has an account with us
● Category D - As long as the user has an account with us
● Category E - As long as the user has an account with us
● Category F - As long as the user has an account with us
● Category G - As long as the user has an account with us
● Category H - As long as the user has an account with us
● Category L - As long as the user has an account with us
Category L information may be used, or disclosed to a service provider or contractor, for
additional, specified purposes. You have the right to limit the use or disclosure of your
sensitive personal information.
We may also collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in the context of:
● Receiving help through our customer support channels;
● Participation in customer surveys or contests; and
● Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
We collect and share your personal information through:
● Targeting cookies/Marketing cookies
More information about our data collection and sharing practices can be found in this privacy
notice.
You may contact us by email at hello@apiir.tech, or by referring to the contact details at the
bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request
if the authorized agent does not submit proof that they have been validly authorized to act on
your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Each service provider is a for-profit entity
that processes the information on our behalf, following the same strict privacy protection
obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This is not
considered to be "selling" of your personal information.
We have disclosed the following categories of personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months:
The categories of third parties to whom we disclosed personal information for a business or
commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?".
We have sold or shared the following categories of personal information to third parties in
the preceding twelve (12) months:
The categories of third parties to whom we sold personal information are:
● None
The categories of third parties to whom we shared personal information with are:
● Affiliate Marketing Programs
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but not limited to) the exercise by
another consumer of his or her right to free speech, our compliance requirements resulting
from a legal obligation, or any processing that may be required to protect against illegal
activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
● whether we collect and use your personal information;
● the categories of personal information that we collect;
● the purposes for which the collected personal information is used;
● whether we sell or share personal information to third parties;
● the categories of personal information that we sold, shared, or disclosed for a
business purpose;
● the categories of third parties to whom the personal information was sold, shared, or
disclosed for a business purpose;
● the business or commercial purpose for collecting, selling, or sharing personal
information; and
● the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer
information that is de-identified in response to a consumer request or to re-identify individual
data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
If the business collects any of the following:
● social security information, drivers' licenses, state ID cards, passport numbers
● account login information
● credit card numbers, financial account information, or credentials allowing access to
such accounts
● precise geolocation
● racial or ethnic origin, religious or philosophical beliefs, union membership
● the contents of email and text, unless the business is the intended recipient of the
communication
● genetic data, biometric data, and health data
● data concerning sexual orientation and sex life
you have the right to direct that business to limit its use of your sensitive personal
information to that use which is necessary to perform the Services.
Once a business receives your request, they are no longer allowed to use or disclose your
sensitive personal information for any other purpose unless you provide consent for the use
or disclosure of sensitive personal information for additional purposes.
Please note that sensitive personal information that is collected or processed without the
purpose of inferring characteristics about a consumer is not covered by this right, as well as
the publicly available information.
To exercise your right to limit use and disclosure of sensitive personal information, please
email hello@apiir.tech or visit: hello@apiir.tech.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the
same person about whom we have the information in our system. These verification efforts
require us to ask you to provide information so that we can match it with information you
have previously provided us. For instance, depending on the type of request you submit, we
may ask you to provide certain information so that we can match the information you provide
with the information we already have on file, or we may contact you through a
communication method (e.g., phone or email) that you have previously provided to us. We
may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or
authority to make the request. To the extent possible, we will avoid requesting additional
information from you for the purposes of verification. However, if we cannot verify your
identity from the information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity and for security or
fraud-prevention purposes. We will delete such additionally provided information as soon as
we finish verifying you.
Other privacy rights
● You may object to the processing of your personal information.
● You may request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the information.
● You can designate an authorized agent to make a request under the CCPA on your
behalf. We may deny a request from an authorized agent that does not submit proof
that they have been validly authorized to act on your behalf in accordance with the
CCPA.
To exercise these rights, you can contact us by email at hello@apiir.tech, or by referring to
the contact details at the bottom of this document. If you have a complaint about how we
handle your data, we would like to hear from you.
14. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding
access to and use of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in
an individual or household context. It does not include a natural person acting in a
commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified
or identifiable natural person. "Personal data" does not include de-identified data or publicly
available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition "consumer" applies to you, we must adhere to certain rights and obligations
regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you
interact with us and our Services. To find out more, please visit the following links:
● Personal data we collect
● How we use your personal data
● When and with whom we share your personal data
Your rights with respect to your personal data
● Right to be informed whether or not we are processing your personal data
● Right to access your personal data
● Right to correct inaccuracies in your personal data
● Right to request deletion of your personal data
● Right to obtain a copy of the personal data you previously shared with us
● Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects ("profiling")
We sell personal data to third parties or process personal data for targeted advertising.
Please see the following section to find out how you can opt out from further selling or
sharing of your personal data for targeted advertising or profiling purposes.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy
notice.
You can opt out from the selling of your personal data, targeted advertising, or profiling by
disabling cookies in Cookie Preference Settings. You may contact us by email at
hello@apiir.tech, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the
authorized agent does not submit proof that they have been validly authorized to act on your
behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you
and your consumer's request. If you submit the request through an authorized agent, we
may need to collect additional information to verify your identity before processing your
request.
Upon receiving your request, we will respond without undue delay, but in all cases, within
forty-five (45) days of receipt. The response period may be extended once by forty-five (45)
additional days when reasonably necessary. We will inform you of any such extension within
the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and
reasoning behind it. If you wish to appeal our decision, please email us at hello@apiir.tech.
Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken
or not taken in response to the appeal, including a written explanation of the reasons for the
decisions. If your appeal if denied, you may contact the Attorney General to submit a
complaint.
15. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated
by an updated "Revised" date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy notice frequently to be informed of how we are
protecting your information.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection
Officer (DPO) by email at hello@apiir.tech, or contact us by post at:
Apiir AS
VM-paviljongen
Trondheim, Trønderlag 7034
Norway
If you have any further questions or comments, you may also contact us by post at the
following corporate address:
Apiir AS
VM-paviljongen
Trondheim, Trønderlag 7034
Norway
Phone: +47 40641458
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable laws of your country, you may have the right to request access to
the personal information we collect from you, change that information, or delete it. To request
to review, update, or delete your personal information, please visit: hello@apiir.tech.

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