Privacy Policy

This Privacy Policy describes the privacy practices for the Website operated by SPYLR and how the Website operated by SPYLR collect and use the personal data you provide on SPYLR Website, with the purpose to use SPYLR Service. It also describes the choices available to you regarding our use of your personal information and how you can access, update and delete this information.

The use of the Website is possible without any indication of personal data; however, if a user wants to use SPYLR Service via our Website, collecting and processing of personal data could become necessary. If the processing of personal data is necessary we generally obtain consent from the user as a data subject.

The processing of personal data, such as the name, address, e-mail address, telephone number or billing information of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to SPYLR. By means of this Privacy Policy, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects (users) are informed, by means of this Privacy Policy, of the rights to which they are entitled.

As the controller, SPYLR has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this Website.

The SPYLR Monitoring Product or Service may only be used for legitimate and lawful purposes by authorized users, and you are hereby notified that installing or using the SPYLR Monitoring Product or Service for any other purpose may violate local, state, and/or federal law.

This Privacy Policy describes how your information are collected, used, and disclosed by SPYLR in connection with your use of our website and our services. It also describes the choices available to you regarding our use of your personal information.

In this Privacy Policy “SPYLR”, “we”, “us” and “our” means SPYLR.


Definitions


Personal data:
means any information relating to an identified or identifiable natural person (“data subject/user”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject/user:
is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; a user to the SPYLR Software.

Processing:
is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Consent of the data subject/user:
is any freely given, specific, informed and unambiguous indication of the data subject/user`s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.


Information we collect

Anyone can access our Website without necessity to provide its personal data.
The purpose of processing your personal data by SPYLR and collection of information about you are as follows:
  • Your intention to use our Service
  • In order for SPYLR to provide the user with the ordered and purchased Service
  • For the performance of a contract to which the user is party, in accordance with Article 6.1.b of the GDPR and the collected data are necessary in order for SPYLR to identify and bill the user and to charge its bank card number
  • For verifying your identity and providing customer care service and assistance
  • Analyse your use of our Website and Service to better understand how they are being used so we can improve our Service and the user experience and engage and retain users.

As you are willing to use our Service you are required to provide your personal data to register an account and purchase a software, thus becoming a user of SPYLR.
With this Purpose we collect and process two types of information:
  1. Aggregate (meaning collective data that relates to a group or category of customers) tracking and Website usage information that we gather automatically as you access our Website, as (1) the browser types and versions used
  2. The operating system used by the accessing system
  3. The website from which an accessing system reaches our Website (so-called referrers)
  4. The sub-websites
  5. The date and time of access to the Website
  6. The Internet service provider of the accessing system
  7. Data provided by Google Analytics, Facebook pixels, Adwords pixels, Google Tech Manger, Zendesk and Zopim systems
  8. Any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to:
  1. Deliver the content of our Website correctly
  2. Optimize the content of our Website as well as its advertisement
  3. Ensure the long-term viability of our information technology systems and Website technology
  4. Provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

Therefore, we analyse anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject (depersonalization), and (2) personal data that you supply voluntarily subject to your consent when you place an order for any subscription plan of SPYLR Software.
Please be aware that you are not obliged to provide us with your personal data. However, if you do not provide us with your name and email address, you may not be able to create an account to log in to and make a purchase of SPYLR Software, consequently, to use our Service.


Personal Data:

We may collect Personal Data from you when you purchase our products or services, register to use our services, register to become an affiliate, or otherwise communicate with us. The Personal Data that we collect through our Website may include, but is not limited to, your first and last name, mailing address, email address, phone number, payment card information, and any information contained in your communications with us.

We also collect Personal Data and other information from the devices you monitor using our services. This information may include text messages sent from and to the device; information about calls made from and to the device; communications made using certain messaging applications; emails sent from and to the device; photos stored on the device; current and historical location data; information about any files stored on the device, information about any events in a calendar on the device, information about the contacts stored on the device, the applications on the device, information about the websites visited using the device; and analytics about device usage. Our services also include certain functionalities that could enable you to collect Personal Data, including the ability to remotely control a device, view a live feed of the device’s screen, and remotely access the device’s camera and microphone.

The storage of this data takes place against the background that this is the only way to prevent the misuse of our Services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller.

The personal data entered by the data subject/user are collected and stored exclusively for internal use by the controller and for his own purposes. The personal data stores separately in SPYLR data base to avoid data subject identification by using depersonalization features in compliance with GDPR storage limitation principle.

We do not authorize the use of your personal data by any third party. We operate and maintain a variety of online security measures to safeguard and keep your personal information private and secured.

When you purchase SPYLR Software you have to fill the User’s Information, which should contain your personal information as ID (first name, last name) and email, which is processed and stored by SPYLR.

You also have to fill the Billing Information and Payment Method, which should contain your Personal data, which is partly stored by SPYLR and processed by the payment providers.

Based upon the personal data you provide us at registration of an account, we may send you a welcoming e-mail to verify your login and password.

You may enter to your account on our Website under login and password sent to your email. All your activity in your account is password-protected, and you should keep and take all necessary measures to protect the secrecy of your password.

We will also communicate with you in response to your inquiries, regarding any information or services you request.

Our Website contains information that enables a quick electronic contact to us, as well as direct communication with us (when we’re online), which also includes a general address of e-mail address. If a user contacts us by e-mail or via a contact form, the personal data transmitted by this user is automatically stored. We will communicate with you by e-mail or other method chosen by you (including but not limited by website).

We may use your Personal data to:
  1. Improve your browsing experience by personalizing the Website and to improve the Service
  2. Send information to you by email regarding registration status, password verification, payment confirmation
  3. Send you communications relating to your use of the Service
  4. Provide our partners with statistical information about our users by secured channels under data processing agreements (DPA).
  5. Where we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request
  6. To enforce our Terms of Use, including investigating potential violations
  7. Security or technical concerns
  8. To protect against harm to the rights, property, or safety of our users or the public, as required or permitted by law
  9. Governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights

    If we sell all or part of our business, your Personal Data may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post an updated privacy policy on our Website. We suggest that you check the Website periodically to learn about how your information is used and disclosed.

    We use the Personal Data you provide to us for the following purposes:
    • Help us communicate with you, such as to contact users in response to questions, solicit
    • feedback from users, provide technical support, and inform users about promotional offers
    • Provide our services to you or to the owner of the account associated with the device you use
    • Operate, maintain, and improve our Website and Services
    • Comply with applicable legal requirements
    • Enforce our Terms of Use and otherwise protect our interests
    • as otherwise disclosed at the time such information is collected.

    We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that are related to the Service. With this regard, you are required to consent separately within your account for each communication. You may always opt-out (unsubscribe) from any communication in your account.

    As you use our Service, you may import into your account information you have collected from target devices. All this information is stored in encrypted way on SPYLR servers. Downloaded information by a user to its device or browser is not encrypted and user is solely responsible for securing it. We have no direct relationship with any person other than you, and for that reason, you are responsible for making sure you have the appropriate consent to collect and process information from an owner of a target device.

    If you use a computer in a public place or share a computer with others, remember to log out/sign out and close your browser window when you finish accessing our Website and Service in order to prevent others from accessing your personal information. You are solely responsible for the control and use of each password you create.

    Information collected via Technology:

    We may automatically collect information about your use of our Website and services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to our services, the time and date of access, and other information that may not personally identify you. We track this information using cookies, small text files, or other technologies. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect information about that user’s visit to our Website or use of our services and keep a record of the user’s preferences when visiting our Website or using our services, both on an individual and aggregate basis.

    The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session until you delete them, while session cookies expire when you close your browser. You may be able to refuse or delete cookies using the appropriate settings on your browser. However, if you refuse or delete cookies, you may not be able to use the full functionality of our Website or services. If you use another browser or device, you may need to review the settings for that browser or device to refuse or delete cookies on that browser or device.

    Automatically Collected Information

    We may use technology to automatically collect certain information from you when you use our Website or services (“Automatically Collected Information”). In general, we use Automatically Collected Information to help us improve our service and customize the user experience. We also aggregate Automatically Collected Information in order to track trends and analyse usage patterns on the Website and our service. This Privacy Policy does not limit in any way our use or disclosure of Automatically Collected Information.

    We also collect and store information that is generated automatically as you navigate through our Website to enhance your experience on our Website by using tracking technologies as Cookies (please read Cookie Policy), Log Files and Pixel tags.
    As you navigate our Website(s) information that we automatically collect is information in "log files" about your device’s connection to the Internet, length of time spent on the Website, and the pages accessed during each visit to the Website. We use this information to analyse trends, administer the Website, track user movement on the Website, and gather broad statistical information for aggregate use.

    Our Website use cookies. Cookies are text files that are stored in a computer system via an Internet browser. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Website, Cookies help us track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Website where you have entered preference information before. Cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
    Through the use of cookies, SPYLR can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized with the user in mind.
    The data subject may, at any time, prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of Cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of Cookies in the Internet browser used, not all functions of our website may be entirely usable.
    If you do not wish to receive Cookies you may be able to refuse them by adjusting your browser settings to reject Cookies. If you do so, we may be unable to offer you some of our functionalities, services or support. If you have previously visited our Website, you may also have to delete any existing cookies from your browser.
    SPYLR also may use Pixel tags (single-pixel image files also known as transparent GIFs, clear GIFs or web beacons) to access Cookies and to count users who visit the Website or open our HTMLformatted e-mail messages.

    HOW WE PROTECT INFORMATION

    We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password, and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.

    SECURITY

    When you register an account, you receive an email with indication of a private key, or you may download it from your account. This private key is used for encrypting your personal data and for restoring access to your data if you lose your password.
    Private key is stored on SPYLR servers in encrypted way. In case of an active account the private key is stored for a period of an active account.
    The period of this private key storage is 1 (one) day after you delete your account under your request.

    YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION
    You have the right at any time to prevent us from sending email marketing communications to you. When we send a promotional email communication to a user, the user can opt out of receiving such communications by following the unsubscribe instructions provided in each promotional email. You can also indicate that you do not wish to receive marketing communications from us. Please note that notwithstanding the promotional preferences you choose, we may continue to send you administrative emails including, for example, communications about updates to our Privacy Policy.

    LINKS TO OTHER WEBSITES
    As part of the Service, we may provide links to other websites or applications. We are not responsible for the privacy practices employed by the owners of those websites and applications or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Website and our service. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Website or via our service. We encourage our users to read the privacy statements of other websites before proceeding to use them.

    CHANGES TO OUR PRIVACY POLICY
    The Company reserves the right to change this Privacy Policy at any time. We will notify you of changes to our Privacy Policy by posting an updated policy on our Website with a new effective date. You should periodically check the Website to review our Privacy Policy for updates.

    Children’s Privacy
    Provision of our Service generally not aimed at children. This Website is not intended for use by children under the age of 18.

    We do not knowingly collect or solicit information from anyone under the age of 13 or allow anyone under the age of 13 to sign up for the service. By using our website and our products or services, you warrant that you are considered to be of legal adult age in your country of origin and/or the country where you reside

    In the event that we learn that we have gathered Personal Data from anyone under the age of 13, we will promptly delete such Personal Data. If you are the parent of a child who is younger than 13 years old, and you believe that we have collected Personal Data from your child, please contact us at support@spylr.com

    Access to Personal Information
    You may review, update, or request modification of any Personal Data that you have provided to us through our Website or services by contacting us using the contact information provided below.

    Data Retention
    We generally retain your Personal Data for as long as is necessary to accomplish the business purpose for which the Personal Data was collected. With respect to data collected from a target device and data provided to register for the service, we retain this data for ninety (90) days.

    Online Behavioural Advertising
    We may partner with third-party organizations, such as ad networks, which may use cookies, pixel tags, beacons, clear gifs, and/or other technologies to collect information about your visits to our Website and other non-affiliated sites or applications over time, including information about relationships among the different browsers and devices you use. These third-party organizations collect this information to provide you with relevant advertising based on your browsing activities and interests. This type of advertising is known as interest-based advertising.

    If you use a different browser, erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choices. If you choose to opt-out of receiving interest-based ads, you will continue to see advertisements on websites serving interest-based ads; however, these advertisements will not be tailored to your interests.

    International Users
    You must visit our Website or use our services from locations outside of the United States or United States’ Territories. Please be aware that the information you provide to us through your use of our Website or our services may be transferred to and processed in countries other than the country from which you viewed our Website or used our services. These countries may not offer equivalent protections for your Personal Data as those available in the country from which you accessed our Website or used our services. The method we use to transfer Personal Data is through the form they fill out and transfer it to our server.

    If you visit our Website or use our services from the European Economic Area (“EEA”) or Switzerland, please note that you may have additional rights with respect to the processing of your Personal Data. You may have the right to request that we provide you with access to your Personal Data. You may also have the right to request that we correct any errors relating to your Personal Data, that we erase your Personal Data, that we restrict the processing of your Personal Data, and that we provide you with a copy of your Personal Data in a structured, machine readable format. You may also have the right to request that we provide your Personal Data to another organization.

    In most instances, we process Personal Data with the data subject’s consent. We obtain your consent to process your Personal Data when you register for an account. We also require that you obtain express consent from the user of any targeted device to use the service. In addition to obtaining your consent to process your Personal Data, we also may process such information to provide our services to you. We may also process Personal Data where required to do so by applicable law or where it is in our legitimate interest to do so and such interests are not overridden by the data subject’s data protection rights. Our legitimate interests may include improving and developing new products and services, fighting fraud, and protecting our business interests and rights. You have the right to object to our processing of your Personal Data on the basis of our legitimate interests or to withdraw your consent to our processing of your Personal Data.

    To exercise your rights, please submit a request using the contact information provided below. Please note that in some instances, we may be required by applicable law to restrict our disclosure of your Personal Information or to retain your Personal Information after you have requested that we delete it. In such instances, we will comply with the applicable legal requirements.

    We do not use automatic decision-making (i.e., making decisions solely by automated means without any human involvement) or profiling (i.e., automated processing of personal information to evaluate certain aspects of an individual).

    In the event that we experience a personal data breach, we will notify you of this incident in accordance with applicable legal requirements.


    LEGAL MATTERS

    SPYLR considers your use of its Service to be private. However, we may disclose your personal information stored in your account and/or on SPYLR servers and databases, in order to:
    1. Comply with the law or legal process served on us.
    2. Enforce and investigate potential violations of this Privacy Policy, including use of this Service to participate in, or facilitate activities that violate the law
    3. Investigate potential fraudulent activities
    4. Protect the rights, property, or safety of SPYLR, its employees, its customers or the public.

    In the event of a change of control of SPYLR (such as asset transfers through a merger, sale, assignment or liquidation of the business entity, or any of its properties, assets or equity) or, in the event of a direct or indirect sale of any of its publishing properties and/or its Website(s), personal data of users of the affected Website(s) in our possession will be transferred to the new owner/successor. You will be notified of any such transaction and have an ability to exercise your legal rights under GDPR. You may always change or delete your personal data or opt out by contacting us as provided below, or if the acquirer posts a new Privacy Policy with new contact information, you may change or delete your personal data or opt out by following any new instructions that are posted.

    We may share Aggregate Information with third parties, including strategic partners, for marketing and promotional purposes under concluded data processing agreements, which secure the transfer and processing of personal data according to GDPR.
    The controller may also transfer to one or more processors (e.g. a payment provider under DPA) personal data of a data subject for payment processing purpose, which is attributable to the controller and without which a user would not be able to purchase the Software and use SPYLR Service.

    As we use third party technological services for the provision of Services, we may transfer your personal date internationally. Providers of such technological services may process personal data collected in the course of providing us their services as sub-processors only under DPA in accordance with GDPR.

    In case there might be a risk of unauthorized disclosure of personal data the controller communicates the personal data breach to the data subject without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, as encryption, and it was applied to the personal data affected by the personal data breach, the controller is not required to communicate the data subject.
    However, the encryption is useless if the access password or other credentials are weakly protected and stored by data subject. In this case the controller is not responsible for personal data breach.
    In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.


    RIGHTS OF THE DATA SUBJECT

    1. Right of confirmation

      Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.

      If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by SPYLR, he or she may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the erasure request is complied with immediately.


    2. Right of access

      Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information.
      Furthermore, the European directives and regulations grant the data subject access to the following information:

      • The purposes of the processing
      • The categories of personal data concerned
      • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
      • Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
      • The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
      • The existence of the right to lodge a complaint with a supervisory authority;
      • Where the personal data are not collected from the data subject, any available information as to their source;
      • The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

      Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

      If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

    3. Right to rectification

      Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

      If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.


    4. Right to erasure (Right to be forgotten)

      Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

      • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
      • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
      • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
      • The personal data have been unlawfully processed.
      • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
      • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR

      If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by SPYLR, he or she may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the erasure request is complied with immediately.


    5. Right of restriction of processing

      Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

      • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
      • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
      • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
      • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

      If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.


    6. Right to data portability

      Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

      Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

      If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.


    7. Right to object

      Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

      If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.


    8. Automated individual decision-making, including profiling

      Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject`s rights and freedoms and legitimate interests, or (3) is not based on the data subject`s explicit consent.

      If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by SPYLR, he or she may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.


    9. Right to withdraw data protection consent

      Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

      If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.



    DATA PROCESSING ON YOUR BEHALF: SPYLR AS DATA PROCESSOR

    Target Device Data. In registering for a SPYLR Account, the Service starts collecting data from a target device linked to the Account, which may include personal data relating to you, to a target device user(s) or to third parties (“User Data”, including information about a target device, websites and apps that is used, contacts, connections, payments, messages and other communications, posted and received content, etc.). In accordance with applicable privacy law, to the extent that it applies to the Service, you are the Data Controller of this Target Device Data and you appoint us as a Data Processor of such data for the purpose of providing SPYLR Service.

    Your use of Target Device Data. As Data Controller, you warrant that you have the appropriate authority to collect and process the Target Device Data and you agree to process and use the Target Device Data in accordance with this Privacy Policy, the Terms of Use and applicable law, and only for the explicit purposes of the Services. You will not submit to the Services any personal data relating to any individual that has not authorized such processing. Through the Services, you may also access a copy of the Target Device Data collected by us on your behalf. You will protect the confidentiality of any accessible Target Device Data and prevent access by or disclosure to any unauthorized third person. You will inform us within 24 hours about any problem arising in relation with management of your Account and/or Target Device Data. You will be responsible for any illegal use of other person’s data (personal or not) through the Service on a target device, including any use contrary to applicable data protection laws and/or in violation of this Privacy Policy.

    Data Processor Obligations. To the extent that we are Data Processor on your behalf, we shall
    1. Implement appropriate technical and organizational measures to safeguard any Target Device Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure
    2. Limit access to Target Device Data only to those employees who need to know it to enable the Processor to perform the Services
    3. Only process the Target Device Data as specified by this Policy and in accordance with your instructions
    4. Will not use the Target Device Data for any purposes other than those related to the performance of the Services or pursuant to your written instructions. Upon the expiry or termination of this Agreement by way of de-registration, or upon your request, we will cease any and all use of the third-party Data and will destroy or return it to you except as provided above with respect to backed-up data and termination. We will not disclose Target Device Data to any third party without your prior written consent or pursuant to court or administrative order.

    Warranties. You are solely responsible for use of the Account and the processing of personal data linked to your Account, which includes, among others, collecting, storing and analysing personal data from a target device. SPYLR automatically uses the configuration and the instructions given by you and you are solely responsible for the configuration of your Account.

    You warrant, as the one responsible for Target Device Data that we process on your behalf as Data Processor, that
    1. You have informed any user(s) that are 18 years old or more that the devices used by them include SPYLR software and have obtained consent from such user(s) for this kind of activity, as provided in our Privacy Policy
    2. You comply with all applicable legislation with respect to the monitoring and control software. You agree to fully comply with this Privacy Policy.

    Indemnity. You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of Target Device Data and other third party personal data submitted to our systems during the course of use and provision of the Service.


    PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

    The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period and when we no longer need personal data, we routinely and securely delete or destroy it, as long as it is no longer necessary for the Purpose.


    ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

    The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of Service provision, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

    SPYLR does not store and process personal data of a data subject for more than it is necessary to achieve the purpose of Service provision. However, in case of conflict situations in progress SPYLR may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defence of legal claims and for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data and information gathered from a target device gets deleted.


    DATA REMOVAL

    We generally retain all logs and information downloaded from a target device on an identifiable basis for 3 months period, for providing our annual behaviour report.

    Please be advised that all logs and information downloaded from a target device with use of the SPYLR Software stored in SPYLR database dated more than 3 months will be automatically deleted for the reasons of security by notifying you appropriately. Logs can be downloaded by user before the determined term above for further storage, should the necessity arise.

    We do not store on our servers all downloaded information from a target device in case of an active account for more than 3 (three) months period. Upon the expiry of this period all information gets deleted. In case of expired accounts all downloaded information from a target device gets deleted within 1 (one) month period.

    In addition, through the Account, you may delete all historical data saved at any time. This data will no longer be accessible and will be fully removed from our systems on the next back-up, except as indicated below.

    If you wish to remove all logs and information downloaded from a target device in your Account, please, uninstall SPYLR from your device(s), and send an email to support@spylr.com (or click on “Delete my Account” button in your Account). Your Account will be permanently removed within 30 days or earlier from our active systems, servers and back-ups. By deleting your Account all your personal data excluding the billing information for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject and gathered information from a target device will be removed as well.


    HOW DO I OPT-OUT OR CHANGE MY PERSONAL INFORMATION?

    To opt-out of further e-mail communications from us, just click on the opt-out button in the e-mail, or contact us as instructed at the end of this Privacy Policy. We may need up to 20 (twenty) business days to assure compliance with your request.

    To change your personal data that you have provided to us, please contact us as instructed at the end of this Privacy Policy.


    CHANGES OR UPDATES TO THIS PRIVACY POLICY

    We may modify this Privacy Policy at any time and post any changes to the Privacy Policy on the Website, so please review it frequently. We indicate the date of the current version of this Privacy Policy below, so you know when it was last updated.

    Changes to this Privacy Policy may not affect your personal data we have previously collected from you or after such changes.

    If you object to the changes, please contact us as provided below.


    CONTACT US

    If you have any questions regarding this Privacy Policy or the practices of this Website, please contact us by sending an email to support@Spylr.com