Privacy policy

We at THARSOS ("Tharsos", "we", "us" and "our") have created this Privacy Policy to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business. Tharsos is the controller of your personal information.

This Privacy Policy applies to our websites and mobile applications and other online services we may provide on which this Privacy Policy is posted (each a "Service" and collectively, the "Services"). In addition to describing how we collect, use, disclose and otherwise process personal information, this Privacy Policy explains the rights and choices available to individuals with respect to their personal information.

1. Information We Process

We may obtain information about you in a variety of ways, including through your use of our Services, when you call, email or otherwise communicate with us (including through social media), or when you participate in events or other promotions.

The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the "GDPR"). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction.

These are the categories of personal information we collect, which may vary based on the Service being used:

Identifiers (e.g., a real name, alias, unique personal identifier, online identifier, IP address, email address, account or other similar identifiers).
Personal Records (e.g., name and surname, email address and username. Some personal information included in this category may overlap with other categories).
Usage data and network activity (e.g., information on a consumer’s interaction with a website, application, or advertisement. See Information collected by Automated Means below for further details).
Commercial information (e.g., records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies).
Information about your habits (i.e. the information about your routine that you input on Productive: Habit Tracker).

Please note that when using certain Services, you may choose to input or provide access to certain physical or health-related information about yourself. Such information will be stored locally on your device and accessed only as described in the "Information collected from you" subsection below.

2. Sources of Information and Purposes of Use

Some of this information you provide to us and some we collect when you use our Services. We also may obtain information about you (including personal information) from our business partners, such as vendors, and others, and from previous owners and data controllers.

You may choose not to provide some or all of your personal information to us but doing so may prevent us from providing our Services to you or limit our ability to provide you with the level of service that you would otherwise expect from us.

3. How We May Use Your Personal Information

In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following:

Service delivery and Customer support

Maintaining or servicing accounts, providing customer service, operation our website and mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments;
Communicating about the products and Services we offer, and responding to requests, inquiries, comments, and suggestions.

Service improvement

Conducting statistical analyses or other research activities to optimize our features and provide you with new ones;
Understanding and evaluating how our Services and features perform with our users;
Uncovering insights about usage in order to improve the Services and provide customers with enhanced features as well as inform our development of new features and products.

Profiling

Measuring our advertising and marketing activity (e.g., measuring how a user was acquired).

Troubleshooting

Ensuring the quality and the proper functioning of our Services by analyzing, preventing, and correcting failures and bugs, and to prevent the illicit use or misuse of the Service.

Targeted advertising and marketing

Understanding our customer in order to more effectively market our Services
Serving relevant advertisements, if applicable.

Quality and Safety Maintenance and Verification

Activities related to improving the quality of the Services we provide, including upgrade or enhancement of the Services;
Verification or maintenance of the quality or safety of Services;
Tracking and responding to quality and safety matters;
Protecting our rights and property.

Compliance with legal obligations

Complying with our legal obligations, including requests from public authorities, and proving that we have complied with them, such as in the event of a request from a public authority.

Defense

Establishing, exercising, or defending our rights and those of our employees, and to carry out corporate transactions or operations. For example, your data may be processed in the event of bankruptcy, merger, acquisition, reorganization, and sale of assets or assignments, and the due diligence related to any such transactions.

To perform the above functions, we may match information collected from you through different means or at different times, including both personal information and Automated Information, and use such information along with information obtained from other sources. We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – pursuant to this Privacy Policy and applicable privacy laws.

Your personal data is not shared.

6. Your Choices and Rights.

You have the following rights in relation to how we use your personal information:

Access: you may request access to your personal information and receive copies of it;
Correction: you may have inaccurate/incomplete personal information corrected and updated;
Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;
Deletion: in certain circumstances, you can request a right "to be forgotten" (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;
Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider); and
Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.

For your protection, we may require proof of identity and verification before we can answer your requests.

You also have the right to complain before the competent national data protection authority, or any other applicable regulator in the jurisdiction where you reside, in the event that you think we’ve violated the applicable privacy laws and we haven’t addressed your request.

7. Legal basis for processing data

In this section, we identify the legal grounds on which we rely to process personal information.

In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities; to facilitate a Corporate Transaction (including a sale of assets or merger or acquisition); or to fulfill our contracts with business partners, such as third parties that distribute our products.

It may also be necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide.

We may also process personal information as specifically permitted by applicable legal requirements.

If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.

8. Data Retention

We retain personal data used for defense purposes for a maximum of ten (10) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply. Upon the expiry of the retention period, the data is either deleted or anonymized.

We retain personal data used for the purpose of compliance with legal obligations for a maximum of five (5) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply. Upon the expiry of the retention period, the data is either deleted or anonymized.

We retain the personal data for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. After this period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

The images uploaded by the users of the Scan Hero app will be processed and stored by us for up to 48 hours. After this time, the image will be permanently deleted.

9. International data transfers

We may transfer your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we may transfer your personal information to the United States. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.

Specifically, we may transfer personal information from the European Economic Area to:

Countries that the European Commissions has deemed to adequately safeguard personal information,
Pursuant to the recipient's compliance with standard contractual clauses (also known as Model Clauses), or Binding Corporate Rules,
Pursuant to the consent of the individual to whom the personal information pertains, or
As otherwise permitted by applicable EEA requirements.

12. Online Privacy Choices and Rights

Device permissions

Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

Uninstall

You can stop all information collection by the app by disabling call forwarding and deactivating your account by following the instructions on the Service's Settings screen and then uninstalling the app using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

Email

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending a request to contact@hugo-gualtieri.com. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional or administrative messages from us regarding the Services.

Location information

If you choose to opt-in, some of our apps may collect your device's precise real-time location, and in such cases, you may be able to opt out from further allowing us to have access to such location data by managing your location preferences in the app and/or on your device.

13. How We Protect Personal Information

We use various efforts intended to safeguard the security and integrity of personal information collected through our Services. Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you provide information to us at your own risk.

If you correspond with us by email or using Web forms like a "contact us" feature available through our Services, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using our Services, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.

If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you. If we have your email address, we may notify you by email to the most recent email address you have provided us in your account profile. Please keep your email address in your account up to date. You can change that email address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application.

14. Links to Websites and Third-Party Content

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that we do not own or control. We encourage you to review the privacy policies of such third parties before providing them with any personal information.

15. Information Relating to Children

We do not knowingly collect information from children under the age of 13 (or 16 in the EEA, or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 13 years of age (or 16 in the EEA, or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE THE SERVICES. If you are a parent or legal guardian and believe that we may have personal information from or about your child under 13, please contact us at contact@hugo-gualtieri.com. Note that we'll attempt to delete the account of any child under the age of 13 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.

16. Updates to Our Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will update the date of this Privacy Policy. Continued use of the Services after such date constitutes acceptance of such updates. When required by applicable law, we may inform you by additional means, such as through a notification on the website or in our mobile applications if we make material changes to how your personal information is collected, accessed or otherwise used as a result of your use of the Services or if your rights under this Privacy Policy are materially impacted by changes to our privacy practices. We recommend that you check this page from time to time to inform yourself of any changes in this Privacy Policy.

17. How to Contact Us

If you want to submit a request by email or if you have any other questions about privacy or data protection at Tharsos, you can contact us at contact@hugo-gualtieri.com.