Online Security
Privacy policy
This Privacy Policy shall apply to the applications published in the Apple App Store by Online Security and that are accessible from mobile devices and personal computers (the "App"), and the use of the websites controlled by Online Security in general (the "Website"; App, and Website together the "Services").
1. General
Regarding the Services: Online Security("Online Security LTD", "we",
"us" or "our") is the Data Controller within the meaning of the General
Data Protection Regulation ("GDPR").
This privacy policy shall inform you on how we collect, process and use
("Use") personal data in connection with the Services.
2. Data we collect, process and use
2.1 In general, you can use the Services without providing any personal
information such as e.g. your name, email address, postal address,
telephone number, financial information (all such information concerning
the personal or material circumstances of an identified or identifiable
individual data subject together "Personal Data"). Therefore, if you do
not provide us directly with Personal Data in another way or actively
consent to the Use by us of certain Personal Data, we, in general, do
not Use your data with the exception of the following:
2.1.1 Regarding the Website: your browser transfers certain data so that
it can access the Website, namely: the IP address, the date and time of
the request, the browser type, the operating system, the language and
version of the browser software.
2.1.2 Regarding the App: certain data is transmitted by your mobile
device: namely your IP address, the periods of time in which you use the
App and the type of device you use (e.g. IPhone, IPad), as well as
events within the application recorded with Amplitude analytics in order
to give us the possibility to continuously improve the App.
2.1.3 Regarding the App: in certain cases, such as downloading and
installing a free trial of a paid App, we ask you to enter a valid email
address to begin your free trial.
2.1.4 Regarding the App: certain apps allow you to send documents via
Fax. In order for this functionality to work we need to record a fax
number and the document intended for transfer. Once the document is
sent, the fax number along with the document will be removed after 30
days.
2.1.5 Regarding the email: we save a record of communication including
attachments and information you voluntary decide to share with us for
troubleshooting purposes whenever you communicate with our support team.
2.1.6 Email messages sent by us via third-party services like MailChimp
or CampaignMonitor may contain tracking pixel which helps us collect
statistics on delivery and opening rates of our correspondence. These
pixels do not provide us with any additional personal data about you or
your behavior online. You can disable image rendering in your email
client which will deactivate this feature, however you will be unable to
see any images within other received emails. The legal basis for the
processing of the data described above in section 2.1.1 through 2.1.6
(to the extent such data is to be considered Personal Data) is Art. 6
(1) sentence 1 lit. f GDPR (legitimate interests; regarding section
2.1.1 the legitimate interests to Use such data arises from the fact
that without such data the Website cannot be accessed by our customers
and/or other users; regarding section 2.1.2 the legitimate interests to
Use such data is that we have an interest to continuously improve the
App; regarding section 2.1.3 the legitimate reason is that we need to
inform you about the end of your free trial; regarding section 2.1.4 the
legitimate reason is that we need the information to follow your
instructions and send a fax on your behalf; regarding section 2.1.5 the
legitimate reason is that we need the information to provide you with
the support you requested).
2.2 Only in cases in which you have given us prior consent we also use
your Personal Data for other purposes but only to the extent needed in
each specific case. The legal basis for the processing of the data
described in this section 2.2 is Art. 6 (1) sentence 1 lit. a GDPR
(consent).
2.3 We may disclose Personal Data to third parties where such disclosure
is required by law (for example, upon request of a court or of law
enforcement authorities). The legal basis for the processing of the data
described in this section 2.3 is Art. 6 (1) sentence 1 lit. c GDPR
(legal obligation).
2.4 Face Data: The application collects and stores facial images for the
purpose of generating and reusing face swap effects. These images are
saved in the user's profile and can be reused in future sessions. Users
have the option to delete their face images at any time from the face
swap screen or the settings screen. The app does not collect biometric
identifiers or share facial images with third parties. Face data is
retained until the user manually deletes it.
3. Online Securitycookies policy
3.1 Online Securitywebsites use cookies to personalize your experience
on our sites. Cookies tell us which parts of our websites people have
visited, help us measure the performance of ads, and give us insights
into user behavior so we can improve our communications and products.
You can disable cookies anytime in your web browser. Here is how it
works in Google Chrome and Safari browsers:
Chrome: Go to the Settings in the Chrome menu (Chrome toolbar) -> Scroll
down the page and click Advanced -> In the "Privacy" section, click the
Content settings -> Click "Cookies" and change anything desired.
Safari: Go to Preferences. -> Click the Privacy tab. ->Choose to Block
all cookies.
For other browsers, please check the documentation your provider
provides.
Online Securitycookies don't collect information that personally
identify you. Also, other sites or companies won't be able to track you
through our cookies.
When you disable cookies, our website can no longer provide you with the
best user experience and you miss the opportunity to get more
personalized information, such as displaying information in your
language or displaying prices in your currency.
COOKIES: USE OF (FURTHER ANALYZING) TOOLS Cookies are stored on your
computer when using the Website. Cookies are small text files that are
stored on your hard disk of the computer with which you visit a website
and which are allocated to your browser and through which certain
information is submitted to the cookies user that sets the cookie (in
this case us). Cookies serve to make the website offering more
user-friendly and effective overall.
The Website uses cookies to the following extent: Transient / Session
cookies, Persistent / Setting cookies, Analysis cookies
Transient cookies are automatically deleted when you close your browser.
This includes in particular the session cookies. These store a so-called
session ID, which identify user session in the browser. Session cookies
are deleted when you log out or close your browser.
Persistent cookies help the Website remember your information and
settings when you visit them in the future. They are automatically
deleted after a specified period, which may differ depending on the
cookie. We also use cookies on our website which enable an analysis of
the user's surfing behavior.
3.2 The Website uses Google Analytics, a web analytics service provided
by Google, Inc. ("Google"). Google Analytics uses "cookies", which are
text files placed on your computer, to help analyze how you use the
Website. The information generated by the cookie about your use of the
Website will normally be transmitted to and stored by Google on servers
in the United States. Because IP-anonymization is activated on the
Website, your IP address will be truncated within the area of member
states of the European Union or within other contracting states to the
Agreement on the European Economic Area. Only in exceptional cases the
whole IP address will be first transferred to a Google server in the USA
and truncated there. Google will use this information on behalf of
Online Securityfor the purpose of evaluating your use of the Website,
compiling reports on Website activity and providing other services for
Online Securityrelating to website activity and internet usage.
The IP address that your browser transfers within the scope of Google
Analytics will not be associated with any other data held by Google.
You may refuse the use of cookies by selecting the appropriate settings
in your browser, however please note that if you do so you may not be
able to use all functions of the Website. You can also opt-out from the
storage by Google of the data that is created by the cookie and is
related to the use of the Website (including your IP address) and the
processing of such data by Google by downloading and installing the
Google Analytics opt-out Browser add-on available under this.
As an alternative to the browser add-on or within browsers on mobile
devices, you can click this link in order to opt-out from being tracked
by Google Analytics within this Website in the future (this opt-out
option applies only for the browser in which you set it and with regard
to the Website). In this case an opt-out cookie is put on your device.
In case you delete your cookies, you will have to use the aforementioned
link again.
For further information on Google Analytics please refer to: Google
Analytic Terms of Service Language Index , Safeguarding your data ,
Privacy Policy
3.3 In order to better understand general usage patters for our Product,
we use a third-party tool of Appsflyer, 100 1st Street, 25th floor San
Francisco, California 94105, United States., called Appsflyer (see
here). Appsflyer is an analytics software tool, which helps us improve
our Service by providing statistical patterns of our product use. This
tool does not provide us with any additional personal data about you or
your behavior online.
3.4 Our Apps use Facebook SDK of Facebook 1 Hacker Way, Menlo Park (, )
to analyze sources of app installations and how you use the app.
Facebook SDK and Analytics is a service which helps us to improve ours
Service by better understanding general app usage patterns.
3.5 If you decide to deactivate (some of) the cookies and tools
described above, please note that certain features and functionalities
of the Services might not work or might not be accessible to you.
3.6 The legal basis for the processing of the data described in this
section 3 (to the extent such data is to be considered Personal Data) is
Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate
interests to Use such data is that we use and analyze the respective
data to improve our Services, such as by gaining a better understanding
of your interests and requirements regarding our Services and to help
personalize your user experience).
4. Technical implementation of the services by subcontractors
We partly use service providers who process Personal Data on behalf of us to operate the technical platform for the Services (for example, the documents that you scan and send via the App are processed by a third party fax service provider (whereas the respective servers are exclusively situated in EU member states)). These service providers process the data exclusively according to our instructions (order processing). The legal basis for the data processing described in this section 4 is Art. 6 (1) sentence 1 lit. b GDPR (performance of contract and pre-contractual measures) and Art. 28 GDPR (order processing).
5. Duration of storage of personal data
Unless no shorter storage period is indicated in this privacy policy, we, in general, store Personal Data as long (i) as required for the provision of the Services to you, and/or (ii) as it is necessary with regard to the contractual relationship with you, thereafter only if and to the extent that we are obliged to do so by mandatory statutory retention obligations. If we no longer require the respective Personal Data for the purposes described above, such Personal Data will only be stored during the respective legal retention period and not processed for other purposes.
6. Your rights
You have the right to request information from us at any time about your
Personal Data stored by us. If the legal requirements are met, you also
have rights vis-à-vis us to request from us access to and rectification
or erasure or restriction of processing concerning your Personal Data or
to object the processing of your Personal Data as well as the right to
receive your Personal Data provided to us in a structured, established
and machine-readable format from us (you can transfer this data to other
parties or have it transferred; data portability).
If you have given your consent to the use of personal data, you can
revoke such consent at any time (for the future).
If you believe that the processing of your Personal Data by us is in
breach of the applicable data protection laws, you can issue a complaint
with the competent supervisory authority for data protection.
7. Contact
You can contact us (e.g. if you have any questions about data protection
regarding narcis@online-security.uk (including regarding the assertion
of your rights further explained in section 6 above)), for example, via
the address indicated above in section 1 or via the following emails: or
(Online SecurityData Protection Officer), or at our GDPR Representative
Office at the following address:
Online Security, Arch. Makariou III, 155, PROTEAS HOUSE, 2nd floor,
Flat/Office 202, 3026, Limassol, Cyprus
8. Keeping your personal data secure
We have taken extensive technical and operational precautions to protect the Personal Data retained by us against unauthorized access and misuse. Our security procedures are revised regularly and adapted to reflect technological progress.
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