PRIVACY POLICY

Welcome to Verified by Pi™!

The owner and Data controller of The Verified by Pi is Serbian IT company “Technology Partnership”, based in Belgrade, Vuka Karadzica no 7 street, represented by director Sava Zivanovic, contact info@tp.rs

Data protection officer (DPO): Sava Zivanovic

We care deeply about your privacy, so be assured that we are doing our very best to protect it and avoid any misuse or abuse of your personal data. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. This document informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of our Services.

I ACCEPTING THE PRIVACY POLICY

Please take a few minutes to read this Privacy Policy, so that you understand what information we collect, what we do with it and why, how we protect it and what are your rights in relation to this information. In general, we only collect information that allows us to provide you with our best Services. If you don’t want us to collect or process your personal information in the ways described in this policy, you shouldn’t use the Services. It’s important you understand that by using our Services, you allow us to collect, use, disclose, and retain your personal information and other information described below. You can be sure that we will only use your information as described in this Policy. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside.

LEGAL BASIS

Under the General Data Protection Regulation (GDPR (Regulation (EU) 2016/679)), ePrivacy Directive (Privacy and Electronic Communications Directive 2002/58/EC) and Serbian Personal Data Protection Law, our legal basis for processing your personal data are:

– Users verified consent for one or more specific purposes;

– The data processing is necessary to perform the contractual obligations in our Terms and Conditions in order to provide the Services to you (Contract)

– The processing is necessary for the legitimate interests of the data controller or third party, except where overridden by the interests, rights, and freedoms of the user, in particular where the user is a child.

DATA WE COLLECT

Information you provide

1) Your Account Information. You provide your mobile phone number to create a Verified by Pi account. Legal basis: Contract (Terms and conditions);

2) Location Data –is information that is derived from your GPS, WiFi, cellular data or IP address. Legal basis: Verified consent;

Automatically Collected Information

1) Log Data – We collect service-related, diagnostic, and performance information. This includes information about your activity (such as how you use our Services), log files, and diagnostic, crash, website, and performance logs and reports, the time of signing the pictures and the time of the verification attempt. Legal basis: Legitimate Interests

2) Transactional Information. If you pay for our Services, we may receive information and confirmations, such as payment receipts, including from app stores or other third parties processing your payment. Legal basis: Contract, Verified consent and in accordance with our obligations under applicable law.

3) Device and Connection Information. We collect device-specific information when you install, access, or use Verified by Pi application. This includes information such as hardware model, operating system information, browser information, IP address, mobile network information including phone number, and device identifiers. Legal basis: Contract (Terms and conditions);

Third-Party Information

1) Third-Party Providers –We work with third-party providers to help us operate, provide, improve, understand, customize, support, and market our Services. We work with the Google Play store to distribute our Verified by Pi app. This provider may provide us information about you in certain circumstances; for example, may provide us reports to help us diagnose and fix service issues.

2) Third-Party Services (Sharing your Verified by Pi data outside the Verified by Pi account) – We provide other Verified by Pi-related features that allow you to share a photo to audiences outside of Verified by Pi app– for now only via your e-mail.  In future, we plan to give an option to share a photos created with our app to publicly accessible blogs and forums, or certain social media features like Facebook, Instagram, Whats App, Viber, etc. within Verified by Pi (such as “plug-ins” (which create a direct link between two websites) and “widgets” (which are interactive Mini Programs that provide third party services within Verified by Pi)) allow you to re-post and disclosure photos. Any information you distribute using such features may be read, collected, and used by third parties that are not controlled by “Technology Partnership”.

Third-party social media platforms are hosted by the relevant third party. Third parties that provide third-party services may collect your Information (including your Personal Information and Log Data), and set cookies on your computer, or device to enable such features to function properly.

Your use of any third-party services (whether social media services or otherwise), including any Personal Information you provide to such third parties and their collection and use of your Personal Information, are subject to the relevant third party’s own terms of services and privacy policies and not the Verified by Pi (“Technology Partnership”) Terms and Condition or this Privacy Policy, so please review those third party terms carefully.

This Privacy Policy only applies to any information collected by us and does not apply to any services offered by or information practices of any third parties. If you choose to use third-party services or features that are made available within Verified by Pi, then we will share certain information with that third party to allow you to use that third-party service. The information we share with such a third party is described to you at the time you first use that service or feature, and that third party will provide the same or equal protection of user data as stated in this policy. You can control which third parties have access to this information in your account. You can withdraw your agreement to the sharing of that information at any time by following the instructions we will set in app. Please note however that if you ask us not to share that information with the third party, you may no longer be able to use that service or feature. We are not responsible for any third-party use of any Information provided by you to them.

HOW WE USE COLLECTED DATA

We use all the information we have to help us operate, provide, improve, understand, customize, support, and market our Verified by Pi application. When you access or use the Verified by Pi application, we collect, use and otherwise process your personal information only as described in this policy.

1)  We use your information to provide our Services.

We use your information to operate and provide our Verified by Pi app to you. We may use your information to improve and customize our Verified by Pi Services and we do so as it is necessary to pursue our legitimate interests in improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used and to explore and unlock ways to research, develop, and test new services and features and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users and obtaining insights into usage patterns of our Services. We also use your information to respond to you when you contact us and to conduct troubleshooting activities.

2) Safety and Security.

We may also use your information for safety and security purposes through verification of accounts and activity and we do so because it is necessary to pursue our legitimate interests in ensuring the security of our Services, including enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kind. We may also use your information to conduct an investigation of suspicious activity or violations of our Terms, and to ensure our Verified by Pi application is being used legally.

3) Enforcement of law

We will not transfer your Personal Information to any other third parties except as specified below, or in circumstances where you consent to such transfer. We share your information with selected recipients who have a legal basis and valid jurisdiction to request such data. These categories of recipients include:

• government, public, regulatory, judicial and law enforcement bodies or authorities: where we are required to comply with applicable laws or regulation, a court order, subpoena or other legal processes, or otherwise have a legal basis to respond to a request for data from such bodies, and the requesting entity has valid jurisdiction to obtain your personal information;
• to protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt; to comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of our Terms and Conditions (link).
• Other Third-Parties– If you choose to use third-party services or features that are made available within Verified by Pi, then we will share certain information with that third party to allow you to use that third-party service. The information we share with such a third party is described to you at the time you first use that service or feature, and that third party will provide the same or equal protection of user data as stated in this policy. You can control which third parties have access to this information in your account. You can withdraw your agreement to the sharing of that information at any time by following the instructions we will set in app.

SECURITY OF YOUR INFORMATION

We will make sure that your information are safe with us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. (read more in our Terms and conditions- link). Your phone numbers are visible in the back-end part of the application, but can only be accessed via the TP internal network, which is protected by appropriate security systems, described below. If you have any questions about the security of your personal information, you can contact us at info@tp.rs

We encrypt and keep in the secure cloud your personal information’s given to us such as phone number, location, IP address. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, such as variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access, or disclosure of Information – for example, we use encryption technology such as SSL- Secure Sockets Layer to protect certain sensitive Information such as Location Data and Transport Layer Security TLS 1.2 for encryption from application to server. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. Therefore, while we strive to protect your personal information, we can’t guarantee its absolute security.

DATA RETENTION

Unless otherwise specified, we retain information as long as it is necessary and relevant for us to achieve the purposes referred to above or to enable us to comply with our legal data protection retention obligations. Upon deactivation of your account, we will minimize the personal data we keep about you only to such data which we are required to keep to comply with laws, or other legal reasons. We will delete your phone number from our base. We may keep activity data on a non-identifiable basis to improve our services, such as previously made log files prior to termination, which will be used, in a pseudonymized way for general user statistics. Please be aware that some user information is stored in the Google Play Store for the entire application lifecycle.

WHO HAS ACCESS TO YOUR INFORMATION?

Only the “Technology Partnership” Director and “Technology Partnership” employees working on maintaining the Verified by Pi application have access to your data.

TRANSFER OF THE INFORMATION

We operate internationally and provide our Verified by Pi users worldwide. That means that your personal information may need to be processed in countries where data protection and privacy regulations may not offer the same level of protection as in your home country. We store and process your personal information on our computers in the Republic of Serbia and on the servers that are in the Republic of Serbia. Maybe in the future, we will need to use service providers that may be located in various locations outside of the European Economic Area (EEA). If that happens, we will put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the info@tp.rs

NOTIFICATIONS FROM VERIFIED BY PI

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend Verified by Pi for maintenance, or security, privacy, or administrative-related communications). We send these via SMS or Notification inside of the app. We may send you service information and tutorials to help you use better and easier our application. You agree that TP can send you non-marketing messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an SMS confirmation when you register your account, modification of key features or functions, reactivation of the account in case of hacking or forgetting the password, correspondence with our support team.

CONTROL YOUR INFORMATION

Verified by Pi gives you the choice of providing, editing or removing certain information, as well as choices about how we contact you. You may change or correct your Verified by Pi account information through your account settings. You can also request the deletion of the personal information in your account. (read more in our Terms and Conditions –link)

YOUR RIGHTS

The right to access and correction

You have the right to access your personal data and information about how your personal data is being processed by us. Upon your request through e-mail support@tp.rs, we will provide information about whether we hold any of your personal information. You also have the right to access personal information we hold about you, how we use it, and who we share it with. You also have the right to correct that information.

You can access and correct your personal information by logging into your Verified by Pi account at any time.

If you believe we hold any other personal information, or you want to correct information that you are unable to correct using your account, please contact us via support@tp.rs. We may not be able to provide you with certain Personal Information if providing it would interfere with another’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person).

The right to erasure

You can delete your account, or remove certain personal information, following the account deletion instructions in our Terms and conditions. If there is any other personal information you believe we process that you would like us to erase, please send us the request via support@tp.rs.

You may request that we erase the Personal Information we hold about you in the following circumstances: you believe that it is no longer necessary for us to have your Personal Information; we obtained your consent to process the Personal Information and you withdraw that consent (and we have no other grounds for processing the Personal Information); you believe we are unlawfully processing your Personal Information.

Please note, however, that we may retain the Personal Information if there are valid grounds under law for us to do so (e.g., for the defense of legal claims, freedom of expression or some other legal obligation) but we will let you know if that is the case.

The  right to restriction of data processing

You have a right to require us to stop processing the Personal Information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Personal Information, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defense of legal claims or for another’s protection).

Where we agree to stop processing the Personal Information, we will try to tell any third party to whom we have disclosed the relevant Personal Information so that they can stop processing it too.

The right to data portability

You have the right to receive a copy of certain Personal Information we collect from you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.

If you wish for us to transfer the Personal Information to a third party, please ensure you detail that party. Note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Information or its processing once received by the third party. We also may not provide you with certain Personal Information if providing it would interfere with another’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person or our trade secrets or intellectual property).

The right to object

You may object to our use of your Personal Information if we use your information on the basis of our legitimate interests (such as when we use your personal information for your account security, such as to prevent malicious log-ins). If you object to such processing, please contact us via support@tp.rs, providing detailed reasons.

ANDROID PERMISSIONS

1. READ CONTACTS – access contacts from your phonebook
2. ACCESS FINE LOCATION – access to the user’s location.
3. WRITE EXTERNAL STORAGE – Take a photo. emergence through an app on your phone (gallery photo).
4. CAMERA – access the camera of the phone.

BUSINESS PARTNERS DATA

When you communicate with us for business purposes as a b2b partner of ours, we will save your contact data provided by you (phone number, email, etc.), as well as any correspondence we have had. We use trusted third-party processors to keep such data, all in accordance with the provisions of this privacy policy.

SPECIFIC LOCATION PRACTICES

Serbian residents may learn more about their rights, including how to exercise their rights under the Serbian Law on personal data protection, by clicking https://www.paragraf.rs/propisi/zakon-o-zastiti-podataka-o-licnosti.html link.

UPDATES TO POLICY

We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following:

– posting the changes on or through the Services,

– sending you a message about the changes,

We encourage you to check back regularly and review any updates.

CONTACT

If you have any question about the Privacy policy you can:

1) Contact the support team via email: support@tp.rs

2) Send an email to TP Data protection officer at email: support@tp.rs