MINWIN PRIVACY POLICY – TERMS AND CONDITIONS:
Effective Date: January 1st, 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
Our engagement
At Minwin, our approach to privacy and data protection starts with our values: we always do the right things, in the right way, for the right reasons.
An ethical approach: Minwin respects the privacy of individuals and values the trust of its users, employees, customers, suppliers and others with whom we do business. Minwin strives to collect, use, disclose and process personal data in a manner consistent with the laws of the countries in which we operate, and we pride ourselves on upholding the highest ethical standards in our practices commercial. We have implemented technical and organizational measures to protect the information we may collect.
Interpretation and definitions
Interpretation
Words whose initial letter is capitalized have meanings defined under the following conditions. The following definitions have the same meaning whether they appear in the singular or the plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for You to access our Service or certain parts of our Service
- Application means the software program provided by the Company and downloaded by You on any electronic device, named Minwin
- Company (referred to as “the Company”, “We”, “Us” or “Our” in this Agreement) means Minwin, Tunis
- Device means any device allowing access to the Service such as a computer, a mobile phone or a digital tablet.
- Personal data means any information that relates to an identified or identifiable individual.
- Service means the Minwin Application or the Minwin.io Website
- Provider means any person or legal entity who processes data on behalf of the Company. It means third party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Third-party social media service means any website or social media website through which a User can log in or create an account to use the Service.
- Usage Data refers to data collected automatically, either generated by the use of the Service or coming from the infrastructure of the Service itself (for example, the duration of a page visit).
- You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collection and use of your personal data
Types of Data collected
Among the types of Personal Data that Minwin collects directly or through third parties include: first name; phone number, email address; Usage Data; Camera permission; device information; geographical area; number of users; number of sessions; duration of session; purchases via the Application; openings of the Application; updates to the Application; first launches; Operating systems; Cookies; Universally Unique Identifier (UUID); Failure information; geographical position.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Any use of Cookies – or other tracking tools – by Minwin or by the owners of third-party services used by Minwin aims to provide the Service requested by the User, in addition to the other purposes described in this document and in the relative Policy to cookies, if available.
Users are responsible for any third party Personal Data obtained, published or communicated through Minwin and confirm that they obtain the consent of the third party to provide the Data to The Company.
You can enable or disable access to this information at any time through Your device settings.
Use of your personal data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the use of our Service.
- To manage your account : to manage your registration as a user of the Service. The Personal Data you provide may give you access to various features of the Service that are available to you as a registered user.
- For the execution of a contract : the execution, compliance and commitment of the purchase contract for the products, items or services that You purchase through the App.
- To contact you : to contact you by email, phone calls, SMS, or other equivalent forms of electronic communication, such as push notifications from a mobile application regarding updates or informative communications related to features, products or contracted services, including security updates, when necessary or reasonable for their implementation.
- To provide you special offers and general information about other goods, services and events offered by us that are similar to those you have already purchased or inquired about, unless you have opted not to receive this information.
- To manage your requests : To respond and manage requests you send to us.
- For business transfers : We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of all or a portion of Our assets, whether as a going concern or bankruptcy, liquidation or similar proceeding, in which Personal Data We hold about users of our Services is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, about our products, our services, our marketing and your experience.
We may share Your personal information in the following situations:
- With service providers : We may share your personal information with service providers to monitor and analyze the use of our service, to contact you.
- With other users: When You share personal information or otherwise interact in public areas with other users, this information may be seen by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, photos, and description of your activity . Likewise, other users will be able to see descriptions of your activity, communicate with you and view your profile.
- With your consent: We may disclose Your personal data for any other purpose with Your consent.
Method and location of Data processing
Treatment methods : The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Data.
Data processing is carried out using computers or IT tools, following procedures and organizational methods closely linked to the purposes indicated. In addition to the Company, the Data may be accessible, in certain cases, to certain categories of people responsible for the operation of Minwin (administration, sales, marketing, legal department, system administration) or to external parties (such as third-party suppliers technical services, messaging services, hosting providers, IT companies, communications agencies) designated, where applicable, as Subcontractors by The Company.
Legal basis for processing : The Company may process Personal Data relating to Users if one of the following conditions applies :
- Users have given their consent for one or more specific purposes; Please note: According to certain legislations, the Company may be authorized to process Personal Data until the User objects (“opt-out”), without having to depend on consent or one of the following legal procedures.
- The provision of Data is necessary for the execution of an agreement with the User or for any pre-contractual obligation of the latter ;
- The processing is necessary to comply with a legal obligation to which The Company is subject ;
- The processing is linked to a task carried out in the public interest or in the exercise of public authority vested in the Company ;
- The processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
Processing location : The Data is processed at the Company's headquarters and in all other locations where the parties responsible for processing are located. Depending on the User's location, data transfers may result in the transfer of the User's Data to a country other than their own.
Retention of your personal data
Personal Data is processed and kept for as long as required for the purpose for which it was collected. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, unless this data is used to strengthen the security or improve the functionality of Our Service, or We are legally obligated to retain this data for longer periods.
Device permissions to access Personal Data
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application. If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.
Approximate location permission (non-continuous):
Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.
Photo Library permission:
Allows access to the User's Photo Library.
Camera permission, without saving or recording:
Used for accessing the camera or capturing images and video from the device. This Application does not save or record the camera output.
Disclosure of your personal data
Commercial transactions : If the Company is involved in a merger, acquisition or sale of assets, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different privacy policy.
Law application : Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (for example, a court or government agency).
Other legal requirements : The Company may disclose your Personal Data if it believes in good faith that such action is necessary to :
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of users of the Service
- Protect itself against legal liability.
Security of your personal data
The personal information we collect is stored in a secure environment. People working for us are required to respect the confidentiality of your information.
To ensure the security of your personal data, we use the following measures :
- Security protocols
- Access management
- Automatic backups
- Firewall
We are committed to maintaining a high degree of confidentiality by integrating the latest technological innovations to ensure the confidentiality of your transactions. However, as no mechanism offers maximum security, some risk is always present when using the Internet to transmit personal information.
Links to other websites
Our Service may contain links to other websites that are not operated by Us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of each site you visit.
We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites or services.
Changes to this privacy policy
We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page.
We advise you to consult this privacy policy regularly to be aware of any possible modifications. Changes to this Privacy Policy are effective when posted on this page.
Contact us
If you would like to contact us to learn more about this Privacy Policy or would like to contact us with any questions relating to it, you may send an email to support@minwin.io