Privacy Policy

1. Scope

This Privacy Policy applies to the Bely App mobile application and all related services provided by Bely App.

This policy does not apply to third-party services or websites that may be accessed through links in our app.

2. Data We Collect

We collect the following types of information:

• Personal Information: Information you provide directly to us, such as your name and email address when you contact us.

• Usage Data: Information about how you use our app, including features used, time spent, and interactions.

• Device Information: Information about your device, such as device model, operating system, and unique device identifiers.

• Log Data: Information automatically collected when you use our app, including your IP address, browser type, and access times.

• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies.

3. How We Use Your Information

We use your information for the following purposes:

• To provide and maintain our service

• To improve and personalize your experience

• To communicate with you, including responding to your inquiries

• To send you updates and promotional materials (with your consent)

• To analyze usage patterns and improve our app

• To detect, prevent, and address technical issues

• To comply with legal obligations

4. Legal Basis for Processing

Our legal basis for processing your personal data depends on the information we collect and the specific context of processing:

• Performance of a contract: Processing necessary to provide our services to you.

• Legal obligation: Processing necessary to comply with applicable laws.

• Legitimate interests: Processing necessary for our legitimate business interests, such as improving our services and ensuring security.

• Consent: Processing based on your explicit consent for specific purposes, such as marketing communications.

5. Third-Party Data Sharing

We may share your information with the following categories of third parties:

• Service Providers: Third-party companies that help us operate our app, such as hosting providers, analytics services, and customer support platforms.

• Analytics Partners: Companies that help us understand how our app is used, such as Google Analytics.

• Marketing Partners: Third parties that help us promote our services, subject to your consent.

• Legal Compliance: When required by law, regulation, or legal process, or to protect our rights and the rights of others.

• Business Transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

We do not sell your personal data to third parties.

6. International Data Transfers

Your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

We ensure that appropriate safeguards are in place for international data transfers, including Standard Contractual Clauses (SCCs) approved by the European Commission.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Our data retention periods are based on the following criteria:

• Service provision: While you have an active account or for 3 years after account termination

• Legal compliance: As required by applicable laws and regulations

• Dispute resolution: As needed to resolve disputes or enforce our agreements

• Business needs: As necessary for our legitimate business interests

8. Your Rights

You have the following rights regarding your personal information:

• Right of Access: The right to obtain confirmation of whether we are processing your personal data and, if so, to access it.

• Right of Rectification: The right to correct inaccurate or incomplete personal data.

• Right of Erasure: The right to request deletion of your personal data in certain circumstances.

• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.

• Right to Object: The right to object to the processing of your personal data in certain circumstances.

• Right to Restrict Processing: The right to restrict the processing of your personal data in certain circumstances.

• Right to Withdraw Consent: The right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, please contact us at [email protected]. We will respond to your request within 30 days.

9. Children's Privacy

Our app is not intended for children under the age of 16. We do not knowingly collect personal information from children under 16.

If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information from our servers.

10. Security Measures

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

Our security measures include:

• Encryption of data in transit and at rest

• Regular security assessments and penetration testing

• Access controls and authentication mechanisms

• Employee training on data protection

• Incident response procedures

Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our app and store certain information.

Types of cookies we use:

• Essential Cookies: Necessary for the app to function properly.

• Analytics Cookies: Help us understand how users interact with our app.

• Marketing Cookies: Used to track visitors across websites to display relevant advertisements.

You can manage your cookie preferences through our Cookie Manager. You can also set your browser to refuse all or some cookies, but this may affect your ability to use our app.

12. Consent Mechanisms

We obtain your consent for processing your personal data in the following ways:

• Explicit consent for marketing communications through opt-in checkboxes

• Consent for cookie usage through our cookie banner

• Consent for specific features that require data processing

You may withdraw your consent at any time by contacting us at [email protected] or through the settings in our app.

13. Automated Decision-Making and Profiling

We do not engage in automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you.

If we introduce such features in the future, we will provide clear information and obtain your explicit consent where required.

14. Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you without undue delay.

We will also notify the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible.

15. Complaints to Supervisory Authorities

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement.

For users in the European Economic Area, you can contact your local data protection authority.

16. 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 and updating the effective date.

We will also notify you via email or in-app notification for material changes to this Privacy Policy.

17. Contact Us

If you have any questions about this Privacy Policy, please contact us at [email protected].