** Personal Data Protection Policy

Effective date: 23 / 03 / 2020

Nissatech Innovation Centre is the owner of Smart4Fit, software as a service (Service).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our privacy policy is created in good faith to ensure your privacy and to protect your rights according to the General Data Protection Regulation (GDPR). We ensure that you will have: a “right to be forgotten”, easy access to your data, data portability, the right to know when your data has been hacked, and protection of your data by design and by default.

** Key Stakeholders
* Nissatech Innovation Centre: Processor and Co-Controller

* The users of the Service: Personal Data Owners
* Lead Supervisory Authority: Government representative

** Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

** Types of Data Collected

** Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
* Email address

* First name and last name
* Date of birth
* Heart rate
* Weight
* Height
* Gender
* Fitness level

** Usage Data

When you access the Service by or through a mobile device, we may collect (log) certain information automatically, including, but not limited to:
* The unique ID of the smartwatch (Wear OS) device you use li>

** Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

The type of cookies we use:

* Session Cookies. We use Session Cookies to operate our Service.
* Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
* Security Cookies. We use Security Cookies for security purposes.

** Use of Data

Nissatech Innovation Centre uses the collected data for various purposes:
* To provide and maintain the Service
* To notify you about changes to our Service
* To allow you to participate in interactive features of our Service when you choose to do so
* To provide customer care and support

* To provide analysis or valuable information so that we can improve the Service
* To monitor the usage of the Service
* To detect, prevent and address technical issues

** Transfer Of Data

Your Personal Data (or any personal identifiable information), will not be transferred to and maintained on computers or any devices located outside of the European Union.

If there is any justifiable need to transfer the data outside of the EU, Nissatech Innovation Centre is obligated to obtain the consent from all relevant data owners.

The only type of data that may be transferred outside of the EU is Usage Data. This data does not contain any personal identifiable data and is only used to ensure the quality of Service.

Nissatech Innovation Centre will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

** Disclosure Of Data

** Legal Requirements

Nissatech Innovation Centre may disclose your Personal Data in the good faith belief that such action is necessary to:
* To comply with a legal obligation
* To protect and defend the rights or property of Nissatech Innovation Centre
* To prevent or investigate possible wrongdoing in connection with the Service

* To protect the personal safety of users of the Service or the public
* To protect against legal liability

** Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We are obligated to follow any data protection rights, communicate any data breach and other personal data issues, as recommended by GDPR, with the Owners of the data and the Lead Supervisory Authority.

** Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

** Children’s Privacy

Our Service does not address anyone under the age of 16 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

** 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 will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

** What are your data protection rights?

Nissatech Innovaton Centre would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.

The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us via the contact information we have provided in contact section of the Privacy Policy

** Contact Us

If you have any questions about this Privacy Policy, please contact us:
* By email: info@smart4.fit

* By support number: +38162244941