This Privacy Policy describes how ColdLake OÜ ("ColdLake," "we," "us," or "our"), collects, uses, stores, and shares your personal data when you use our mobile application "Bengodi" (the "App").
We are committed to protecting your privacy and handling your data in a transparent and lawful manner, in accordance with the General Data Protection Regulation (GDPR) (EU 2016/679) and applicable Estonian data protection laws.
1. Data Controller
ColdLake OÜ is the data controller responsible for the processing of your personal data collected through the Bengodi App.
2. What Personal Data Do We Collect?
We collect the following types of personal data:
- Account Data: When you create an account, we collect your username and email address.
- Profile Information (Optional): You may choose to provide additional information for your public profile, such as a profile picture, a short bio, or other details.
- Content Data:
- Pictures: Pictures you choose to upload to the App.
- Geographical Information (Location Data): We collect the precise geographical location (GPS coordinates) where a picture was taken. This data is associated with the picture.
- Post Content: Any text, captions, or other information you add to your posts.
- Visibility Settings: Information about whether you designate a post as "public" or "private."
- Interaction Data: Information about your interactions within the App, such as comments you make, likes you give, and users you follow.
- Device and Usage Data: We automatically collect certain information when you access and
use the App, including:
- Your device's unique identifier.
- Your mobile operating system.
- The type of mobile Internet browser you use.
- IP address.
- App usage statistics (e.g., features accessed, time spent on the App).
- Crash logs and performance data.
- Communication Data: If you contact us for support or other inquiries, we collect the content of your communication and our responses.
3. How We Collect Your Personal Data
We collect personal data in the following ways:
- Directly from You: When you create an account, upload pictures, set post visibility, or communicate with us.
- Automatically: Through your use of the App, your device's GPS functionality, and standard logging technologies.
- From Your Device (with your consent): We request access to your device's local pictures only for the purpose of allowing you to select which pictures you wish to upload to the App. We do not access, collect, or store any local pictures other than those you explicitly choose to upload.
4. Legal Basis for Processing Your Personal Data (GDPR)
We process your personal data based on the following legal bases:
- Performance of a Contract (GDPR Article 6(1)(b)): We process your Account Data, Content Data (pictures, post content), and Interaction Data to provide you with the Bengodi service.
- Your Consent (GDPR Article 6(1)(a)):
- Location Data: We will explicitly ask for your consent to access and collect your GPS location data when you take a picture within the App. You can withdraw this consent at any time.
- Access to Local Pictures: We will ask for your consent to access your device's local pictures solely for the purpose of allowing you to select images for upload.
- Legitimate Interests (GDPR Article 6(1)(f)): We may process Device and Usage Data for our legitimate interests to improve the App, ensure security, and analyze trends.
- Legal Obligation (GDPR Article 6(1)(c)): We may process your personal data where it is necessary to comply with a legal obligation to which we are subject.
5. How We Use Your Personal Data
We use your personal data for the following purposes:
- To Provide and Maintain the App: To operate the core functionalities of Bengodi.
- To Display Your Content: Handling both public and private post visibility based on your exact settings.
- To Personalize Your Experience: To recommend content or users that may be of interest to you.
- To Improve and Develop the App: To understand how users interact with Bengodi and develop new features.
- For Security and Fraud Prevention: To protect the integrity of the App and prevent unauthorized activities.
6. How We Share Your Personal Data
We may share your personal data with the following categories of recipients:
- Other Bengodi Users: Based strictly on your public or private visibility settings.
- Service Providers: Cloud hosting providers, analytics providers, and customer support bound by strict data processing agreements.
- Legal and Regulatory Authorities: If required to do so by law or in response to a court order.
- Business Transfers: In the event of a merger, acquisition, or sale of assets.
- Aggregated or Anonymized Data: Data from which your personal identity has been removed.
7. International Data Transfers
As ColdLake OÜ is an Estonian company operating within the EU, your data is primarily processed and stored within the European Economic Area (EEA). If we transfer your personal data to countries outside the EEA, we will ensure that appropriate safeguards are in place, such as Standard Contractual Clauses.
8. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes for which it was collected. Generally:
- Account Data: Retained for as long as your account is active.
- Content Data (Pictures, Location, Posts): Retained for as long as the content is active on the App. Deleting a picture deletes its associated location data.
- Usage and Device Data: Retained for a period necessary for analytics and security purposes, typically up to 6 months.
9. Your Data Protection Rights (GDPR)
As a data subject under GDPR, you have the following rights concerning your personal data:
- The Right to Be Informed about the collection and use of your data.
- The Right of Access to request a copy of the personal data we hold about you.
- The Right to Rectification to correct inaccurate or incomplete data.
- The Right to Erasure ("Right to Be Forgotten") under certain circumstances.
- The Right to Restriction of Processing to limit the way we use your data.
- The Right to Data Portability to receive your data in a machine-readable format.
- The Right to Object to processing based on legitimate interests or direct marketing.
To exercise any of these rights, please contact us using the contact details provided in Section 11.
10. Security of Your Personal Data
We implement appropriate technical and organizational measures to protect your personal data, including encryption, access controls, regular security audits, and data minimization. While we strive to protect your personal data, no method of transmission over the internet or method of electronic storage is 100% secure.
11. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us:
ColdLake OÜ
Email: info @ coldlake.eu
12. Complaints to the Supervisory Authority
You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).
Address: Tatari 39, 10134 Tallinn, Estonia
Website: www.aki.ee
13. 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" at the top.