Thank you for your interest in our services. Read carefully our privacy policy incorporated herein before you start using the Heyway mobile app. BY DOWNLOADING, INSTALLING OR USING THE APP (AS DEFINED IN SECTION 1 OF TERMS OF SERVICE) YOU AGREE THAT YOU HAVE READ, UNDERSTOOD AND ACCEPTED TO BE BOUND BY THIS PRIVACY POLICY WHICH TOGETHER WITH TERMS OF SERVICE CONSTRUES THE AGREEMENT BETWEEN YOU AND US. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY YOU SHALL NOT USE OUR SERVICES. Any terms used in this document which start with capital letter shall have the meaning defined in section 1 of the terms of service available under following link. [●]
- The Administrator may collect following information regarding the User (including personal data) in connection with the use of the Services:
- any information provided by the User during registration of the Account (particularly any information listed in section 5 of terms of service).
- any information made available by the User in his/her Facebook account – in accordance with privacy settings chosen by the User in Facebook (particularly: email address, first name, last name, nickname, gender, list of friends).
- any information made available by the User during use of the Services, particularly any messages, comments, reviews, photos, videos.
- GPS location of User’s mobile device – as provided by the mobile device used by the User; GPS localization may be disabled by the User directly on the mobile device used by the User, it will however decrease significantly functionalities of the App.
- information about connections and contacts between the Users.
- information about preferences of the User (regarding particularly choice of places, goods and services reviewed or otherwise mentioned by the User within or through the App, User’s interests, data indicated in pt. 5 below).
- information about search terms used by the User within the Services.
- information about friends requested by the User to join the Services (particularly first name, last name, e-mail address).
- The Administrator (Let’s Meet sp. z o.o. with its registered seat in Warsaw under following address: Chmielna 2/31, 00-20 Warsaw, entered into commercial register in National Court Register in the District Court for the capital city of Warsaw, 12th economic division, under KRS no. 702848, NIP (VAT-EU): PL 5252728399, REGON: 368706396, with a share capital of 6250 PLN – fully paid, e-mail: support@heyway.pl) shall perform the function of administrator of personal data collected from the Users. Any personal data collected by Administrator shall be stored and processed in accordance with regulations provided by applicable laws, particularly:
- Polish Personal Data Protection Act, dated 29 August 1997 – until 24 May 2018.
- Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as “GDPR” – from 25 May 2018.
- The User understands that he/she is free to:
- access his/her personal data processed by the Administrator.
- demand from the Administrator to supplement, update, rectify his/her personal data collected by the Administrator.
- demand temporary or permanent stopping of processing of User’s personal data.
- demand from the Administrator to delete User’s personal data in situations listed in art. 17 of GDPR, particularly in case if they are processed with a breach of applicable laws or if they are no longer needed to gain the purpose for which they were collected. The User understands and accepts however that deletion of certain personal data may disallow or impair provision of the Services. The Administrator reserves the right to retain the information required by applicable laws, information required to enforce any rights arising from the Agreement, to prove proper provision of the Services or to report or document any crime, tort or abuse committed by the User in connection with use of the Services.
- demand from the Administrator to limit processing of User’s personal data in situations listed in art. 18 of GDPR (starting from 25th May 2018).
- demand from the Administrator to transfer User’s personal data processed by the Administrator due to regulations provided in art. 20 of GDPR (starting from 25th May 2018).
- file an objection to processing of User’s personal data due to regulations provided in art. 21 of GDPR (starting from 25th May 2018).
- file a complaint to supervisory body (starting from 25th May 2018).
- withdraw at any time User’s consent on processing of his/her personal data for a purpose indicated in pt. 4.3 below.
- User’s personal data revealed during registration of the Account (listed in pt. 5.2 and 5.5 of terms of services) are necessary for conclusion of the Agreement and use of the Services by the User. Processing of aforementioned personal data and other personal data revealed by the User during use of the App will be performed by the Administrator for following purposes:
- In order to perform the Services by the Administrator – as necessary for execution of the Agreement;
- In order to promote Administrator’s services and goods within the App and using User’s e-mail address linked with the Account – as necessary to achieve the objectives arising from the legitimate interests of the Administrator;
- In order to promote services and goods of Administrator’s business partners within the App and using User’s e-mail address linked with the Account – in case the User expresses his/her consent and based on that consent.
- The User adding or responding to any dating announcements within the use of the App indirectly discloses his/her sexual orientation. These data, constituting a special category of personal data within the meaning of art. 9 of GDPR, will be processed by the Administrator only to provide Services. In the same way and for the same purpose, the Administrator may process other special categories of personal data disclosed by the User – e.g. in connection with participation in specific public events declared by the User within the App, publication of specific announcements or comments by User, which may reveal data on political views, religious beliefs and philosophical beliefs of the User. The User discloses such data always in a voluntary and conscious manner, their processing by the Administrator will take place only for the purpose of proper provision of the Services. The User declares and accepts that his use of the Application in a way that reveals his sexual orientation, political views, religious beliefs or philosophical beliefs may lead to the public disclosure of such data within the meaning of Art. 9 clause 2 pt. e of GDPR and will authorize the Administrator to process such data in order to provide the Services. In case of disclosing personal data of special category as part of private messages sent to other Users, which will not be automatically made public, the User declares that he/she consents to the processing of such special categories of personal data by the Administrator in order to perform the Services.
- The User agrees that certain scope of personal data and other information disclosed by the User within his/her use of the App will be publicly available on the webpage dedicated to the App – under following link: support@heyway.pl. The aforementioned will apply to the following personal data of the User:
- profile picture;
- city of residence;
- name of the User.
- Personal data other than listed in pt. 6 above will be available, subject to pt. 8 and 9 below, only to other registered Users of the App.
- User’s personal data disclosed as part of using the App may be transferred by the Administrator to the following recipient categories:
- providers of hosting services;
- providers of mail services, including electronic mail;
- providers of legal, tax and accounting services;
- providers of IT services (providing support in App maintenance).
- Irrespective of pt. 8 above, any information collected by the Administrator within administration of the App (including personal data of the User) may be disclosed to:
- other Users – when information are made available to them by the User (particularly by contacting other Users or placing information in publicly accessible area of the App).
- employees and contractors of the Administrator involved in provision of Services (such as IT experts, software developers, hosting providers, payment processors, legal advisors).
- any subsidiaries, affiliates, buyers or successors of the Administrator (particularly in case of any merger, acquisition or transformation of the Administrator).
- to third parties advertising their services within the App – in regard to the User who consented on receiving such advertisements on his/her e-mail address linked to the Account.
- any courts, administrative bodies and law enforcement agencies – in accordance with applicable laws.
- third parties who have filed claims against the Administrator, its affiliates, owners or members of the Administrator’s bodies with respect to the content posted by the User within the App or with respect to any breaches of the Agreement by the User.
- The User’s personal data will be stored by the Administrator for (i) the entire period when the User holds an active Account and the following period equal to (ii) the period of expiration of all claims that may be vested in the User and Administrator in connection with the use of the Services by the User, plus (iii) the period of the next 12 months needed to ensure that no claims have arisen or have been placed before the expiry of the period of their expiration. After this period, personal data disclosed by the User within use of the App will be deleted or anonymized by the Administrator.
- The User’s personal data will not be transferred outside the European Economic Area, with the exception of entities based in countries which, in accordance with the relevant European Commission decision, ensure an adequate level of protection of personal data and entities based in the United States of America who are signatories of Privacy Shield program ( e.g. Google, Microsoft).
- The User’s personal data and other information indicated in the Agreement may be collected directly from the User or automatically during the registration of the Account or use of the Services.
- User’s personal data and any other data collected by the Administrator will be stored on Google Cloud Datastore and/or Google Cloud SQL servers located in Germany. If the User accesses the App from other countries, he/she accepts that his/her personal data will be transferred to Germany and may be transferred to other countries in connection with storage and processing of data and provision of Services.
- The Administrator may at any time change the hosting provider and the location of the servers to a different location within a country that is a member of the European Economic Area, which will be notified by updating this privacy policy.
- Any inquiries or requests regarding processing of User’s personal data by the Administrator shall be directed to Administrator in Polish or English:
- By post – on Administrator’s address indicated in pt. 2 above, or
- By e-mail sent from his/her contact e-mail address linked with his/her Account – on a following e-mail address of the Administrator: support@heyway.pl.
- The Administrator uses cookies and similar technologies. Cookies are small data files sent by the website and stored in the User’s web browser in order to help the Administrator develop the App. The cookies alone don’t allow User’s identification. By using the App or website dedicated to the App (address: heyway.pl) without prior settings change of the software used by the User, the User agrees to accept cookies by used software (particularly web browser used by the User). Guidelines for blocking cookies in most popular Internet browsers may be found under following links: Mozilla Firefox / Internet Explorer / Opera / Google Chrome. The Administrator is committed to offer the User a choice regarding provision of their personal data as well as data collected by cookies. The User agrees however that refusal of provision of required data or blocking of cookies may disallow provision of the Services or cause improper functioning of the App.
- The Administrator may use both persistent cookies and session cookies. Persistent cookies remain after the User closes Internet browser in his/her electronic device and may be used during User’s subsequent visits to the App and webpage dedicated to the App. Session cookies disappear after the User closes Internet browser in his/her electronic device.
- The cookies enable tracking of following information:
- information about User’s activity within the App or webpage dedicated to the App, regarding particularly: time and duration of use of the Services, visited web addresses, functions used within the Services.
- information about software (particularly Internet browser and operating system) and electronic device used by the User.
- information about location of the User.
- information about Internet addresses visited by the User directly before and after use of the Services.
- information about Internet connection provider.
- information about Internet connection speed and type.
- unique mobile device identifier assigned by the manufacturer of the mobile device used by the User.
- MAC address of the electronic equipment used by the User.
- User’s preferences regarding chosen language or time zone.
- Information about online or offline status of the User in the App.
- The cookies, similar technologies and collected information are used by the Administrator for following purposes:
- to remember User’s choices within the App and webpage dedicated to the App and enable faster and more comfortable use of the App and webpage dedicated to the App.
- to improve the App and webpage dedicated to the App and personalize the content provided within the App and webpage dedicated to the App adequately to User’s location, choices and preferences.
- to diagnose and analyze any technical problems within the App and webpage dedicated to the App.
- to increase the security of the Services.
- to allow keeping the User logged in to the App.
- to process any queries placed by the User.
- to generate reports about the use of the App and webpage dedicated to the App by the User.
- to provide the User with notices regarding the Account and the App.
- to display ads which are adequate to User’s preferences.
- to allow and maintain proper use and functionality of the App and webpage dedicated to the App.
- to generate, analyze and provide the providers of services included in the App (particularly ISP) the anonymized statistics including, particularly: age, gender and place of residency of User reviewing services offered by ISP.
- to perform any obligations and enforce any rights arising from the Agreement.
- any other purposes agreed with the User.
- The User acknowledges that he/she may be subject to profiling by means of cookie files collecting information about the User’s interests and preferences. Profiling will aim to adapt the advertising and marketing content displayed within the App to the interests and preferences of the User, but will not affect the legal situation of the User or the ability to use the Services.
- The Administrator may use Google Analytics or other web analytics services offered by third parties which allow collection of anonymous data regarding the use of the Services by the User, particularly information listed in pt. 18 above collected for purposes listed in pt. 19 above. Such information may be collected directly by or disclosed to web analytics service providers.
- Purchase of a Premium Account subscription may require the User to disclose information regarding User’s credit card, debit card or bank account number. By providing such information, the User discloses them directly to the entities handling the payment, in accordance with the rules of using the Google Play store and the Apple Store. These data are not disclosed to the Administrator. However, disclosure of the User’s bank account details to the Administrator is necessary in case of refund of all or part of the payment of purchase price made by the User for Premium Account subscription.
- The User acknowledges and agrees that use of social media features (such as Facebook like button) within the App or webpage dedicated to the App may cause collection and publication of information regarding the User by social media provider.
- Third parties services linked with the Services (such as Facebook, Google Maps) may use their own cookies and similar technologies – respectively to their own privacy policies. Privacy policy of Facebook, Inc. (owner of www.facebook.com service) may be checked at https://www.facebook.com/about/privacy, privacy policy of Google, Inc. (owner of Google services) may be checked at https://www.google.com/policies/privacy/.
- The Administrator reserves the right to anonymize, in accordance with provisions of applicable laws, any information collected from the User. Anonymized information (non-personally identifiable information) are not restricted by provisions of this privacy policy and may be used and disclosed to third parties without limitation.
- The Administrator undertakes appropriate technical, organizational and physical means to safeguard any data collected from the Users and prevent unauthorized access to such data. However, no method of storage of electronic data and transmission of data via Internet or mobile device is fully secure and cannot be guaranteed by the Administrator. The User shall use reliable anti-virus software and protect confidentiality of his/her login and password allowing use of the Services.
- This document constitutes an integral part of the Agreement. In matters which are not regulated by this privacy policy, provisions of terms of service and applicable laws shall apply.