Terms of Service

ACCEPTANCE OF TERMS

In what follows "Future Decoded" and "We" refer to SC Future Decoded SA, the company from Bucharest, Romania. The Zinny Service (or "Service") refers to the Zinny mobile applications. The Services are designed to read technical details about Your device and network diagnostic information to give You a fair opinion about how Your device works, as well as to help You quickly run certain commands to Your device.

The Zinny Service is a venture of Future Decoded. This is a legal agreement ("Agreement") between You and Future Decoded, for use of the Zinny service. Through this Agreement, You acquire a limited, non-exclusive, non-transferable, non-sublicensable license to use the Service on any mobile device that You own or control.

"You" refers to any individual who agrees to approve these terms of service by clicking "OK" in the Zinny mobile apps or, if the Service is being used on behalf of an entity by an individual authorized to agree to such terms on behalf of such entity, then "You" refers to such entity. If You do not agree with the terms of this Agreement, do not click "OK" and do not use the Service, click "Cancel" to exit the mobile application. Future Decoded reserves the right to update and change the Agreement from time to time without notice or acceptance by You. The Agreement will also be applicable to the use of the Service on a trial basis. By using the Service, You signify Your irrevocable acceptance of this Agreement. Future Decoded (including its affiliates and subsidiaries) hereby grants You permission to use the Zinny Service for non-commercial purposes, subject to these Terms.

Unless explicitly stated otherwise, any new features that augment or enhance the current Service, including the release of new tools and resources, shall be subject to the Agreement. To use the Service through the World Wide Web, You must obtain access to the World Wide Web, either directly or through devices that access web-based content and pay any Service fees associated with such access. In order to use the Service mobile applications, You will need a phone with the ability to access network data.

Some of the features of the Service may be or become available only as part of a subscription plan, which may require payment of certain fees.

HARVESTING OF DATA

You agree not to use or launch any automated system, including without limitation, "robots," "spiders," and "offline readers," that accesses the Zinny Service in a manner that sends more request messages to the Zinny servers in a given period of time than a human can reasonably produce in the same period by using a conventional browser.

You agree not to collect or harvest any information from the Zinny Service (other than information made available by Us), nor to use the Zinny Service for any commercial purposes. You may not hack or otherwise modify the code of the Zinny application. You may not send requests to the Zinny servers purporting to be from the application that are not from the application. You agree not to sell, resell any portion of the Zinny Service, use of the Zinny Service, or access to the Zinny Service without the express permission of Zinny. You may not send spam or transmit any content that contains software viruses or other harmful computer code, or disrupt servers or networks connected to the Zinny Service.

Future Decoded has the right to terminate Your access to the Zinny Service, at its sole discretion.

PROPRIETARY/INTELLECTUAL PROPERTY RIGHTS/THIRD PARTY CONTENT

The content on the Service, including without limitation, the Android application, signal data, text, graphics, skins, and icons ("Content") and the trademarks and logos ("Marks"), are owned by or licensed to Future Decoded. Content on the Zinny Service is provided to You "AS IS" for Your information and non-commercial use only and may not be used for any other purpose without Our prior written consent. We reserve all rights not expressly granted to You. You agree not to circumvent, disable or otherwise interfere with security-related features of the Zinny Service. Future Decoded makes no representations or warranties regarding the accuracy or completeness of the information provided by the Zinny Service.

The Zinny Service may contain links to third party websites that are not owned or controlled by Future Decoded. Future Decoded assumes no responsibility for any third-party website, and You release Future Decoded from any liability arising from Your use thereof.

INJUNCTIVE RELIEF

You acknowledge that any use of the Service contrary to this Agreement, or any transfer, sublicensing, copying or disclosure of technical information or materials related to the Service, may cause irreparable injury to Future Decoded, its affiliates, suppliers and any other party authorized by Future Decoded to resell, distribute, or promote the Service ("Resellers"), and under such circumstances Future Decoded, its affiliates, suppliers and Resellers will be entitled to equitable relief, including, but not limited to, preliminary and permanent injunctive relief.

NO WARRANTIES OR REPRESENTATIONS BY FUTURE DECODED

The Zinny service (including the content and any other services provided thereby) is provided "as is" and without warranties of any kind including without limitation, warranties of merchantability, fitness for a particular purpose, title, non-infringement, and those arising by statute or from a course of dealing or usage of trade. The content may not be current, accurate or complete, and Future Decoded does not guarantee that the Zinny service will be free of bugs, security breaches, viruses, or that it will always be available.

INDEMNITY

You agree to indemnify, defend and hold harmless Future Decoded, its affiliates, officers, directors, employees, consultants, agents, suppliers and Resellers from any and all third party claims, liability, damages and/or costs (including, but not limited to, attorneys fees as and when incurred) arising from Your use of the Service or Your violation of this Agreement.

INTERNATIONAL USE

Recognizing the global nature of the Internet, You agree to comply with all local rules regarding online conduct and acceptable content.

PHONE CHECK

The Service allows You the possibility to test Your phone’s seven (7) main functionalities (namely communications, sensors, battery, sounds, screen, hardware and camera) in order to evaluate if Your phone components are operating properly.

You may choose to undertake a complete phone evaluation, by pressing the button "Run Full Check", or just pick manually the test You want to run.

The Service can perform the above tests both automatic and manual, based on the test You choose. We can test manually for example, touchscreen, display, speaker (we’ll play a number of sounds and You have to count them), wired headphones, light sensor, proximity sensor, compass, charger, physical buttons, flashlight. The automatic test comprises, for example, battery autonomy (records of battery consumption over the last 7 days), battery health, battery temperature (average over 7 days), SIM status (registered/not registered), Wi-Fi and Bluetooth (We scan if We can find devices nearby), Internet connection (check if there is connectivity to certain servers).

The results of these tests are generated by the Service in the form of a report (the "Report"), which also includes Your phone’s IMEI number. Such Report is available to You in the Results menu.

You may choose to share the Report with Your friends, third parties or to publish it.

We use the Reports received for the purposes described below:

• to create a global database ascertaining the performance of phones tested through our Service;
• to publish aggregate data regarding phones’ performance results based on criteria like phone models or phones hardware components (e.g. battery autonomy under 12 hours on specific phone models);
• to make available to our partners aggregate phone data based on phone models.

PHONE COMPATIBILITY

The Service also allows You the possibility to explore Your compatibility with other devices, based on Your preferences and on those devices’ specifications. When You launch "Choose my next phone" module of the Zinny app, We will undertake an automatic test of Your device and provide a Report. This Report will serve as a benchmark, so We can recommend a new device based on a comparison with Your current device.

We will ask You to tell Us which are Your preferences in terms of how fast You’d like Your new device to be as compared to Your current device, what size of screen You prefer, what are Your expectations in terms of battery autonomy, price range and other stuff. If You give Us permission, We would like to know which apps You use the most on Your device so that We ca recommend something suitable.

Based on the automatic check Report and on Your preferences, We will recommend one or more smartphones which We think are suitable to You. We will also tell You if these smartphones are available in Our partners’ shops and show You Our partners’ offers. You may choose to select one offer directly from Zinny app, in which case You will be re-directed to the relevant website.

CHATBOT

You may access Our Chatbot to ask questions about Your device. We will try to assist You with Your queries based on the information extracted from the data collected from Your device. For example, if You ask Us how You can improve Your device autonomy, We will run a check on Your device and offer some recommendations, such as may be, for instance, to adjust brightness of Your screen.

RECOMMENDATIONS

Sometimes, We will make recommendations based on the information You provide to Us. Note that all information We provide to Your as recommendations are mere suggestions, and We undertake no obligation or liability in connection with the recommendations We present to You. The recommended products or services are offered by third parties and, should You choose to buy products or services We recommend, You will enter an agreement with the third parties offering such products or services.

The recommendation presented to You shall not be considered as being the only ones available or the best options on the market. Future Decoded has not made any comprehensive assessment of the offers available and has not made a comparison of prices and commercial conditions associated with the products or services offered by Our recommended partners. We strongly recommend You to carefully check the service offers, terms of service, working schedule and delivery deadlines.

Some of the recommendations We present to You may be based on partnership agreements We sign with Our partners.

As You may learn in more detail from Our Privacy Policy, We do process Your personal data to do all these.

Privacy Policy

In what follows "Future Decoded" and "We" refer to SC Future Decoded SA, the company from Bucharest, Romania. The Zinny Service (or "Service") refers to the Zinny mobile applications. The Zinny service is a venture of Future Decoded.

"You" refers to any individual who agreed to approve the Zinny Terms of Service by clicking "OK" in the Zinny mobile apps. Future Decoded has a profound respect for user privacy. This policy explains the privacy practices of Our Service. It describes how Future Decoded collects and uses information that You provide to Us.

In this policy, the term "Personal Information" (or "personally identifiable information") means any information that, with reasonable efforts, may be used to identify You, such as a first and last name, home address or email address.

A. Data controller

Your data controller is Future Decoded SRL, a company incorporated in Romania, with registered headquarters Gheorghe Moceanu no 11, ground floor, room 3, Bucharest, Postal code 011924. Should You require further information on how Future Decoded is processing Your personal data or should You wish to exercise Your rights as data subject, please contact Us at the following contact details: (feedback@futuredecoded.ro) or by regular post at Gheorghe Moceanu no 11, ground floor, room 3, Bucharest, Postal code 011924, ROMANIA.

B. Data We collect

We do collect certain amount of data from You and from Your device. In general, We collect technical data about Your Device (storage capacity, device type, device hashed ID, IMEI, approximate location, etc.), network diagnostic data (e.g., network strength), data related to your mobile services resources and the traffic on your mobile device as well as data about Your preferences in terms of smart devices.

Most of the data We collect is not Personal Information, as it may not be tracked down to You. Future Decoded makes commercially reasonable efforts to permanently remove or obscure Your identity so that information collected is not linked to an identifiable person. Unless You choose to send Us an inquiry, We will never ask Your name, phone number or email address. Nevertheless, data collected from You or Your device may be sometimes associated with a unique identifier (such as Your phone IMEI number) and We then use that identifier to reach out to You. That is the case, for example, when You launch "Choose my next phone" module of the Zinny app to give Us data about Your preferences and We come back to You with suggestions as to which might be an appropriate device to match Your preferences.

We also use anonymous and aggregated data collected from you and your device to build up a database with analytic data.

C. HOW WE USE YOUR DATA

C.1. Providing You with Our Service

If You chose to install Zinny apps, it means You want to know more about Your device. You want to know about battery life, network strength, available storage, whether Your camera or Your light sensor work properly or other interesting and useful stuff about Your device. Through Zinny We can read Your approximate location along with other technical details about Your device and network diagnostic information to give You a fair opinion about how Your device works.

We read all this information to provide You with Our Service and to offer You information about how Your device works. When We do that, We rely on the Terms of Service which You have accepted when You chose to install Zinny apps. We wouldn’t be able to provide You with Our Service if We didn’t read these device and network diagnostic data.

Future Decoded makes commercially reasonable efforts to permanently remove or obscure Your identity so that information collected for this purpose is not linked to an identifiable person. Moreover, We will never read, copy or otherwise process Your contacts, Your photos or other Personal Information You store on the device in order to provide You with Our Service.

C.2. Analysis and management of Our activity

We process some data to organize in the best way and make Our Services more efficient, namely, to analyse how customers use the Services. In order to do that, We process data on how You use Our Services – how often You run a check of Your device, what features of Our apps You use the most, etc. When We do that, We rely on Our legitimate interest to ensure quality of the Services We provide to Our customers.

Future Decoded makes commercially reasonable efforts to permanently remove or obscure Your identity so that information collected for this purpose is not linked to an identifiable person.

C.3. Provision of friendly services related to your mobile services

When You access “My Resources” Module and click on the Refresh button We will deem We have Your consent to send an SMS to your mobile services carrier in view of obtaining an update on Your available resources. What Zinny does is that once You click the Refresh button it accesses Your device and sends the SMS to Your mobile services carrier from Your device. After the SMS is sent, Zinny app scans your SMSs (sees only if a SMS is received from the standard number used by your mobile services provider after You used My Resources, without being able to see the other SMSs details) and when it identifies a SMS is received from Your mobile services provider’s standard resources number, it processes such SMS to illustrate You in a friendly visual interface in the Zinny app your current resources.

When You use “Manage my services” Module You can interrogate the status of specific services which may be provided by Your mobile services provider. What Zinny does is to access Your device and send a request to Your mobile services provider from Your device, so that You benefit these services. Clicking on the request for a specific service status represents Your consent for Zinny to undertake such operation.

When You use Our other various automatic options available in the Zinny app (e.g., activate a specific mobile service offer, pay a specific fee, etc.), Zinny will process Your data in view of fulfilling Your order (e.g., will send via Your device SMSs/USSDs to the relevant services provider to fulfil Your order). Such processing will take place based on Your consent expressed when clicking on the relevant service request.

C.4. Customer support

Your Personal Information (such as Your unique ID allocated by Zinny or Your contact details) may be collected when Future Decoded exchanges communications with You, for example, if You submit a request, contact Zinny'' support team, or report a violation to the abuse team. We will use the Personal Information You provide exclusively for the purpose of handling Your request.

When We do that, We rely on Our legitimate interest to properly manage requests concerning Our Services and to keep Our customers informed on any relevant aspects regarding the Services provided to them.

C.5. Preference data. Marketing and communications

The Service allows You the possibility to explore Your compatibility with other devices, based on Your preferences and on those devices’ specifications. When You launch "Choose my next phone" module of the Zinny app, We will undertake an automatic test of Your device and provide a Report. This Report will serve as a benchmark, so We can recommend a new device.

We will ask You to tell Us which are Your preferences in terms of how fast You’d like Your new device to be as compared to Your current device, what size of screen You prefer, what are Your expectations in terms of battery autonomy, price range and other stuff. We will open an interface of Zinny app where We will suggest the features of Your next device (Our suggestions will rely on the features of Your current device). In that interface, You may customize Your preferences (wider screen, better battery life, etc.). Sometimes, We may also ask You a few questions on Your preferences and things You like or dislike about Your device. If You give Us permission, and if You confirm that You are over 16 years of age, We would like to know which apps You use the most on Your device.

We will use Your preference data and data on what apps You mostly use on Your device to recommend a new device or accessories which would best suit Your preferences. Our recommendations will be the result of automatic processing of Your preference data. Our algorithm assesses matching scores with each device in Our library. For example, if You prefer a device with a 6 inches wide screen, We will apply 100% matching score to all devices having a 6 inches or wider screen and a lower matching score (e.g., 97%) for devices with 5.8 inches wide screen. We will do that for each of Your preferences and calculate average matching scores for each device in Our library. We will ask for Your consent and We will ask You to confirm that You are over 16 years of age whenever We will use Our algorithms to recommend new devices based on Your preferences.

Devices with highest matching scores will be presented to You in the app, along with Our partners’ commercial offers for the selected devices. You will also be able to set up price alerts and the app will notify You if Your desired device is available for the price range You have set up the alert for. These offers and alerts will be presented to You directly in the app. We will not ask for any contact details, such as phone no., email, etc. to send You commercial offers.

If You click “buy” on any of the offers presented to You, We will associate an ID to Your request to buy and send that ID to the Partner whose offer You have chosen. That way, Our partners will have an image on the amount of clients generated by Our app. When We do that, We rely on Our legitimate interest to show Our partners the number of clients Our app has generated to them. Some of Our partners are paying Us for clients We generate to their businesses. When You consented to be profiled, including when You use “My Next Subscription” module of the Zinny app, We will analyze Your data related to mobile services resources and the data collected from Your device (only data volumes) and such will be used as a benchmark so We can recommend You the most suitable offers considering Your needs. Should you not consent to such operation, You will not receive customized offers in respect to services which may be of interest for You.

Currently We send such communication only directly in the app. However, in the future We may also send You such communications also to the other contact coordinates available in Our app (e.g., e-mail, phone number, etc.).

C.6. Functioning of the IT systems, security and abusive use

Future Decoded collects information about the use of the Services. For example, Zinny may record the frequency and scope of Your use of the Services, the duration of Your sessions, the Internet protocol (IP) address, the name of the domain that serve You to access the Services, and the approximate location of the smartphone that You are using to log-in. Such data is usually automatically collected and stored in log files of the Services'' servers. To do that, We rely on Our legitimate interest to ensure the viability of the IT systems, the prevention and investigation of fraudulent and abusive use of Our systems / Services

Future Decoded makes commercially reasonable efforts to permanently remove or obscure Your identity so that information collected is not linked to an identifiable person.

C.7. Analytic data

We process location data, technical details about Your device, details about Your resources and Your device traffic use and network diagnostic information to create a database with anonymous, statistical, or aggregated data about Our users’ devices. Sometimes, We may also ask you a few questions on Your preferences and things You like or dislike about Your device. We may include the answers We receive to Our surveys in Our database with anonymous, statistical, or aggregated data. Future Decoded may use Personal Information You provide to carry out analyses and statistics on how Our Services are used or otherwise how You interact with them. We do that to properly operate the Services, to improve the quality of the Services, to enhance Your experience, to create new services and features, including customized services, to change or cancel existing content or Service, and for further internal, commercial, and statistical purposes.

The app does use third party services that may collect and process information. Such collection and processing is subject to the privacy policy of the relevant third party. For details on the technologies used, please refer to Our Analytic Tools Section below.

We also use the Advertising Identifier which is a random device identifier assigned by the operating system of Your device. This identifier allows Us to uniquely distinguish Our apps users. We may rely on the Advertising Identifiers to gather insights on how the users interact with Our app, namely: to understand which of Our offers You have chosen in the module „Choose my next phone".

Future Decoded may also use anonymous, statistical or aggregated information collected on the Services, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services'' providers, partners and any other third party. For example, based on analytic data We collect, We may be able to say that a certain model has a better battery autonomy as compared to another one. Or that the network quality is better in a certain area than in another area. We may share such information with Our partners and users. When doing so, We rely on Our legitimate interests to improve Our Service and to study performance of various types of devices in different situations.

Data processed for this purpose is in all cases anonymized and aggregated. Future Decoded makes commercially reasonable efforts to permanently remove or obscure Your identity so that information collected is not linked to an identifiable person. Even so, You may stop at all times the application from collecting analytic information from the settings menu. Following the turning off the data sharing menu, We will not be able to include further location, technical details or network diagnostic information collected from You in Our analytics database. When the data collection is disabled, certain Service functionalities might not work, like the Battery diagnostic based on historical data.

C.8. Personalized in-app advertising

We are using Google Admob advertising platform to allow Us to show You personalized ads when You use the Zinny App. Google Admob is part of the advertising tools offered by Google LLC1600 Amphitheatre Parkway, Mountain View, California 94043 USA.

The following categories of personal data may be processed in connection with Our use of Google Admob services:

• IP address, which may be used to estimate the general location of a device;
• User-associated performance data such as app launch time, hang rate, or energy usage, which may be used to evaluate user behavior;
• A Device ID such as the device's advertising identifier;
• Advertising data, such as advertisements the user has seen;
• Other user product interactions like app launch taps, and interaction information.

The abovementioned personal data shall be processed for the following purposes related to the provision of the in-app advertising:

• Storing and/or accessing information on Your mobile device (as noted above, Google Admob relies on Google device advertising identifier, a resettable identifier for advertising and analytics). Additional details regarding the Google advertising ID and how you can reset it may be found here https://support.google.com/googleplay/answer/3405269;
• Create a personalized ads profile and select personalized ads (e.g. Google may use the advertising ID from the device on which the ad is serving to generate interests and demographics (for example, 'sports enthusiasts'). Interests, demographics, and other data may be used to serve better targeted ads to the user).

We will rely on Your consent on the processing of your personal data. You can withdraw your consent any time by accessing the settings available here.

Please note that the use of Google Admob services will involve the sharing of personal data to Google. Such sharing and further processing of personal data is governed by Google controller-to-controller contractual terms available here (terms which may be updated/adjusted by Google from time to time). Also, as independent controller and owner of the entire Google IT ecosystem, Google may further process personal data in accordance with its practices and terms. For additional details regarding Google data processing practices, please see https://policies.google.com/technologies/partner-sites?hl=en-US.

Also, as part of Our use of Google Admob services, We may share certain personal data to certain partners helping Us to measure and serve ads on Zinny App when ads inventory is sold via programmatic channels. The list of such partners including details with regards to their privacy policies is available .

C.9. Integration with social networks

You may choose to have Personal Information and other content about You available from Zinny, including Your location and submitted network information, transmitted to and shared through Your social network account.

The social network's use of information made available by Zinny is governed by that social network's privacy policy and controlled by the social network, not by this Policy or Zinny.

C.10.Fulfilment of legal obligations and defense of any legal interest / rights / claims in relation with official competent bodies

We may process Your data in view of meeting Our specific legal obligations (such as tax related obligations, obligation to disclose Your data upon a competent authority’s request) or to defend Our legal interests, rights, claims in relation with official competent bodies. We will do such based on Our legitimate interest to obtain the satisfaction of our interest / rights / claims deriving from or in connection with the contractual relationship with You or to defend ourselves where You would initiate legal proceedings against Us and Our legal obligation to keep/disclose specific data.

D. To whom We disclose Your Personal Information

We may disclose Your Personal Information to:

• providers of the operation system platforms for Your device, or other third-party operators providing application distribution platforms. This includes Apple or Google;
• providers of app analytics services, as described in the Analytics Tools section;
• Our proxies helping Us manage the applications or offering Us data storage services;
• public authorities, as provided by law (e.g. when the laws require the disclosure or when We have a legitimate interest to make the disclosure);
• potential acquirers of Our business or of Zinny App, or to any other acquirer, when Future Decoded or its affiliates may be subject to an acquisition and/or restructuring process.
• providers of in-app advertising services (including Google and other vendors involved in the management of the ads services via Google Admob);
• Your proxies, where they request information in connection with You, based on the mandate You granted to them;
• providers of consultancy services such as accountants, legal advisors, financial advisors.

E. Transfer of Personal Information abroad

All Our data, including Personal Information is stored in the EU.

However, some of Our partners have servers based in third countries and, therefore, Your data may be transferred to such third countries. In such cases, We will make sure that the personal data will be transferred under adequate guarantees (i.e. by using Standard Contractual Clauses adopted by the competent authority, certification procedures, such as Privacy Shield for USA entities) or, in any other case, in observance of the requirements of the data protection legislation.

Our partners to which We transfer the personal data, and whose servers are based in third States are:

• Google LLC1600 Amphitheatre Parkway, Mountain View, California 94043 USA (a provider of cookies and similar technologies analysis services) – the data can be transferred to US based servers and other servers based in third States. The associated guarantees for the data transfer: Standard contractual clauses;
• Trustlook, with the headquarter at 97 E Brokaw Rd, Suite 100, San Jose, CA 95112, USA - the data can be transferred to US based servers and other servers based in third States. The associated guarantees for the data transfer: Standard contractual clauses;

The list of Our partners to which We transfer personal data may change from time to time. You can request Us to provide You with a complete list of the States outside the European Economic Area, where Your personal data may be transferred, as well as details regarding the measures adopted for such transfers, by using the contact details provided in this document.

F. Data retention

Future Decoded will retain Your data (including Personal Information) for as long as it is necessary in order to achieve the purposes for which they were collected, in observance of the internal procedures on data retention, including the applicable archiving rules. Please find below a few rules used by Future Decoded in determining the data retention periods:

• generally, the Personal Information of users of Zinny app are retained for as long as they have an active user account on the app;
• the Personal Information of the persons registered in Our marketing database will be retained until such data subjects exercise their right to withdraw consent / respectively their right to object;
• the data related to the analytics technologies will be retained according to the specific periods set for such technologies, with a storage period which may range between the period of the app usage session and a period of up to 3 years. The data related to Your mobile services resources and data collected from Your device used for profiling purposes will be kept for a period of up to 2 years after which it will be anonymized;

Exceptionally, Your data may be stored for longer periods where such is necessary in the context of a litigation, the law provides for a specific time lapse in respect to the possibility of Future Decoded to defend its rights/interests by using Your data, or the law provides for Our direct/indirect obligation to keep Your data for a longer period of time.

G. Children privacy

Our Services are intended for general audiences. We do not knowingly collect or otherwise process any personal information of children. Please note that whenever You download Our App from the app platforms (such as App Store or Google Store) We do not receive any specific Personal Information allowing Us to determine or otherwise infer Your age.

Whenever We seek Your consent to process Your Personal Information (e.g. for marketing purposes), We will ask You to confirm that You are over 16 years of age.

H. Information security

Future Decoded considers information security to be a top priority. We implement systems, applications and procedures to secure Your information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, these measures are unable to provide absolute assurance. Therefore, although Future Decoded takes great efforts to protect Your data, We cannot guarantee and You cannot reasonably expect that the Zinny''s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

I. Your rights as data subject

Whenever the EU General Data Protection Regulation is applicable to You as data subject, You will have the following rights related to the processing of Your personal data carried by or on behalf of Future Decoded:

1. Right of access: You may obtain from Us the confirmation that We process Your Personal Information, as well as information on the specific nature of the processing. Such right allows You to obtain free of charge a copy of the processed Personal Information, as well as, against payment, any additional copies.
2. Right to rectification of data: You may request Us to change Your incorrect Personal Information or, as applicable, to supplement incomplete data.
3. Right to erasure: You may request the erasure of Your Personal Information where: (i) the Personal Information is no longer necessary in relation to the purposes for which We collected and process it; (ii) You withdrew consent for the Personal Information processing and We have no other legal grounds for the processing; (iii) the Personal Information is unlawfully processed; respectively (iv) the Personal Information have to be erased according to the relevant legislation.
4. Right to object and to withdraw consent: You can withdraw at any time Your consent for the Personal Information processing based on consent, without this affecting in any way the processing carried out prior to the withdrawal of consent. You may object at any time to the processing of Personal Information for marketing purposes, without providing any justification, as well as to other data processing in reliance on Our legitimate interest, for reasons related to Your specific situation.
5. Right to restriction: You may request the restriction of Your Personal Information processing if: (i) You contest the accuracy of the Personal Information, for a period enabling Us to verify the accuracy of the Personal Information at issue; (ii) the processing is unlawful and You oppose the erasure of the Personal Information and request the restriction of such use instead; (iii) We no longer need the Personal Information for the purposes of the processing, but such Information is required by You for a legal claim; respectively (iv) if You have objected to processing, pending the verification whether Our legitimate interests as controller override Your rights as data subject.
6. Right to portability: You may request Us, as provided by law, to provide You with the Personal Information that You provided to Us in a structured, commonly used and machine-readable format. Also, if You expressly request Us, We may transmit Your Personal Information to another entity, where technically feasible.
7. Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with the supervisory authority for personal data processing of the EU Member State of Your habitual residence.

To exercise the rights mentioned under items a) - f) above, You can contact Us at the contact details mentioned above in this Privacy Policy.

Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services, as well as push notifications. You can change Your settings on Your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if You do that, certain Services provided through the Zinny app may lose full functionality.

J. Changes to this Privacy Policy

Future Decoded may from time to time change the terms of this policy. Substantial changes will take effect 30 days after Future Decoded has posted an initial notification on the Website''s homepage or any other relevant web pages. Other changes will take effect 7 days after their initial posting on the Website. However, if Future Decoded amends this policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.

You agree to be bound by any of the changes made in the terms of this policy. Continuing to use the Services will indicate Your acceptance of the amended terms. If You do not agree with any of the amended terms, You must avoid any further use of the Services.

K. ANALYTIC TOOLS

We use analytics tools (such as libraries, APIs, etc.) to monitor how Our Services are used to ensure performance and improve Our activity and Services.

Analyses and assessments are made in an aggregate manner, using data such as: users’ purchases, the type of operating system, the aggregate number of application users per zones / intervals of time, events, interactions with our Services and application errors.

We use the Firebase services from Google LLC. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) with a view to implement and operate the Zinny app. Firebase is part of the Google Cloud Platform and offers numerous services for developers. A list can be found here: https://firebase.google.com/terms/.

K.1. Analytics

Google Analytics and Facebook analytics helps Us understand how people use Our app. The SDK automatically captures a number of events and user properties and also allows Us to measure and analyse how You interacted with the Zinny app.

Please see below a few examples of data collected via:

Google Analytics for Firebase

Instance IDs - Instance IDs identify individual installations of the app. Since each Instance ID is unique to a particular app and device, they give Firebase services a way to refer to specific app instances. Country/Region Timestamp for all events Events data such as (app install / remove, open, update, use data) Device Model Name and operating system

How it helps: Google Analytics uses the data to provide analytics and attribution information. The precise information collected can vary by the device and environment. For more information see Data collection. Retention: Google Analytics retains certain advertising identifier associated data (e.g., Apple’s Identifier for Advertisers and Identifier for Vendors, Android’s Advertising ID) for 60 days, and retains aggregate reporting and certain user-level campaign data without automatic expiration.

For Analytics for Firebase, Google does not only use the "Instance ID" described above, but also the advertising ID of the device. You can restrict the use of the advertising ID in the device settings of Your mobile device.

The antivirus solution is offered in partnership with Trustlook, with the headquarter at 97 E Brokaw Rd, Suite 100, San Jose, CA 95112, USA. For more details, please consult https://www.trustlook.com/privacy-policy

K.2. LEGAL BASIS:

Considering the aforementioned method and purpose for which We use the data collected, We deem that We can process Your personal data in reliance on Our legitimate interest without such interest overriding Your fundamental rights and interests which could be affected by the data processing.

For additional details on Our relationship with Google in connection with Firebase services please see https://firebase.google.com/support/privacy