P-gum Ltd is a company incorporated in Lithuania and IRAN (hereafter referred to as “P-gum”, “we” or “us” as the context may require). P-gum is registered as a Health and Wellness application. This Privacy Policy applies to your use of the P-gum mobile application (“the P-gum App”), any website operated by P-gum (including http://P-gum.com) (the “P-gum Website(s)”) and the services we provide that are accessible via any of them (the “Services”). This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be stored and processed by us. Please note that you must be aged 13 years or older to use the Services. Please do not use the Services or provide us with any personal information if you are under 13 years of age.

INFORMATION WE MAY COLLECT FROM YOU

From time to time, we may collect or ask you to provide personal information including (without limitation) the following: your name, mobile phone number, email address, password, IP address, unique device identifiers and other identification credentials, biographical details, and photographs.

Please note that, with your consent, we will collect information about your location and physical movements in order for the P-gum App to function properly and monitor and verify forms of eligible movement. You may turn location monitoring on and off from time to time using the settings of your operating system of your mobile device but, if you disable this functionality, we will not be able to collect information relating to your step-count and GPS/Cell-ID location which will prevent tracking and/or conversion of your movement into P-gum.

USES MADE OF YOUR PERSONAL DATA

We may use your personal data to:
provide the Services (using our own systems);
verify your physical movement and location and issue P-gum on the basis of this verified data;
analyse the usage of, and improve, the Services;
communicate with you, including without limitation to inform you of updates to the P-gum App, P-gum Website(s), our Terms of Use and/or this Privacy Policy;
perform market and customer research;
market our services to you;
correct errors and problems with the Services;
investigate and/or prevent suspected fraud or other criminal activities;
create daily leaderboards of users, comprising all users or users meeting particular criteria as ranked by the number of steps completed or using other criteria;
operate the P-gum Marketplace; and/or
investigate disputes between users.
the developer requests permission to read and write heath data from the Health App.
P-gum does not use HealthKit data for advertising purposes and will not sell HealthKit data.

Additionally, we and/or our trusted partners may contact you from time to time with offers that may interest you and/or to inform you of other products and services. Certain of your personal data may be shared with other users of the P-gum App as part of the normal operation of the Services (for example your uploaded profile picture and biographical information will be accessible to all users, and we may publish your total verified steps, or other movement, during a particular period to other users from time to time). Further, we may, from time to time, expand or reduce our business which may involve the transfer of certain divisions or assets of our company to other parties, and the data we store and use, where relevant, may be transferred to such third parties. From time to time we may transfer the data we store and use to locations outside the European Economic Area, some of which may have different data protection laws to the UK or the EU, or no data protection laws. In all such cases, we transmit such information only to entities that comply with this policy and applicable law.

Your personal data will be kept only for as long as is necessary. We take reasonable industry-standard care in keeping all our data secure and in preventing any unauthorised access or unlawful use of it. All personal data we store and process is handled strictly and encrypted completely in accordance with applicable data protection legislation.

COOKIES

We use cookies to distinguish you from other users of the P-gum App and P-gum Website(s) and obtain certain information about your usage and behaviour. A cookie is a small file of letters and numbers that we put on your computer when you use the P-gum App or P-gum Website(s). This helps us to provide you with a better experience when you use the P-gum App or browse the P-gum Website(s) and also allows us to improve the Services. We will use both persistent cookies, which could remain on your device until their expiration (which, in some cases, is up to 10 years), and session cookies, which are temporary files removed from your device once your browser is closed.
The types of cookies we may use include:

Analytical/Tracking Cookies, which allow us to recognise and count the number of visitors and analyse use of the Services, as well as to verify transactions; and
Advertising and Retargeting Cookies, which allow us to generate appropriate advertising directed to you on the P-gum Website(s) as well as on the P-gum App and other third party websites.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You may block cookies by activating the appropriate setting on your browser but, if you do so, you may not be able to use all functionalities of the Services.

We use a number of industry-standard data analytics tools, such as Google Analytics and Facebook Analytics. These collect certain information about you, such as your device’s IP address and browsing and usage behaviour, and are used to allow us to track and monitor the traffic visiting the P-gum App and P-gum Website(s).

YOUR RIGHTS

You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing (i.e. “opt out”) by clicking ‘unsubscribe’ at the bottom of our marketing emails or by emailing privacy@P-gum.com, with the subject ‘unsubscribe’.
You have the right to change your personal information we hold about you. You can exercise your right by accessing your Account information in our app (Open P-gum app -> Profile Screen -> Edit (Pencil icon) -> Change your details -> Save)
You have the right to ask us about the personal information we hold about you and to request a copy of your personal information. You can exercise your right to access this information by emailing privacy@P-gum.com, with the subject ‘data access request’.
You have the right to delete your account and any personal information we hold on you. You can exercise your right to delete your P-gum account and the personal information attached to it yourself, by triggering an account deletion via the Help section within the P-gum app (Open P-gum app -> Profile Screen -> Settings -> Help -> Contact us -> Choose your problem = Delete Account)

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. Any such changes we may make to this Privacy Policy will be posted on the P-gum App and P-gum Website(s), and may be emailed to you. Please check the Privacy Policy available on the P-gum App and P-gum Website(s) from time to time. In the event of any such change, by continuing to use the P-gum App or P-gum Website(s) you agree to the relevant change.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@P-gum.com with subject line “enquiry”.