Privacy Policy

I. Introduction

Device Finder (“Device Finder,” “Us,” “We”) values your privacy and is committed to protecting your personal data ("Data").

This privacy policy (the “Policy”) explains how we collect, process, store, share, and protect the Data you provide to Us or that we collect when you use our website (“Website”), fill out our questionnaires (“Questionnaires”), use our application (“Application”), and our well-being coaching services (our “Services”) or any other features operated by Device Finder.

We reserve the right to modify this Policy at any time at our sole discretion. If changes are made, they will be published on the welcome page of the Website and/or the homepage of the Application. Changes will take effect thirty (30) days after publication. Continued use of our Services will signify acceptance of the changes.

II. Data Collection

We collect the following data when you use the Application and our Services:

Information such as Bluetooth and Wi-Fi configurations, and a list of Bluetooth networks (connection names).

III. Data Processing Purposes and Legal Basis

We process your Data to fulfill our contract with you and provide our Services, including the following purposes:

Personalizing user experience
Improving our Application
Managing technical and customer support to assist with issues such as account management

We also process your Data for the following purposes:

Participating in investigations and proceedings by public authorities or government agencies, especially for detecting, investigating, and prosecuting illegal acts
Preventing, detecting, and mitigating illegal activities (e.g., fraud, money laundering, terrorist financing)
Complying with information requests from third parties based on statutory information rights (e.g., intellectual property infringement, product piracy, other unlawful activities)
Ensuring the security of our Services
Retaining and storing Data to comply with specific legal retention requirements

Additionally, we process your Data where necessary for our legitimate interests, including improving our Application and Services by monitoring usage to enhance user satisfaction.

With your consent, we process your Data for:

Personalizing, measuring, and improving our advertisements

We may also de-identify, aggregate, and/or anonymize your Data for various business purposes, including product, service, and program development and improvement. De-identified data, in individual or aggregated form, may be used for research purposes both internally and with research partners and other third parties to advance clinical and scientific knowledge.

IV. Cookies and Similar Technologies

Cookies are small files commonly used as anonymous unique identifiers. They are sent to your browser from the websites you visit and stored on your device's internal memory.

Our Service does not explicitly use cookies. However, third-party code and libraries used by the app may employ cookies to collect information and improve their Services. You can choose to accept or refuse these cookies. If you refuse cookies, some portions of the Service may be unusable.

V. Data Storage

We (via our service providers) store your Data on storage facilities located in the European Union for European users. Data is stored only as long as necessary for the purposes for which it was collected and processed, and always in accordance with legal requirements.

Your Data will be stored in our active database for the duration necessary to provide the Services and will be irreversibly deleted, anonymized, or archived in an intermediate database with limited access upon the termination of your subscription. Contact data will be retained for three years to send you promotional communications upon your consent.

If legally required, your Data will be archived in an intermediate database with limited access for compliance, establishing evidence of our rights or contract, or for tax, accounting, or auditing purposes. The duration of storage will depend on statutory limitation or retention periods and will be deleted after these periods expire.

VI. Data Transfer Outside the European Union

Some of our service providers and employees are located outside the European Union, in countries where data protection laws may differ. When transferring Data of European users, we ensure an adequate transfer mechanism is in place. For internal services located in the United States, we rely on the EU-US Privacy Shield.

VII. Data Security

We implement industry-accepted security measures to protect your Data and limit access to it. This includes technical and organizational measures to minimize risks associated with data loss, misuse, unauthorized access, and disclosure, such as encryption technology (e.g., SSL) and physical access restrictions for our data centers.

Despite our efforts, there is always a risk of unauthorized access or interception of Data during Internet transmission. Therefore, we urge you to take precautions to protect your Data while using the Internet or the Application.

VIII. Your Rights

As a data subject, you have the following rights regarding your Data and its processing:

Right to access your Data
Right to rectify inaccurate Data
Right to erase your Data, unless processing is necessary for freedom of expression, compliance with legal obligations, public interest, or legal claims
Right to request the limitation of Data processing under certain conditions
Right to receive a copy of your Data in a structured electronic format or ask for its transfer to another controller
Right to object to Data processing for profiling or marketing purposes and to withdraw consent at any time

You can exercise your rights by sending a clear and specific request by email to powellelliot51@gmail.com. Requests will be handled within a reasonable time, subject to our legal obligations and the limits of your rights.

IX. Protection of Children

We are committed to protecting children's privacy. Our Website, Application, and Services are not intended for children, and we do not knowingly collect data from users under 18 years old.

Users must confirm they are 18 or over during subscription. If under 18, we require parental consent before authorizing access. We do not collect Data from children under 13 years old.

For users under 18, we may limit data collection, use, and storage, restricting access to certain challenges.

We share your Data with our internal service employees (e.g., IT, development, marketing) to provide Services and enhance user experience.

We also share your Data with third-party service providers who host data, manage subscriptions, send promotional communications, detect illegal activity, and compile aggregate statistics. These providers must adhere to our Privacy Policy and comply with data protection obligations.

Data may be shared with other users or partners, with your consent, for offers on products and services. We may also share Data with employers if using the Application and Services through Device Finder.

We may disclose Data to competent authorities to exercise legal rights or comply with laws or court decisions. We are not obligated to notify you of such disclosures unless required by law.

XI. Third-Party Links

Our Website and Application may contain third-party links or content. We are not responsible for how these third parties collect or use your Data and do not guarantee compliance with our data protection practices. We encourage you to read the privacy policies of every third-party website, application, and service you visit or use, including those you interact with through our Services.

Additionally, we may rely on third-party advertisers, ad networks, and ad servers to promote our App. This includes platforms like Facebook, Twitter, or Google. These third parties may use cookies alone or with web beacons or other tracking technologies to collect information about user behavior on our App and other Apps for interest-based advertising. No information you share within our Application will be shared with third-party advertisers. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.