Sky Gauge Privacy Policy

Last updated: August 4, 2023

At Appogeum, protecting your personal data is our priority.

When you use the application Sky Gauge (hereinafter the "Application"), the application Flow, our web applications and websites, we may collect personal data about you.

The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").

1. Who is the data controller?

The data controller is Appogeum Limited, address: The Hallmark Building, Suite 227, Old Airport Road, The Valley, Anguilla (hereinafter “Us” or “We”).

2. What personal data we collect?

Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

We may collect the following personal data:

  • Identification data (e.g. first name, surname, email and postal addresses);
  • Data relating to your preferences on the Application (e.g. your choices of towns, choices of temperature unit, main activity, type of notification);
  • Login data (e.g. IP address, date of connection, “in-app” events);
  • Location data (e.g. your GPS position, speed and altitude);
  • Data related to air quality measurements (e.g. N02, COV, PM);
  • Data related atmospheric measurements (e.g. temperature and relative humidity);

Please note that if you consent to the processing of your location data in order to calculate your exposure to pollution, through our Application, we will collect and process your precise location within a street.

All this personal information is carefully protected and used exclusively for the purpose for which it was originally shared with us.

3. On what legal basis, for what purposes and for how long do we keep your personal data?

Purpose 1: To manage your access to our applications and your use of our services

  • Legal basis

Performance of a contract to which you are party and taking steps at your request prior to entering into a contract with Us.

  • Data retention period

Your personal data are retained for a period of 2 years started from your last activity from your account. Location data, measurements and sensor data are archived after 6 months from inactivity of the account. Your data will be deleted if you request it.

Purpose 2: To create a database of registered members, users, customers and prospects

  • Legal basis

Our legitimate interest in developing and promoting our business

  • Data retention period

For our customers: personal data are retained for the duration of contractual relationship, and then for 3 years for prospecting purposes. For our prospects: personal data are retained for a period of 3 years starting from the last contact with Us for prospecting purposes.

Purpose 3: To send newsletters, requests and direct marketing mailings

  • Legal basis

For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news For our prospects: your consent

  • Data retention period

Newsletters: Personal data are retained for 1 year after the last account activity or until you withdraw your consent. You can unsubscribe at any time with the link at the bottom of the newsletter. Requests and promotional messages: Personal data are retained for 1 years from the last contact with Us or until you withdraw your consent.

Purpose 4: To elaborate commercial and audience statistics of our services

  • Legal basis

Our legitimate interest in analyzing the composition of our customer base and improving our services

  • Data retention period

Personal data are retained for the time needed to draw up statistics, for a maximum period of 6 months from the date of the data collection.

Purpose 5: To manage your opinions and comments about our products, services or content

  • Legal basis

Our legitimate interest in knowing the opinions of our customer base in order to improve our services

  • Data retention period

Data are retained for 2 years from the filing of the opinion.

Purpose 6: To personalise our answers to your information requests

  • Legal basis

Our legitimate interest in responding to your inquiries

  • Data retention period: Personal data are retained for 2 years from the last contact with Us.

Purpose 7: To comply with our legal and regulatory obligations

  • Legal basis

To comply with our legal and regulatory obligations

  • Data retention period

For invoices: invoices are archived for a period of 10 years.The data relating to your transactions (but not your banking data) are retained for a period of 5 years.

Purpose 8: To process data subjects’ requests to exercise their rights

  • Legal basis

Our legitimate interest in responding to your requests and keeping records of them

  • Data retention period

If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted.If you exercise your right to object to direct marketing: we keep this information for 3 years.

4. Who are the recipients of your personal data?

Will have access to your personal data:

  • The staff of our company who need to have access to this data in the course of their duties
  • Our processors: hosting provider, mailing provider, statistic tool, authentication and account security management tool, solutions for online sales of Flow sensors;
  • Our partners: logistic partners of order management and delivery;
  • Some of our partners in the context of studies for which there is a contractual relationship between you and the partner;
  • If applicable: public and private organisations, exclusively to comply with our legal obligations.

5. What rights do you have regarding your personal data?

You have the following rights with regard to your personal data:

  • Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.
  • Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.
  • Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.
  • Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.
  • Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.
  • Right to file a complaint to a competent supervisory authority, under GDPR article 77, if you consider that the processing of your personal data constitutes a breach of applicable regulations.
  • Right to define instructions related to the retention, deletion and communication of your personal data after your death (article 40-1 of French law “informatique et libertés”).
  • Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal
  • Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
  • Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing us through the contact details listed below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

6. Contact information for data privacy matters

Contact email: info@appogeum.dev

7. Modifications

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

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email us: info@appogeum.dev