Owner and data controller

Email address for contact:hallo@fitr.nl

Types of Data collected

Among the types of Data that this Application collects, by itself or through third parties, there are: Trackers; Usage Data; city; Postal code; state; province; country; province; latitude (of place); longitude (of place); metropolitan area; geographic area; IP address; device data; app data; device registers; operating systems; browser information; language; app opens; number of sessions; session duration; scroll-to-page interactions; mouse movements; scroll position; keyboard events; motion sensor events; touch events; data about viewed videos; clicks; browsing history; search history; session statistics; page views; interaction events; page events; custom events; Application opens; order ID; email address; user subscriptions; gender; unique device identification for advertising (Google Advertiser ID or IDFA, for example); number of Users; last date an email was sent; date of the message; time the message was sent; sender of the message.

Complete information on each type of Personal Data collected is provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services.In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact Fitr.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Methods and place of processing the Data

Processing method

Fitr takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Fitr, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Fitr. The updated list of these parties may be requested from Fitr at any time.

Location

The Data is processed at Fitr's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to an applicable legal obligation or based on the Users' consent.

The purposes of processing

The Data concerning the User is collected to allow Fitr to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect malicious or fraudulent activity, and for the following purposes: Analytics, SPAM protection and bot management, Platform services and hosting, Managing contacts and sending messages, and Traffic optimization and distribution.

For specific information about the Personal Data used for each purpose, the User may refer to the section "Detailed information on the processing of Personal Data".

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Information about opting out of interest-based advertising

In addition to the opt-out options provided by the services listed in this document, Users can find information about how to opt out of interest-based advertising in general in the corresponding section of the Cookie Policy.

Further information for Users

Legal basis of processing

In any case, Fitr will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to an applicable legal obligation or based on the Users' consent.

Fitr may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Fitr may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users

Users may exercise certain rights regarding their Data processed by Fitr.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Fitr to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Fitr or for the purposes of the legitimate interests pursued by Fitr, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. Users can learn whether Fitr is processing Personal Data for direct marketing purposes in the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to Fitr through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Fitr as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by Fitr to each recipient to whom the Personal Data has been disclosed, if this proves impossible or involves disproportionate effort. At the Users' request, Fitr will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by Fitr in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that Fitr may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

Fitr may request Users to provide additional information, such as a photo, to better identify the User or to contact the User.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from Fitr at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

Fitr reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to Fitr. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User's consent, Fitr shall collect new consent from the User, where required.

Cookie Policy

This document informs Users about the technologies that help this Application to achieve the purposes described below. Such technologies allow Fitr to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User's device as they interact with this Application.

For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate. For instance, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
For instance, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

This Application uses Trackers managed directly by Fitr (so-called "first-party" Trackers) and Trackers that enable services provided by a third-party (so-called "third-party" Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of "first-party" Cookies and other similar Trackers may vary depending on the lifetime set by Fitr. Some of them expire upon termination of the User's browsing session.
In addition to what's specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information - such as the presence of other Trackers - in the linked privacy policies of the respective third-party providers or by contacting Fitr.

Activities strictly necessary for the operation of this Application

This Application uses so-called "technical" Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

Third-party Trackers

Other activities involving trackers

This Application uses Trackers to measure visits and analyze User behavior to improve the Service.

Measurements

Marketing

This Application uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.

How to manage preferences and provide or withdraw consent

There are various ways to manage Tracker preferences and to provide and withdraw consent, where relevant:

Users can manage preferences related to Trackers directly from within their own device settings, for example, by preventing the use of or deleting Trackers.

Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences privacy widget, if available.

It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User's initial consent preferences.

Other Trackers in the browser's local memory may be cleared by deleting the browsing history.

With regard to third-party Trackers, Users can manage their preferences via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.

Locating Tracker Settings

Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users can open the device settings and look for the relevant setting).

How to opt out of interest-based advertising

Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices(EU and UK), the Network Advertising Initiative(US) and the Digital Advertising Alliance(VS), DAAC(Canada), DDAI(Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. Fitr thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices which helps Users to control interest-based advertising on mobile applications.

Consequences of refusing Trackers

Users are free to decide whether or not to allow Trackers. However, please note that Trackers help this Application to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, if the User chooses to block the use of Trackers, Fitr may be unable to provide related features.