PRIVACY POLICY
Bestys Mobile Ltd. (together with our affiliates and subsidiaries, including BESTYS Ltd., and any future affiliates or subsidiaries) (“Bestys”, “we”, “us” and terms of similar meaning) adopted this privacy policy (“Privacy Policy”) to reflect our commitment to protecting your privacy. We take the collection of personal information from our end-users seriously and we are committed to protecting each user’s privacy in accordance with the applicable regulations.
The Privacy Policy is an integral part of the Terms of Service (the “Terms”) which are available on our mobile application “Bestys File Converter”. All capitalized terms have the meaning given to them in the Terms, unless otherwise stated herein.
PERSONAL DATA
What is Personal Data
Personal Data is any information that relates to an identified or an identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.
Personal Data We May Collect
We use the below information in order to provide you the App’s main functionalities:
Information directly related to your usage of the App. In order to use our App, you will need to give us access to your storage to read the contents of your memory card and modify or delete content.
Note that we do not collect, store or use the data contained in your storage. All files that might be processed through the App are stored locally on your device and/or in your iCloud storage, they are inaccessible to us. Only you can share files to certain party by exporting them through the App.
Payment Information. When you authorize payment of a purchase (for a subscription or anything other) using Apple Pay or Google Play billing service, both of the latter may provide us information for identification such as a device-specific account number, your shipping address, or email address. The card number from your credit, debit, or prepaid card is not provided to us when you use Apple Pay or Google.
Contact Information. If you decide to contact us you might be required to provide to us any of the following information:
● Name
● E-mail address
● Phone number
● Other information that you may decide to provide to us when contacting us.
We use the above three categories of information on the grounds of performing our contractual obligations.
Information that we collect from third parties or is automatically collected
When you use the App, some information about your device and your user behavior may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data we may not be able to provide you with all the features of the App.
We use third-party automatic data processing technologies to analyze certain information sent by your device via our App (advertising or analytics tools). Some of them launch automated processing of your Personal Data, including profiling, which means any form of automated processing of Personal Data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements. Processing information through automatic data processing technologies starts automatically when you first time launch the App.
Links to the privacy policies of third-party service providers used by the Application:
AppsFlyer
Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (e.g. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties.
FOR WHAT PURPOSES WE USE YOUR PERSONAL DATA AND ON WHAT GROUNDS
To the extent permitted by applicable law, we may use Personal Data:
● providing our Services to your benefit, including providing support and answering your questions about our Services and the Application.
The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between Bestys and you. Additionally, the implementation of these purposes requires processing under applicable law, including tax and accounting legislation.
● to respond to your inquiries
● improving our Services
We would always like to offer you the best experience using our Services. For this purpose, we can use certain information about your user behavior, invite you to fill in satisfaction surveys after using our App, or with partners, market research, and other research, and send you educational emails. Educational emails contain instructions, tips or, perhaps, information about the advanced features of the Application. The purpose of these communications is to streamline end-user work in the Application. Educational emails never include marketing messages.
We base these activities on our legitimate business interests by always ensuring that your fundamental rights and freedoms are unaffected.
● for direct marketing
We require your prior consent to send you different marketing messages, e. g. newsletters, commercial messages. You can change your mind and withdraw your consent at any time by:
- Using the "Unsubscribe" link in the messages you receive from us; or by
- contacting us using the contact details below.
● participation in competitions and different promotions
We might organize different competitions and promotions. If you decide to participate in such an event, then we will process your Personal Data for conducting it. If you don’t want your Personal Data to be processed for such reasons, you should not participate in such events.
● protecting our legitimate interests
There may be cases in which we use or transmit information to protect our rights and our commercial activities. These may include:
- measures to protect the Application and the users of the Application against cyber-attacks;
- measures to prevent and detect attempts at fraud, including the transmission of information to competent public authorities;
- measures to manage various other risks.
The main reason for these types of processing is our legitimate interest in protecting our business by making sure that we ensure that all the measures we undertake ensure a balance between our interests and your fundamental rights and freedoms.
In addition, in some cases, our processing is based on legal provisions such as the obligation to protect the goods and the values provided by the applicable legislation in this respect.
● to provide you with interest-based (behavioral) advertising or other targeted content.
We may use the information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.
FOR HOW LONG WE STORE YOUR PERSONAL DATA
As a rule, we store your Personal Data while you use the Application. You may always ask us to delete certain information or to close your account and we will respond to this request by retaining certain information, even after the account is closed when the applicable law or legitimate interests impose it. Personal Data, collected for contact purposes only is stored until completion of the communication, unless otherwise required by law.
SENSITIVE INFORMATION
We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the App or otherwise to us.
HOW PERSONAL DATA MAY BE DISCLOSED
To the extent permitted by applicable law, your Personal Data may be disclosed:
● to our third-party service providers who provide services such as website hosting, data analysis, infrastructure provision, IT services, email delivery services and other services, to enable them to provide their services;
● to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
● as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
USER’S RIGHTS
Access to your Personal Data
You have the right to view, amend, or delete the Personal Data that we hold about you. To request access please email support@converter.bestys.com . We will provide the information free of charge and within one month, except in the event that the request is unfounded, excessive or repetitive, in which case we reserve the right to charge a proportionate administration fee or refuse.
Rectification of Personal Data
If any of the information we hold on you is inaccurate or incomplete, you may ask us to correct or complete it at any time.
Your right of erasure, or to be forgotten (for individuals within the European Economic Area (EEA) and the State of California)
You may ask us to delete your Personal Data, but only if:
- it is no longer necessary for the purposes for which it was collected; or
- you have withdrawn your consent (if the processing of the data is based solely on consent); or
- exercise a legitimate right of objection; or
- it has been unlawfully processed; or
- there is a legal obligation in this respect.
We have no obligation to honor your request for deletion of your Personal Data if processing is required:
- to fulfill a legal obligation; or
- to establish, exercise or protect a legal claim.
There are certain other circumstances in which we are not obliged to comply with your request for data deletion, even though these are the most likely circumstances in which we may decline your claim.
To request deletion of your personal information, contact support@converter.bestys.com using the email address we hold for you or otherwise proving your identity.
Please be aware that the process of deleting data and deleting the Application with all data and documents associated with it is an irreversible process.
Restrict data processing
You may ask us to restrict the processing of your Personal Data, but only if:
- its accuracy is being challenged (see Rectification of Personal Data section) to be able to verify its accuracy; or
- processing is illegal, but you do not want the data to be deleted; or
- it is no longer necessary for the purposes for which it was collected, but we still need to identify, exercise or defend a legal claim; or
- you have already exercised the right of objection and you are checking whether the dominance of our rights is still in place.
We may continue to use your Personal Data as a result of a restriction request:
- if we have your consent; or
- to establish, exercise or defend a legal claim; or
- to protect the rights of the App owner or any other person or entity.
Data portability (for individuals within the EEA)
You may ask us to provide your Personal Data in a structured, widely used and machine-readable format, or you may request that it is directly transferred to another data operator, but only if:
- the processing is based on your agreement or the conclusion of a contract with you; and
- processing is carried out automatically.
Right of objection
You may object at any time, for reasons related to your particular situation, to the processing of your Personal Data based on our legitimate interests if you believe that your fundamental rights and freedoms dominate these interests.
You may also object at any time to processing your data for direct marketing purposes by following the instructions on the email we send you or by sending an email to support@converter.bestys.com .
Making automated decisions
Bestys does not conduct profiling or automated individual decision-making.
You can ask us not to be the subject of a decision based solely on automatic processing, but only when that decision:
- has legal consequences for you; or
- affects you in a similar way and to a great extent.
This right is inapplicable if the decision taken after the automatic decision has been taken:
- is needed for execution and fulfilment of a contract with you;
- is permitted by law and there are adequate safeguards for your rights and freedoms; or
- is based on your explicit consent.
Your right to file a complaint with the Supervisory Body
If you believe that Bestys processes your Personal Data in the wrong way, you can contact support@converter.bestys.com .
You have the right to complain to your jurisdiction’s local authority on the processing of your Personal Data.
OTHER INFORMATION
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity, such as:
● Browser and device information, carrier, internet connectivity
● Server log file information and application usage logs
● In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data)
● Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analysis. Some services also record the list of applications and/or processes which are installed or run on your device.
● Information collected through cookies, pixel tags and other technologies
● Location information, demographic information and other information provided by you
● Device identifiers: Identity For Advertisers for iOs devices, user identifiers (if they are set up by the App’s developer). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.
● Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we may use and disclose Other Information for all the purposes for which we use and disclose Personal Data.
DATA SECURITY METHODS
For the purpose of securing our user’s data against their unauthorized or accidental disclosure, we utilize reasonable and appropriate technical and organizational measures. Technical measures consist in the application of technologies that prevent unauthorized access to the user’s data by third parties. For the purpose of maximum protection, we use encryption of the user’s and end users’ data, primarily including passwords for logging into the Application, communication within the Application system and all data stored on servers. Organizational measures comprise a set of rules of behavior for our employees and are incorporated into Bestys’ internal regulations, which are, however, considered confidential due to security reasons. Bestys takes to ensure that, in the event of the placement of servers at a data center operated by a third party, similar technical and organizational measures are also implemented by such third party.
All data are placed only on servers located within the European Union or in countries ensuring personal data protection in a manner equivalent to the protection ensured by the legal regulations of the Ireland.
TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATION
We do not share your personal information with third parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your personal information to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.
We store personal data on LeaseWeb servers, located within the EAA and the United States and in other countries and territories. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which Bestys has operations. Therefore, your personal information, in rare cases, may be processed outside of the EEA and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA.
In this event, we will ensure that the recipient of your personal data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.
We have implemented safeguards to ensure an adequate level of data protection where your personal data is transferred to countries outside the EEA. For further details on the transfer of your personal data, including a list of the organizations with whom said information may be shared, please reach out to our team at support@converter.bestys.com .
THIRD PARTY SITES
The Application may contain links to other websites, mobile applications, and other online services operated by third parties. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the App contain a link. The inclusion of a link on thе Application does not imply endorsement of the linked site by us.
We are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including in connection with any Personal Data you disclose to other organizations through or in connection with our social media pages.
MISCELLANEOUS
Your Use of Other Persons’ Information
By downloading, installing, accessing or using the App, you agree that, with respect to the personal information of other persons that you collect, use and disclose on the Application, you have all necessary consents and rights to collect, use and disclose that information as described in this Privacy Policy from time to time, and you agree that the indemnity you give to us in the Terms of Service applies to any non-compliance by you with the foregoing.
Residents of Canada
Personal Data (as the term is defined in the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by Bestys in compliance with Bestys obligations under PIPEDA.
California Residents
The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how we handle personal information of California residents and gives California residents certain rights with respect to their personal information.
Bestys is both a “business” and a “service provider” under the CCPA. The following supplemental privacy policy applies to information we collect in our role as a business—this is when we interact directly with you.
When we act as a service provider (for example, by providing our services to another company that you interact with), we follow the instructions of the business that engaged us with respect to how we process your personal information. If you would like more information about how your personal information is processed by other companies, including companies that engage us as a service provider, please contact those companies directly.
European Economic Area (EEA) Visitors
Personal Data (as the term is defined in the Regulation (EU) 2016/679 of the European Parliament and of the Council 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, and repealing Directive 95/46/EC (“GDPR”)) will be collected, stored, used and/or processed by Bestys in compliance with Bestys obligations under GDPR.
COOKIES POLICY
What are cookies?
Cookies are small text files that are stored on your computer or mobile device. They are widely used in order to make websites work, or work in a better, more efficient way. They can do this because websites can read and write these files, enabling them to recognize you and remember important information that will make your use of a website more convenient (for example by remembering preference settings).
What Cookies does the App use?
Currently, the App does not use cookies.
Opt-out of Marketing Tracking
If you don’t want third-party service providers to use to personalize ads on the basis of your interests, please follow these instructions:
- Choose option "Limit Ad Tracking" on your iOs device in Settings/ Privacy/ Advertising, please find additional information here: https://support.apple.com/en-us/HT202074.
- Turn On opt out of Ads Personalization on your Android device in Settings/Google/Ads
You can also visit https://youradchoices.com for the same purpose.
Please mind when you opt out of certain interest-based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.
Opt-out of Location Data Processing
If you don’t want third-party service providers to use your precise location data, or street-level location information about you please follow these instructions:
- for iOS 11 or later: turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services”. Then select the applicable App and set the “Share My Location” status to “Never”.
- For Android: turn Location Services off for the applicable Product via the menu “Settings/Location/.
DATA CONTROLLER
Where we collect Personal Data directly from the data subjects, such as our users, and make decisions in regards to processing such Personal Data, we act as the data controller. Otherwise, where we process Personal Data on behalf of third parties, we are the data processor.
Data controller information:
Bestys Mobile Ltd., a company duly incorporated under the laws of the UK and registered with the Companies House under company number 13076616, with seat and management address at: The Archive Centre Honeywood Road, Whitfield, Dover, Kent, United Kingdom, CT16 3EH
HOW TO CONTACT US
You may contact Bestys directly if you have any question regarding our privacy practices. Please send your query to support@converter.bestys.com .
CHANGES TO THIS PRIVACY POLICY
We may modify this Privacy Policy at any time. The current version of the Privacy Policy is always be available on the Application. If a significant change occurs within this policy in regard to the manners of handling personal data, Bestys will inform you by publishing a notification in a visible manner prior to the implementation of such changes. We agree that changes cannot be retroactive. We recommend checking the Privacy policy from time to time when utilizing the Bestys Solution.
Your continued use of the Application after the changes of the Privacy Policy have been announced to you, means that you are consenting to the updated terms.
Last Updated: 05/10/2021