December 26, 2021.
At Vibio Ltd., we know privacy and security is important to you.
This Privacy Notice describes our privacy and data practices on the Vibio™ application (the “Vibio app”). The Vibio app is owned and operated by Vibio, and we can be contacted at the contact information set out below.
Collection and Use of Information
You can use Vibio® products without the Vibio app. No information related to your use of Vibio products is collected from you if you don’t install and use the app.
We only collect the strictly necessary data, and all of the data collected is anonymized. Each user has a randomly generated identification number that helps us distinguish them, for example “5f1193aa3269f723a11a9aab”.
We collect and use information in our AWS servers for the purposes identified below.
Setting up the account
We store your email address to ensure your account is password protected and nobody can read your messages, and to help restore the password. Email addresses are kept separate from operation of the device and not included in any record used for communication between devices or client to server.
We do not require a real name, so users can opt for a nickname or alias. We give users the option to disclose their gender to better tailor their in-app content, but it’s not mandatory.
We request a year of birth to verify the users are over 18 years old.
To prevent automated abuse (such as data-scraping) we limit the users ability to execute queries (login attempts, user search, etc) to 15 attempts per day.
Pairing Vibio and Partner Control feature
To access and use certain Vibio product features, the Vibio app must be installed on an iOS or Android enabled device and paired with a Vibio product.
We collect and save the device model of the user and if the user owns a Vibio product. We also receive information when the user connects a Vibio product to help us understand whether a user can initiate ‘Invite to Play’.
Using the Vibio app
We only collect the required data for the Vibio app to function on your device. This data includes the type of device hardware and operating system and the date and time the Vibio app accesses our servers. We never collect you or your partner’s IP address.
We use a randomly generated token to enable push notifications to facilitate the exchange of messages between you and your partner.
We will also store any avatar or graphic image a user decides to upload to their profile.
Anonymous App Data
The Vibio app is connected to Firebase as a dependency for push notifications, but we do not use it for analytics. We don’t use third-party service providers to collect any analytical information regarding metadata or app usage.
When you contact us at email@example.com outside the Vibio app we collect your name and email address to communicate with you and respond to your comment, question or complaint. We also collect certain technical information about your device to help us provide you with support including the operating system and version and type of device hardware you are using to access the Vibio app. We may retain this information to assist you in the future and to improve our customer service. This data is collected outside of the Vibio app and is not associated with an individual Vibio app user.
Sharing and Transfers of Information
We do not sell or share information relating to the use of the Vibio app with third parties, except in the event it may be required by law or legal process.
We use service providers to facilitate the exchange of messages and vibration controls when using the Partner Control feature of the Vibio app.
We, and the service providers with whom we share information (as set out above), may transfer to and store information in the United States and other destinations outside of the European Economic Area (“EEA”). By using the Vibio app, you acknowledge that certain information described in this Privacy Notice will be collected, stored, processed and transferred in and to the United States or other foreign jurisdictions, pursuant to the laws of the United States or such other foreign jurisdictions, and may be disclosed to or accessed by the courts, law enforcement, and governmental authorities in accordance with those laws.
While the United States and other jurisdictions may not offer the same level of privacy protection as your own country, we commit to uphold the privacy protections as explained in this Privacy Notice. We take steps to comply with applicable legal requirements providing an appropriate level of protection for the transfer of information to countries outside the EEA, and ensure that recipients of your information are bound to duties of confidentiality.
Safeguarding and Retention of Personal Information
We have implemented administrative, technical and physical measures designed to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modiﬁcation and disclosure.
We restrict access to information on a need-to-know basis to employees and authorized service providers who require access to fulﬁll their job requirements.
We have information retention processes designed to ensure that we will retain your personal information only for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable statutes of limitations, legal requirements and the duration of your use of the Vibio app.
Users from the European Union
This section of the Privacy Notice applies only if you use the Vibio app from a country that is a Member State of the European Union and supplements the information in this Privacy Notice. Vibio Ltd. is the data controller for processing of information defined as personal data under applicable data protection law (“Personal Data”).
Legal Basis for Processing Personal Data
We process Personal Data for the purposes set out in this Privacy Notice, as described above. Our legal basis to process Personal Data includes processing that is: necessary for the performance of the contract between you and Vibio Ltd. (for example, to provide you service through the Vibio app); necessary to comply with legal requirements (for example, to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you); and based on your consent (for example, to connect to your partner through the Partner Control feature), which may subsequently be withdrawn at any time (by contacting us at the email address below) without affecting the lawfulness of processing based on consent before its withdrawal.
In some instances, you may be required to provide us with Personal Data for processing, as described above, in order for us to be able to provide you all of our services, and for you to use all the features of the Vibio app.
Subject to applicable law, you have certain rights with respect to the processing of your Personal Data. You may be entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. Requests should be submitted by contacting the email or mailing address below.
If you are aware of changes or inaccuracies in your Personal Data, you should inform us of such changes so that our records may be updated or corrected. If you consider that our processing of your Personal Data infringes applicable law, you may lodge a complaint with a competent supervisory authority, which may be the authority in your jurisdiction of residence or work.
Updates to the Privacy Notice
We may update this Privacy Notice to reflect changes to our privacy and data practices. You should check this notice occasionally to ensure you are familiar with those changes. If the changes made to the Privacy Notice are material, we will also post a notice on the Vibio app prior to the effective date of the change.
We welcome your comments and questions regarding this Privacy Notice. If you have questions or concerns, please contact our team at firstname.lastname@example.org.