Effective date: May 2024

This Privacy Policy describes how personal information is collected, used, and protected for users of the Ereasy App. By using this App you agree to the terms and conditions outlined in this policy.

We may update this Privacy Policy according to new legislative or jurisprudential requirements and/or business needs, among others reasons. The new version of this Privacy Policy will be applicable from the moment of its publication on the App. Therefore, the User is recommended to review this Privacy Policy regularly. This Privacy Policy will always be available on the App so that the data subjects can consult it at all times.

Who is the personal data controller? MAETCH EXPANSION, S.L. (hereinafter, the “Company”, “We”, “Us” and the like) is the controller of the User’s personal data mentioned above. We are firmly committed to regulatory compliance and the privacy and protection of personal data. Accordingly, in the present Privacy Policy, the User (hereinafter “the User”, “you”, “your”) of Ereasy (hereinafter, “the/our App”) will find all the relevant information to better understand what We do with their personal data. If you do not agree with this Policy, please do not access and use our App. 

What does this Policy apply to? This Privacy Policy applies to the personal data that We collect and process from you as a User of our App as well as the services offered within it. Please bear in mind that this App is for adults in accordance with the laws and regulations of their birth or residence country. 

What does personal data mean and which data do We collect and process? For the purposes of this Policy, "personal data" refers to all data that identifies you or that could be used to identify you, such as:  

• Your User ID by using RevenueCat. For further information, please consult RevenueCat’s privacy policy;

• E-mail addresses, when you contact us directly.

• Debit/credit card associated with the Apple/Google Play user account and Apple/Google Play gift cards.

• Information about your IOS/Android device when you have provided your consent to these platforms to communicate this data to third party partners who develop apps offered through the platforms.

The App may use your personal information to enable you to access and use the App as well as to enhance the quality and functionality of the App. For this purpose, the App may collect information about how you navigate in the App, in order to improve the Users’ experience.

Likewise, the User will be prompted with a pop-up requesting your consent to access your camera roll, in accordance with Apple/Google Play policies, to save the edited image to the User’s device, if applicable. The permit may be a one-time permit or a permanent permit. It is your responsibility to allow or refuse our temporary access to this data while using the App. If you choose to grant access, please note that you can revoke this consent at any time by going to the "Settings" on your device. 

In all cases, We only process personal data which is strictly necessary for the fulfillment of the purposes described above. That is, if you provide Us with more information than the one expressly required, you consent to its processing for Us for the informed purpose(s).

In view of the foregoing, the Company shall not be liable if:

• The User is not of legal age according to the laws and regulations of their country of birth or residence. In this regard, it is the sole responsibility of parents and/or legal guardians to exercise appropriate control over the online activity of their minor children and prevent their access to apps whose content is not suitable or recommended for minors.

• The Company has received personal data and/or private information from an adult to provide the services offered on the App by a third party who has not requested the adult's consent to communicate their personal data to us. In such a case, the Company reserves the right to inform the data subject of how their personal data and/or private information has been collected and, where appropriate, we will request the natural person who has provided the personal data to the Company to confirm that they have requested the consent of the data subject and/or to amend this circumstance, as well as, if appropriate, suspend the services and/or the User account.

• For circumstances beyond our reasonable control, such as receiving erroneous, incomplete and/or fraudulent information from the User. You will be solely responsible for the inaccuracy or untruthfulness of the information provided. In this sense, the Company will not be responsible for the impossibility or error in the use of the App.

What do We use your personal data for? Please be informed that you only are required to provide personal data and information that is strictly necessary to fulfill the purposes explained below. In this regard, if you provide Us with more information than is expressly required, you consent to its processing for the purpose(s) for which it was granted.

Having said that, We use your personal data for the following purposes:

• To personalize your experience and improve the services.

• To collect the fees of the subscription plans to the Services offered through the App and process transactions;

• To manage your information queries regarding our App and/or the Service offered through it;

• To comply with our legal obligations, legal requirements, laws, and regulations and/or to respond to judicial, police or the corresponding authorities’ requirements;

• To protect, investigate, and deter fraudulent, unauthorized, or illegal activity on/through our App;

• When applicable, to improve our App’s functionalities and the Service offered by analyzing disaggregated data not associated with a particular User’s personal information.

• To send periodic push notifications to the User to achieve the purposes outlined in this Privacy Policy. Users must be aware that disabling push notifications may negatively affect the utility of this App.

What is the legal basis for processing your personal data? We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why We collect and process your personal data. In almost all cases the legal basis will be:

• The consent that you provided Us with for the processing of your personal data in order to be able to provide you with the services offered through the App and other purposes informed at the time of collection of your data. As well as for the purpose of tracking your activity when the User enables such an option voluntarily.

• The consent you have provided Apple/Google Play to install similar technologies on your device(s) for the purpose of tracking your activity in these platforms, for example, what applications you have installed or which information you share with third party partners about your browser or device for advertising purposes.

• To comply with our legal obligations and/or to attend administrative, judicial, police, or the corresponding authorities’ official requirements.

• Our legitimate interests in (i) offering an enhanced user experience when you access and use the app and operating it efficiently, (ii) monitoring fraudulent activity in order to preserve the security and integrity of our app; (iii) providing advertisements to users according to their interests; (iv) defending and addressing our rights in the event that a claim regarding our app and/or Service may arise.

Regarding cookies and/or similar technologies used by Apple/Google Play to collect and store the information on your device that is later shared with the partners of the services offered by these platforms, we recommend that you consult the Privacy and Cookie Policies of these platforms for information on how to revoke the consent that you have given for the installation of similar technologies.

How long do We keep your personal data for? We will keep your personal data only for as long as you are subscripted to the Service and, beyond that, your personal data will be retained, and securely blocked, for the necessary retention period to fulfill our legal obligations and/or for our legitimate reasons (i.e to address claims in connection with the services offered through the app; to finish the investigation of detected fraudulent or illicit activity.) 

Once the necessary retention period has ended, your personal data will be securely deleted from our information systems.

Who do We share the User’s personal data with? We will not share your personal information with third parties without your consent. Nonetheless, in order to provide the Service and comply with a legal obligation, protect our legal rights, or respond to a valid legal request, we may communicate your personal data to the following third parties, including but not limited to:

• (i) our main service providers, such as Apple/Google Play, where appropriate; 

• (ii) other providers such as RevenueCat, Google Inc, Amplitude, Firebase, Dezgo, among others;

• (iii) administrative, police or judicial authorities as long as the data is required in accordance with the applicable law and regulations; 

• (iv) law firms to respond to claims regarding our App or services offered through it; 

The third parties mentioned above may have their headquarters outside the European Economic Area (EEA), therefore, your personal data will be the object of international transfers. In any event, if a personal data international transfer is deemed appropriate, We inform you that We will only transfer personal data to recipients located in countries that ensure an adequate level of data protection or, failing that, offer the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, in order to ensure that your personal data is properly protected and that your individual rights and freedoms are guaranteed. In this regard, please be informed that the third parties mentioned above are committed with standard contractual clauses approved by the EU Commission certification in case of transfers to the USA.

How do We protect your personal data? Your trust is very important to Us. For this reason, your personal data is stored confidentially and securely in our information systems. We have established the appropriate technical and organizational measures to safeguard and protect your personal data against illegal or unauthorized access, loss or accidental destruction, damage, use, and illegal or unauthorized disclosure.

What rights do you have and how can you exercise them? We inform you that the Users can withdraw their consent to processing their personal data at any time. Users may also exercise the following rights: access, verify and seek rectification, have their Personal Data deleted or otherwise removed, restrict the processing of their data, object to processing of their data, as well as the right to have the Personal Data transferred to another controller (portability), with a written request, addressed to us, via the following e-mail: info@ereasy.app. We also inform you of your right to lodge a complaint to the Supervisory Authority.

As a general rule, We will respond to data protection rights requests within one (1) month. Occasionally, this period may be extended by two (2) further months where necessary, taking into account whether your request is particularly complex or you have made several requests. In this case, We will notify you of this event and explain the reasons for the delay to you.

Finally, We inform you that should you consider it appropriate, you have the right to lodge a complaint before the corresponding Supervisory Authority, especially if you consider that your data protection rights have not been adequately addressed. 

We remain at your disposal for any doubts or questions you may have about this Policy, please contact Us by email at info@ereasy.app.

What are cookies and what are they used for? For the purposes of this Policy, the single term ‘cookies’ refers to cookies and similar technologies that track information about accessing and interaction with our app, for different purposes such as facilitating information about the user’s device, the user’s your navigation through our app, remembering your browsing preferences, customizing the services offered on this app, the user’s purchase and cancellation history, to generate aggregate statistics based on user interaction, among others. 

The memorized data recorded by cookies takes up a small space on a device’s memory and does not harm the device in any way.

When are cookies installed? Interacting with our app and purchasing the paid services offered in it implies the installation of cookies, which may belong to us or be from third parties.

The use of third-party cookies is subject to the Cookies and Privacy Policies of these third parties. Therefore, We will not be responsible for the content or the veracity of the mentioned policies of said third parties. Please consult the website(s) and/or app(s) of said third parties to obtain more information or in the event that you want to change your preferences for setting these cookies.

What type of cookies are installed?

Cookies that can be installed include the following:

• Session cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and are automatically deleted when the browser on the User’s device is closed.

• Persistent cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and remain installed for a certain time in the browser of the User’s device.

• Owned cookies: these are sent to the User's device from our app and/or computer equipment, managed by Us, and their information is collected for our own purposes.

• Third-party cookies: these are sent to the User's device from computer equipment and/or website and/or app managed by another company (partners and/or service providers) and their information can be collected for our own purposes (i.e to know the geographical location of the User) and/or to manage or improve the services that these third-party companies offer (i.e to manage the payment of the app’s services). 

• Technical cookies: these allow the management and operation of this app and enable its functions and services, for example, to carry out the purchase process and manage payment, etc. 

• Analytical cookies: these allow Us to analyze the use of this app and recognize which functionalities interest users the most, in order to improve the quality and functionalities of our services (i.e the app’s look and feel, messages’ design for usability, etc.) This information is obtained from disaggregated data which is not associated with a particular User or his/her personal information. 

To install cookies in your device's browser, We need your express consent, although there are other cookies that are exempt from such consent. The exempt cookies are user authentication or identification cookies (session cookies only). 

We have enabled adequate mechanisms to obtain your consent for the installation of cookies that require it. However, please be informed that, in accordance with the applicable laws and regulations, (i) it will be understood that your consent has been given if you modify the configuration of the browser by disabling the restrictions that prevent the installation of cookies and that, (ii) when the installation of cookies is necessary to provide you with the services that you have expressly requested, your consent will not be necessary.