DigiBarboleta mobile appprivacy policy

This privacy policy informs about the privacy practices and principles of personal data processing in connection with the Barboleta Ltd. mobile app DigiBarboleta. Our privacy policy is based on the European Union’s General Data Protection Regulation (GDPR). 

This Privacy Policy provides detailed information about the processing of personal data and your rights and obligations in relation to your personal data. We collect your personal data for the following purposes: our services improvement, communication with the mobile app users, profile personalization, statistical data storage and analysis, balance board finding and connection to the mobile app using Bluetooth and location data, and debugging errors.

1. Terms used in the Privacy Policy

1.1. Personal data processing manager – Barboleta Ltd, registration number 43603079216, address: Atmodas street 9, Jelgava, Latvia, LV-3003, e-mail: support@barboleta.lv

1.2. Privacy Policy – Privacy protection and data processing policy, which refers to Barboleta Ltd. actions regarding information that Barboleta Ltd. collects about its Customers, including the use of Content and Services, as well as visiting the mobile app. Any changes we will make to this Privacy Policy will be published on the website www.barboleta.lv.

1.3. User – a natural person who visits the DigiBarboleta mobile app and/or uses it.

1.4. Application – the DigiBarboleta mobile app, which runs with the Android operating system, and in which Users with an internet connection can access and use the Content and Services available in it. The mobile app can be used without the Internet, as long as it does not affect the user profile and its associated data.

1.5. Content – tasks for children aged 3-6 and 7-10 years on various topics, for use with the DigiBarboleta balance board. Tasks are designed to support the learning process on a daily basis, promote children’s ability to focus, improve balance and reduce stress. The content is free of charge.

1.6. Service –Barboleta Ltd service provides the User with access to the Content of the DigiBarboleta mobile app.

2. Purposes of data processing

2.1. Barboleta Ltd collects your personal data when you visit the mobile app, contact us, use the Services and Content of the mobile app, or sign up for news.

2.2. Barboleta Ltd. processes your personal data to successfully manage, develop and analyze Barboleta Ltd. relations with Users.

2.3. Barboleta Ltd. uses the personal data of Users in connection with marketing, and sales, as well as for organizing marketing campaigns.

2.4. We care about the privacy of Users, therefore the personal data of Users will in no case be sold or disclosed to third parties for purposes not provided for in this Privacy Policy, thus by agreeing to the processing of your personal data in accordance with this Privacy Policy, you agree that Barboleta Ltd. may process your personal data for the following purposes (they may be processed for one or more purposes at the same time):

2.4.1. The purpose of the data to be processed is to implement the execution of the selected service, including ensuring the quality associated with it, solving the reported issues, if they arise, as well as executing the binding regulatory acts. The basis of data processing is the requested/used service of Barboleta Ltd. and the implementation of related regulatory acts. Such processing is a prerequisite for the provision of the service, and failure to provide data may partially or fully delay or terminate the provision of the transaction. Regarding his data, the User has the right to exercise the rights stipulated in the regulatory acts.

2.4.2. In order to provide products and services, Barboleta Ltd. may process your personal data in order to verify your identity, conclude contracts with you, including distance contracts, and ensure the fulfillment of the requirements of regulatory acts and the contracts concluded with you.  In addition, for the implementation of this purpose, Barboleta Ltd. may transfer your personal data to subcontractors and other cooperation partners, if necessary.

2.4.3. Barboleta Ltd. may use your personal data to contact you, answer your questions, send you important warnings, information, and notifications related to the mobile app Services and mobile app Content, as well to inform you that our Services and Content have changed, and we would like to ask you to provide feedback on our mobile app Content and Services.

2.4.4. Barboleta Ltd. may send you commercial notices about the mobile app Content and Services, advertising and marketing campaigns, and other activities.

2.4.5. For the management, analysis, and development of products and services Barboleta Ltd. within the limits of the internal operations may use your data to manage, analyze and improve relations and cooperation with its Users internally, as well as to improve and develop the Content and Services of the mobile app, to analyze the effectiveness of our advertisements, and provide you with appropriate recommendations regarding our mobile app Content and Services.

2.4.6. Barboleta Ltd. can perform your profiling as part of the processing of your personal data in order to personalize offers and provide you with the most relevant Content.

2.4.7. User data may be used in anonymized form for statistical, mobile app improvement, and advertising purposes.

3. What information do we collect?

3.1. First name;
3.2. E-mail address;
3.3. Represented country;
3.4. Year of birth;
3.5. Technical data sent by your mobile device for more accurate error detection and prevention.
3.6. Campaigns and marketing activities sent to you and their use;
3.7. Your personal data, which we must process in accordance with the requirements of regulatory acts.
3.8. Your mobile app usage statistics and game statistics.
3.9. The location data of the phone when the mobile app and the balance board are connected so that the mobile app can find and connect to the balance board. This requirement is disclaimed in Android‘s official documentation

(see https://developer.android.com/guide/topics/connectivity/bluetooth/permissions#declare-android11-or-lower )

4. Where do we collect your personal data?

4.1. Your basic data is collected when you register your profile and use the mobile app, as well as in e-mail correspondence, in writing, orally, or from information provided in the mobile app, as well as from software, cookies and similar technologies when you use the mobile app or our posted advertising materials in e-mail or on the Internet.

5. Are your personal data regularly shared with others?

Without the User’s consent, Barboleta Ltd. does not give the User’s personal data to third parties, except in the cases, in the order and in the scope defined in the laws and regulations, and Barboleta Ltd. authorized persons and cooperation partners for ensuring the provision of Services, the Application quality assurance, development and improvement of the operation.

5.2. Barboleta Ltd. ensures that your personal data is not disclosed to third parties, except if otherwise specified in this Privacy Policy.

5.3. Barboleta Ltd. may transfer your personal data to third parties who provide services for the purposes described in this Privacy Policy within the limits of the applicable laws and regulations. This may include, for example, the provision of services such as IT services, management, and analysis of personal data, conducting surveys and research, marketing management, and execution of various campaigns, etc.

5.4. Barboleta Ltd. may transfer your personal data as part of a company merger, acquisition, sale of company assets, or transfer of services to another service provider.

5.5. Keep in mind that Barboleta Ltd. may need to disclose your personal data if it is determined by the applicable regulations. We are obligated to disclose customer information to law enforcement authorities if criminal activity is suspected.

6. Personal data processors whose services we use.

6.1. We use the IT service provider Midis Ltd. for mobile app technical monitoring and ensuring mobile app functionality.

6.2. If you have signed up to receive Barboleta Ltd. news by e-mail, then this section applies to you.

6.2.1. We use a service provider MailerLite to manage our email marketing subscriber list and send emails to our subscribers. MailerLite is a third-party service provider that may process your data using industry-standard technologies to help us monitor and improve our mailing list.

MailerLite privacy policy is available at https://www.mailerlite.com/privacy-policy.

6.2.2. You can unsubscribe from our e-mails by clicking the unsubscribe link at the end of any e-mail you receive.

7. Will we transfer your personal data outside the European Union or the European Economic Area?

7.1. Without your written consent, we will not transfer your personal data outside the borders of the European Union or the European Economic Area.

7.2. The operation of the application is provided by the technological platform for mobile applications developed by the Google company. Google receives data about your purchases on these websites and the use of the App. The processing of this data is carried out outside the member states of the European Union and the European Economic Area. Familiarize yourself with the Privacy Policies of these companies so you are aware about the data that is at the disposal of these companies. 

8. Ensuring data security

8.1. In order to guarantee the security of the collected information, Barboleta Ltd. has implemented electronic, physical, and administrative security measures. Your data is kept safe. They are protected against unauthorized access, disclosure, modification or destruction by any organization or individual.

9. Your right to access your personal data, correct it and prohibit the use of it.

9.1. You have the right to receive information about your personal data contained in the Barboleta Ltd. files and to request the correction or updating of incorrect data, the termination or destruction of their processing, if they are incomplete, outdated, illegally processed or they are no longer necessary for the purpose of their collection. Such a request must be made in writing and submitted to Barboleta Ltd, Atmodas iela 9, Jelgava, Latvia, LV-3001, e-mail: support@barboleta.lv.

9.2. We draw your attention to the fact that Barboleta Ltd. may not delete your data if there is a legal requirement to store them for a certain period of time, for example, accounting, record keeping, etc. requirements or if there are other legitimate grounds for data processing, such as contractual obligations.

9.3. You have the legal right to prohibit Barboleta Ltd. from processing your personal data for sending commercial messages, or for use in the market and public opinion research at any time. In this case, you must make a written request and submit it to Barboleta Ltd. Atmodas street 9, Jelgava, Latvia, LV-3001, e-mail: support@barboleta.lv. or by using the opt-out link that you will find at the end of each of our electronic marketing mailings.

10. Applicable Law, Breach Reporting

10.1. The processing of personal data is regulated by Regulation (EU) 2016/679 of the European Parliament and of the Council (April 27, 2016) on the protection of natural persons with regard to the processing of personal data and the free movement of such data, as well as the related valid regulatory acts of the Republic of Latvia.

10.2. Please do not hesitate to contact Barboleta Ltd. by e-mail at support@barboleta.lv if you have any questions, or comments related to this Privacy Policy or want to report violations of this Privacy Policy.

11. Renewal of Privacy Notice

11.1. Barboleta Ltd. may change this privacy statement. Any such changes will be communicated on this page in due course. If you continue to use our mobile app after you have been notified of changes to the Privacy Policy, this indicates that you agree that your newly submitted information is used in accordance with the changed mobile app Privacy Statement. This Privacy Policy is valid since 15.11.2022.

12. How to contact Barboleta Ltd.

12.1. If you have any questions or want Barboleta Ltd. to correct or delete your profile, contact us by writing to the e-mail address: support@barboleta.lv.