Privacy Policy

Effective as of 14 September 2022.

Introduction

This Privacy Policy explains how Ringoals (“we” or “us”) collects, stores, uses, transfers and shares Personal Data from our users (“you”) in connection with the Systemize mobile application, My Done & RingDo (the “App”)*, and the ringoals.com website including any products and services related to it (the “Website”) (all collectively, the “Services”).

*Please note the App may be listed under a different name depending on your location.

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address provided when you register), through the App, or by presenting you with a new version of this Privacy Policy. If permitted by applicable law, your continued use of the Services after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will be given a choice about whether to explicitly accept changes to the Privacy Policy. If you do not accept the terms of the Privacy Policy, please do not use the Services. 

Please check the Privacy Policy posted on our Website and in the App for the latest updates on our data privacy practices.

Personal Data we collect from you

We collect Personal Data about you in a variety of ways. Sometimes we collect Personal Data automatically when you interact with the Services, and sometimes we collect the Personal Data directly from you. At times, we may receive Personal Data about you from other sources and third parties. 

Personal Data you provide to us directly:

General Information. When you sign up to use the Services, we may collect Personal Data about you such as:

  • Name;
  • Email address;
  • Year of birth;
  • Password or passcode;
  • Place of residence and associated location information including time zone and language;
  • ID (for limited purposes).

In many cases, we may be able to infer your gender by your use of the Services. 

Personal Data we collect automatically:

When you access or use the Services, we may automatically collect the following information:

Device Information:

  • Device model;
  • Information about the operating system and its version;
  • Unique device identifiers (e.g. IDFA);
  • Enabled device accessibility features (e.g. display features, hearing features, physical and motor features);
  • Mobile operator and network information;
  • Device storage information;
  • Version of your device system.

Location Information:

  • IP address;
  • Time zone;
  • Information about your mobile service provider.

Data about your use of the Services, including, among others:

  • Frequency of use;
  • Areas and features of the Services that you access, visit or use;
  • Engagement with particular features.

To collect this and other information, we may use cookies and other tracking technologies. See more in our Cookie Policy.

Data from external sources. We may receive Personal Data about you from third parties. For example, we may obtain information from third parties, to enhance or supplement existing user information, including to customize and personalize your experience and for statistical purposes and analytics, as described below.

How we use your Personal Data

We will not collect and use your Personal Data without letting you know. Depending on which features of the Services you use, we will process your Personal Data based on one or more of the following legal bases:

  1. Your consent. For example, on the registration screen when you give us permission to process your Personal Data;
  2. To fulfill our contractual obligations to you in order to provide the Services to you;
  3. Legitimate interest. We may process your Personal Data in relation to our interests in providing the Services to you, our commercial interests, including our interest in protecting the security and integrity of the Services, and wider societal benefits;
  4. Legal obligation. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.

Principles of processing

Data minimization and purpose limitation. We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate consent. 

No sale of Personal Data. We will not sell or rent your Personal Data. We will not disclose your Personal Data except as otherwise described in this Privacy Policy. We may share your Personal Data with our service providers solely as described in this Privacy Policy. We will also not use information received through your use of the HealthKit and Google Fit framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.

Third parties processing your Personal Data

We will not share your Personal Data with third parties except as specified below.

Processing to find new users and stay in touch with you

With your consent, we may share some of your Personal Data with AppsFlyer for marketing and promotional purposes. AppsFlyer is a mobile marketing platform that handles your Personal Data in accordance with our instructions. By using AppsFlyer and its integrated partners for marketing and promotional purposes we are able to reach you and people like you on various platforms and spread the word about us. If we need to share your Personal Data with other platforms for this purpose, except as we have explained in this Privacy Policy, we will ask for your consent. 

Aggregated information

We may aggregate, anonymize or de-identify your Personal Data so that it cannot reasonably be used to identify you. Such data is no longer Personal Data. We may share such data with our partners or research institutions or use for statistical purposes, for example, we may share or use general age, demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users in articles, blog posts and scientific publications. Sharing this data contributes to the advancement of scientific research on women’s health. Our legal basis for processing your data for this purpose is legitimate interest. 

Special circumstances

We may also share some of your Personal Data in the following special circumstances: 

  • in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements);
  • when disclosure is required to maintain the security and integrity of the Services, or to protect any user’s security or the security of other persons, consistent with applicable laws. In such cases we may also delete some of your Personal Data (e.g., by resetting your password to avoid unauthorized access);
  • when disclosure is directed or consented to by the user who has input the Personal Data;
  • in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.

Depending on the circumstance, we may rely on legitimate interest or legal obligation as our legal basis for the above processing activities. 

Retention of your Personal Data

Except as set forth below, we will retain your Personal Data as long as needed to provide you with the Services or otherwise fulfill the purposes for which it was collected. 

Impact of App Deletion or Inactivity: If you choose to delete the App from your device or your account becomes inactive, we will retain your Personal Data for a period of 3 years in case you decide to re-activate the Services or re-install the App. The App covers different periods of users’ lifecycle; therefore, retention of your data is needed in some cases to secure your smooth experience with other App functions (e.g., switching to pregnancy mode after cycle tracking). 

Limitations: You should be aware that, although we will anonymize or otherwise de-identify your data where possible, we may retain certain Personal Data and other information after your account has been terminated or deleted as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

Security of your Personal Data

General security measures

We implement technical and organizational measures in an effort to protect Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). These measures include Pseudonymization and tokenization of certain categories of your Personal Data.

Encryption of your Personal Data in transit and in rest.

Systematic vulnerability scanning and penetration testing.

Protection of data integrity.

Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the Services. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.

Conducting periodical data protection impact assessments in order to ensure that the Services fully adhere to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake a privacy audit in the event of a merger or takeover.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. However, no security system is perfect and, as such, we cannot guarantee the absolute security of the Services, or that your information will not be intercepted while being transmitted to us. 

Security breaches

If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in the Privacy Policy (such as notifying you in certain cases), we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.

Communication with you

We may contact you from time to time via email or through other means (like popups or push notifications) to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. 

Opt-out options. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails or notifications will not end the transmission of important service-related emails that are necessary to your use of the Services. You may also opt out of receiving popups or push notifications by adjusting your settings in your device. If applicable laws prescribe so, we may ask some users to provide their additional consent for such communications.

Please note that we may contact you with information about products, services, offers, promotions, rewards, and events offered by us and others via third-party platforms (like social media). For more information, including instructions for how to opt-out, please see the section above titled ‘Processing to find new users and stay in touch with you’. 

Contact us

General

If you have any questions or concerns about your privacy you may contact us at:

hello@adnsol.com

You may also contact your local data protection authority. A list of local data protection authorities is available here.