This Policy applies between you, the User of this App and Clean Something For Nothing the owner and provider of this App. This Policy applies to our use of any and all Data collected by us in relation to your use of the App and our Services. This Policy was last updated on the 10 September 2020.
This Data Protection Policy applies to the services of Clean Something For Nothing. If you live in the European Economic Area, Regulation (EU) 2016/679 (General Data Protection Regulation) is the European Regulation and in Luxembourg, it is the Law on the organization of the National Data Protection Commission (CNPD) and the general data protection framework.
Clean Something For NothingTM is the Controller of your personal data.
The Supervisory Authority
The National Commission for Data Protection (Commission Nationale pour la Protection des Données) (CNPD) in Luxembourg is the for us relevant authority in matters of data protection. You have the right to make a complaint at any time to the CNPD (www. cnpd.public.lu). We would, however, appreciate the chance to deal with your concerns before you approach the CNPD so please contact us in the first instance.
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Our App is not intended for children and we do not knowingly collect data relating to children.
What is personal data?
Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”).
What about your GSM location?
We only use your location to show display a better user experience and to be able to identify the events and cleanup alerts around you. We do not save or track in any case your location data, neither we will share it with any third parties.
What data do we collect?
We may collect data or ask you to provide certain data when you use our App and services. The sources from which we collect Personal Data are:
Data collected directly from you or your device relating to an identified or identifiable natural person (“Data Subject”) and may include direct identifiers such as username, email address and country of origin (optional).
We organise collected Personal Data as Account Data and Clean-up activity Data.
Account Data is everything we need to set up your account and includes your email address and username, and information connected with our services, such as your Clean-up activity.
Clean-up activity is everything we need to give you an overview of the place you’ve cleaned (before and after).
As described above, we link data and if we have already collected some of your data, we will only ask you for the remaining data that is necessary to carry out our service.
If you have used our service and later delete your account, we will entirely remove your data from the app. Your cleanup activity and clean-ups will remain on the app as an empty user with no name. If you desire to fully delete these ones too, we kindly ask you to contact us at our email address previously mentioned.
How personal data is collected
We collect personal data in the following ways:
|direct interactions||you may provide personal data when you complete our registration form, subscribe to our services, create a user account, use our feedback form or otherwise or correspond with us .|
|automated technology||we automatically collect personal data (technical and usage) when you browse or interact with our app. We may also receive technical data about you if you use our app such as your ip address.|
On what grounds do we use Personal Data?
We use your Personal Data for the following purposes and on the following grounds:
- On the basis of fulfilling our service (when you use our service)
- On the basis of your consent (when you contact us)
- On the basis of legal obligations (for obligations such as when a court or other authority asks us to)
- On the basis of our legitimate interest (for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights.)
Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
When do we disclose your Personal Data?
We disclose your Personal Data in response to your enquiry or your request for information within our Company in order to provide the best service possible and within our legitimate interest.
We may share your information with organisations that help us provide the services described in this Data Protection Policy and who may process such data on our behalf and in accordance with this Data Protection Policy, to support this App and our services. For example, with our legal other professional advisors.
We may disclose personal information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the App and its users.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
You have the right to:
- information about the processing of your personal data
- obtain access to the personal data held about you
- ask for incorrect, inaccurate or incomplete personal data to be corrected
- request that personal data be erased when it’s no longer needed or if processing it is unlawful
- object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation
- request the restriction of the processing of your personal data in specific cases
- receive your personal data in a machine-readable format and send it to another controller (‘data portability’)
- request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision
Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at firstname.lastname@example.org
If you feel that your request is not satisfactorily resolved by us, you may approach your local data protection authority. The National Commission for Data Protection (Commission Nationale pour la Protection des Données) (CNPD) is the supervisory authority in Luxembourg and relevant to Clean Something For Nothing.
How do we protect your Personal Data?
We protect your data using state of the art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards and procedures to ensure the highest level of administrative protection.
In more detail to access our database the user must be authorised, is challenged through a two-way authentication system and use an encrypted VPN. Also, the removal of Personal Data from our location is forbidden and made by using a complex encryption system very difficult. We use cutting edge antivirus and anti-malware software and up-to-date firewall protection. Moreover, authorised personnel must have a legitimate need to know interest such as being your point of contact or service your user account.
The data we collect from you may be stored, with appropriate technical and organisational security measures applied to it, on our servers in Frankfurt, Germany. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.
To exercise any of your rights, or if you have any questions or complaints about our use of your Personal Data and this policy, please contact us using email@example.com.
We do not transfer your personal data outside the European Economic Area (EEA).
Automated decision-making and profiling
We do not use automation for decision-making and profiling
This Data Protection Policy and our commitment to protecting the privacy of your personal data can result in changes to this Data Protection Policy. Please regularly review this Data Protection Policy to keep up to date with any changes.
Queries and Complaints
Any comments or queries on this policy should be directed to us using the following contact details.
Clean Something For Nothing
If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us. You can also make a referral to, or lodge a complaint with, the National Commission for Data Protection (Commission Nationale pour la Protection des Données – CNPD).