As part of our mission to spread good vibes, we want you to share the things that matter to you most with your friends, family and anyone else around you. It's important to us that you feel comfortable and trust us with your information when you use the CwSim services (the "Services"). Please take a few minutes to read this Privacy Policy, so that you understand what information we collect, what we do with it and why.

In general, we only collect information that allows us to provide you with our best Services. This includes, for example, simple tasks like allowing other users to see the name and picture you choose to show. It also helps us to keep our Services clear of fraud and spam, and it allows us to get a unique understanding of what additional services may be useful to you, and all other purposes set out in this policy below.

Scope and consent

Before you start sharing good vibes, it's important you understand that by using our Services, you allow us to collect, use, disclose, and retain your personal information and other information but we will never read or listen to the content you are sharing privately. You can be sure that we will only use your information as described in this Policy.

Information we collect

We collect the minimum information required to achieve the purposes set out in this Policy (see below):

Registration and Account Information: When you use our various Services you voluntarily give us personal information (e.g., name, email, birth date, age, phone number and, when necessary, billing information) and you are not anonymous to us.

Additional Information: We collect additional information when you access our App through a certain device (e.g. your mobile device's unique identifier; information about your device's operating system, your browser, browser or operating system language; your wireless network, and your mobile carrier; the CwSim call log).

Accessing, Reviewing, and Changing Your Personal Information

As a registered member, you can review and change personal information at any time by accessing your account on the App or contacting our support. Please be sure to update your personal information promptly if it changes or becomes inaccurate. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account or membership is terminated or suspended, we may maintain some information to prevent you from re-registering.

EEA Privacy Rights

If you use our services from the EEA, you have certain rights regarding your personal information, subject to local law. These include the following rights to: access your personal information, rectify the information we hold about you, erase your personal information, restrict our use of your personal information, object to our use of your personal information, receive your personal information in a usable electronic format and transmit it to a third party (right to data portability), lodge a complaint with your local data protection authority. To learn more about exercising your EEA rights, visit our EEA rights page. If you would like to understand or exercise such rights, please contact us at the details below. We will contact you if we need additional information from you in order to honor your requests.

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

  • to fulfill our contractual obligations to you, for example to provide the services, to ensure that invoices are paid correctly.
  • Where you have given your consent to the processing.
  • to comply with our legal obligations, as explained above.
  • to meet our legitimate interests, for example to understand how you use our products services and to enable us to derive knowledge from that, which allows us to develop new products and services, and to personalize the service for you and the ads you see. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
  • to protect the vital interests of the data subject or of another natural person.
  • necessary for the performance of a task carried out in the public interest.
We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to Cookies and Tracking Technologies or when we process accurate location data for purposes other than performing the service). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice or by changing your setting within the app. We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Security

We know that security is important to our users and we care about the security of your information. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use include firewalls, data encryption, physical access controls to our data centers and information access authorization controls. We need your help too: it is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third-parties.

Children's Privacy

Our Services are not intended for children under the age of 13. Therefore we do not knowingly collect personal information via our websites, applications, services, or tools from anyone under 13. In the EEA, certain default privacy settings will be applied to users under the age of 16 and can only be changed if the legal guardian instructs so in writing.

Updates to this Policy

From time to time, as our services evolve, we may update this Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the App. Please check the App frequently for updates.

Contact Us

If you still have questions about our privacy policy, please feel free to send us an email to info@comfortway.com, or using the contact us form on the App.

In the event you read this Privacy Policy in any language other than English, you agree that in the event of any discrepancies, the English version shall prevail.

Privacy Policy
ЛОЯЛЬНОСТЬ
ПАРТНЕРАМ
Официальный дистрибьютор в РФ ООО "Технотрэвел"
ОГРН 1157746408753
ИНН 7720302135
Юридический адрес:
127055, г. Москва, ул. Сущевская, д. 12, стр. 1.
+7 (800) 333 66 86