1. Introduction
Made in Heaven Sàrl ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use Spylib (the "Service"). By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
2. Data Controller
3. Information We Collect
3.1. Personal Data
We may collect the following personal information:
- Registration Information: Name, email address, and payment details when you create an account.
- Authentication Data: Information from third-party services like Google or Discord if used for login.
- Communication Data: Records of your communications with us.
3.2. Usage Data
We collect information on how you access and use the Service, including:
- Device Information: IP address, browser type, operating system.
- Log Data: Pages visited, time and date of access, time spent on pages.
3.3. Cookies and Tracking Technologies
We use cookies, web beacons, pixels, and similar technologies to collect data about your interactions with the Service.
3.4. Marketing and Analytics Data
Data collected through marketing platforms and pixels for analytics and advertising purposes.
4. How We Use Collected Information
We use your information for the following purposes:
4.1. Service Provision
- To operate, maintain, and improve the Service.
- To process transactions and manage your account.
4.2. Communication
- To send administrative information, updates, and support messages.
- To respond to your inquiries and provide customer service.
4.3. Marketing and Advertising
- To provide personalized content, offers, and advertisements.
- To perform retargeting and behavioral advertising.
4.4. Analytics
- To analyze usage patterns and improve user experience.
4.5. Legal Compliance
- To comply with legal obligations and protect legal rights.
5. Legal Basis for Processing Personal Data (Under GDPR)
Our legal basis for processing your personal data includes:
- Consent: For marketing communications and non-essential cookies.
- Performance of a Contract: To provide the Service as agreed.
- Legitimate Interests: For improving the Service, fraud prevention, and network security.
- Legal Obligations: Compliance with laws and regulations.
6. Data Sharing and Disclosure
6.1. Service Providers
We may share your information with third-party vendors for:
- Payment Processing: To facilitate transactions.
- Analytics: To understand and improve the Service.
- Marketing: To deliver advertisements and promotions.
- Hosting Services: To host our website and data.
6.2. Legal Requirements
We may disclose your information:
- To comply with legal obligations.
- In response to lawful requests by public authorities.
6.3. Business Transfers
In the event of a merger, acquisition, or asset sale, your personal data may be transferred.
6.4. Protection of Rights
To protect the rights, property, or safety of Made in Heaven Sàrl, our users, or others.
7. International Data Transfers
Your information may be transferred to and processed in countries outside of your own. We take appropriate safeguards to ensure your data is protected, such as:
- Standard Contractual Clauses approved by the European Commission.
- Compliance with applicable data protection laws.
8. Cookies and Similar Technologies
8.1. Types of Cookies Used
- Essential Cookies: Necessary for the functioning of the Service.
- Analytical Cookies: For performance and analytics.
- Marketing Cookies: For advertising and marketing purposes.
8.2. User Consent
We obtain your consent for the use of non-essential cookies.
8.3. Managing Cookies
You can control cookies through your browser settings. However, disabling cookies may affect the functionality of the Service.
9. Data Retention
9.1. Retention Period
We retain your personal data for as long as necessary to:
- Provide the Service.
- Comply with legal obligations.
- Resolve disputes.
- Enforce our agreements.
9.2. Deletion Procedures
When no longer needed, we securely delete or anonymize your data.
10. Data Security
10.1. Protection Measures
- Use of encryption, firewalls, and secure servers.
- Regular security assessments.
10.2. Access Controls
- Restricted access to personal data to authorized personnel.
10.3. Data Breach Protocols
- Procedures to detect, respond to, and notify of data breaches as required by law.
11. User Rights Under GDPR
You have the following rights:
11.1. Access
- Request a copy of your personal data.
11.2. Rectification
- Request correction of inaccurate or incomplete data.
11.3. Erasure ("Right to be Forgotten")
- Request deletion of your personal data under certain conditions.
11.4. Restriction of Processing
- Request limiting the processing of your data.
11.5. Data Portability
- Receive your data in a structured, commonly used format.
11.6. Objection
- Object to processing based on legitimate interests or for direct marketing.
11.7. Withdrawal of Consent
- Withdraw consent at any time without affecting the lawfulness of prior processing.
11.8. How to Exercise Rights
12. Children's Privacy
12.1. Not Intended for Minors
- The Service is not intended for individuals under 16 years of age.
12.2. Parental Consent
- If we become aware of data collected from a child under 16, we will delete it promptly.
13. Third-Party Services
13.1. Links to Other Sites
- The Service may contain links to third-party websites.
13.2. Third-Party Privacy Practices
- We are not responsible for the privacy practices of third parties.
13.3. Data Sharing with Third Parties
- Data may be shared with third-party services for analytics and marketing.
14. Marketing Communications
14.1. Consent for Marketing
- We obtain your consent to send promotional emails or newsletters.
14.2. Opt-Out Mechanisms
- You can unsubscribe using the link in our emails or by contacting us.
14.3. Transactional Messages
- You cannot opt-out of essential service-related communications.
15. Changes to Privacy Policy
15.1. Right to Update
- We may update this Privacy Policy periodically.
15.2. Notification of Changes
- Significant changes will be notified via email or prominently posted on our website.
15.3. Effective Date
- Changes become effective on the date specified in the updated policy.
15.4. Continued Use
- Continued use of the Service after changes constitutes acceptance of the new policy.
16. Contact Information
16.1. Data Protection Officer
16.2. Privacy Inquiries
16.3. Complaint Resolution
- You have the right to lodge a complaint with a supervisory authority if you believe your rights have been violated.
