This Privacy Policy ("Policy") explains how AppSalt (Beellet, UAB, company code 305782095, registered at Antakalnio g. 17, Vilnius, LT-10312, Lithuania) ("Beellet," "AppSalt," "we," "us," or "our") collects, uses, discloses, and stores personal information when you use our services or interact with us. It applies to end-users of AppSalt applications and visitors to the AppSalt website. It also outlines statutory rights under applicable data protection laws.
1. Categories of data we collect
AppSalt develops a range of applications (referred to as 'AppSalt Applications') for various platforms, including TV, mobile, and PC. We collect only the minimal amount of user data necessary to provide and support the functionality of the AppSalt application. Also, we collect data from users of our AppSalt website.
1.1 Data collected through the AppSalt application.
When you use AppSalt Applications, we process the following categories of personal data:
- Registration data: User email address and encrypted password.
- Device information: IP address, operating system version, device model, last-seen timestamp, and location.
- Aggregated usage statistics: Data related to application usage, including crash and error reports, and analytics provided by analytic tools.
1.2. Data collected through the AppSalt website.
When you visit our website or contact us, we collect the following categories of personal data: Automatically collected data: IP address, location, type of browser, device, operating system. This data is collected using cookies and similar technologies. If you wish to read more about the cookies we use, their purpose, and duration, please see a detailed cookie table in Section 7 of this Policy. Data collected via communication: when you contact us via email or the contact form, we may collect: your name and/or surname (if provided), email address, subject and content of your inquiry, date of your inquiry, attachments (if applicable), our reply and any additional communication related to your inquiry.
1.3. No data about minors
We do not intend to collect any personal information of children under the age of 14 or any other age which would require authorization or consent of a holder of parental responsibility for collecting or processing the personal data of such a child. In the case of us accidentally collecting the personal information of children, we undertake to delete or otherwise dispose of such information as soon as possible after we become aware of having received it. If you are a holder of parental responsibility for a child that has provided us with their personal information without your consent or supervision, please contact us so we can take the actions required to stop collecting and processing your child’s personal data and erase the data that we may have already collected.
2. Purposes and legal basis
We process your data only when we have a lawful basis to do so. Below we provide more information on the purposes and legal bases for the data usage.
2.1. AppSalt application:
To provide services: Processing registration data and device information is necessary for the performance of a contract with you. To improve our services: Analyzing aggregated usage statistics helps enhance functionality, based on our legitimate interests. To process payments: Payment data is collected for contractual purposes and compliance with legal obligations.
2.2. AppSalt website:
To operate the website and improve user experience: Automatically collected data via cookies is processed based on your consent or our legitimate interest in ensuring website functionality and security. To respond to inquiries: Communication data is processed for the legitimate purpose of managing your request.
2.3. We may also process data mentioned in Section 1.1. and Section 1.2. to exercise our legal rights and fulfill legal obligations such as to comply with applicable tax obligations, to resolve disputes and to enforce, exercise, and uphold our rights.
3. Data retention
We retain your personal data only as long as necessary for the purposes outlined in this Policy. If the data is no longer required for a purpose pursued by us and there are no legal obligations to retain it (e.g., tax retention periods to which we are subject), we delete personal data. We only store personal data to the extent that it is necessary to comply with our legal obligations, particularly statutory retention periods, and for the establishment, exercise, or defense of legal claims. Specific retention periods include:
| Registration, service provision related data: | 5 years after the end of contractual or other relationships with you |
| Communication data: | 2 years after resolving your inquiry unless required longer for legal purposes |
| Usage data: | aggregated data may be retained indefinitely in anonymized form |
| Compliance data (referred to in Section 2.3) for | 10 years |
| Website functionality and analytics data | up to 1 year |
4. Data sharing
We do not sell your personal data for commercial business purposes. However, we may share your data with data recipients, both within and outside the European Economic Area (EEA), in cases where necessary for the above described purposes and allowed in accordance with applicable laws.
| Recipients/ categories of recipients | Location of the recipient | Legal basis for transferring data outside the EEA |
| Hetzner Online GmbH (data storage providers) | EU | - |
| Google Ireland Ltd (web and application usage analytics providers) | EU | - |
| Google LLC (web and application usage analytics providers) | US | Standard Contractual Clauses by the European Commission |
| Our business partners, clients with whom we may share your location and IP data in order to enable them to access and collect data from public internet resources (e.g., various websites) (such data sharing is necessary for the performance of the contract between you and Honeygain). | Worldwide | In cases where we transfer data outside the EEA, we rely on, Standard Contractual Clauses by the European Commission. |
| State, governmental, law enforcement institutions, courts, and regulatory authorities (when we are obliged to disclose information by law; when we exercise our legal rights to defend our interests in legal processes to which Honeygain is a party). | Worldwide | In cases where we transfer data outside the EEA, we rely on the condition that the transfer is necessary for the establishment, exercise, or defense of legal claims. |
5. Statutory data protection rights
Subject to conditions, limitations, and exceptions established by statutory data protection provisions, you have the rights listed below.
| Right | When is this right applicable? |
|---|---|
| Right of access, right to know about the personal information collected, disclosed | When you seek to obtain confirmation as to whether we collect or otherwise process personal data concerning you, and, where that is the case, access to the personal data and the information about the data processing. Once we receive and verify your request, we will disclose to you the categories of data we collected about you, the categories of sources for the data we collected about you, our business or commercial purposes for collecting that personal information, the categories of third parties with whom we share that data, the specific pieces of data we collected about you and other information that we are obliged to provide under the applicable laws. |
| Right to rectification | When you seek to obtain from us the rectification of inaccurate personal data concerning you. |
| Right to erasure (‘right to be forgotten”) | – When personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; – when you withdraw consent on which the processing is based and there is no other legal ground for the processing; – when you object to the processing and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes; – where the personal data have been unlawfully processed; – where the personal data have to be erased for compliance with a legal obligation; – where the personal data have been collected in relation to the offer of information society services directly to a child and subject to a consent. |
| Right to restriction of processing | – Where the accuracy of the personal data is contested by you; – where the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; – where we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; – where you have objected to processing |
| Right to data portability | Where you seek to receive the data you have provided in a structured, commonly used and machine-readable form or to transmit those data to another controller, the processing is based on consent or on a contract and is carried out by automated means. |
| Right to object | Where the collection and use is based on a task carried out in the public interest or in the exercise of official authority vested or legitimate interest, as explained in Section 3 of this Policy, or where you object to the collection of your personal data for direct marketing purposes. |
| Right to withdraw consent | Where the processing is based on consent, as explained in Section 3 of this Policy, and you seek to withdraw it at any time. |
| Right to lodge a complaint | Where you want to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the GDPR. |
| Right not to receive discriminatory treatment while exercising rights | When you exercise your rights enshrined in applicable laws, you also have the right to non-discrimination. For example, because you exercised your rights under applicable laws, you will not be denied any services, charged with a different price, provided a different quality of goods and services etc. |
6. No automated individual decision-making, including profiling
We do not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you. However, for security purposes, we use algorithms to decide whether there are any abnormalities in our user base. In case the algorithms show such abnormalities, the related activities are submitted for a human review and may result in suspension or (in the most extreme cases) termination of our services.
7. Cookies or similar tracking technologies
We use cookies to collect information from the device you use to access our services. Cookies are small text files containing an identifier that is sent by a web server to your web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use cookies and similar technologies to enhance user experience, analyze traffic, and provide functionality.
For a detailed list of the cookies we use, their purposes, and duration, please see the AppSalt cookie list below.
| Cookie Category | Cookie name | Cookie purpose | Cookie expiry |
|---|---|---|---|
| Necessary | bscookie | This cookie is used to identify the visitor through an application. This allows the visitor to login to a website through their LinkedIn application for example. | 1 year |
| li_gc | Stores the user's cookie consent state for the current domain. | 180 days | |
| ZD-suid | Unique id that identifies the user's session. | Persistent | |
| Statistics | _ga | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 years |
| _gid | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 day | |
| _gat | Used by Google Analytics to throttle request rate. | 1 day | |
| _clck | Collects data on the user’s navigation and behavior on the website. This is used to compile statistical reports and heatmaps for the website owner. | 1 year | |
| _clsk | Registers statistical data on users' behavior on the website. Used for internal analytics by the website operator. | 1 day | |
| _cltk | Registers statistical data on users' behavior on the website. Used for internal analytics by the website operator. | Session | |
| _ga_# | Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit. | 2 years | |
| AnalyticsSyncHistory | Used in connection with data synchronization with third-party analysis service. | 30 days | |
| c.gif | Collects data on the user’s navigation and behavior on the website. This is used to compile statistical reports and heatmaps for the website owner. | Session | |
| CLID | Collects data on the user’s navigation and behavior on the website. This is used to compile statistical reports and heatmaps for the website owner. | 1 year | |
| collect | Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. | Session | |
| ln_or | Registers statistical data on users' behavior on the website. Used for internal analytics by the website operator. | 1 day | |
| ZD-buid | A unique id that identifies the user on recurring visits. | Session |
When you visit our website, we ask for your consent for the use of non-essential cookies. However, essential cookies are enabled by default because they are a prerequisite for our website to function. We respect your preferences concerning cookies, and you can easily manage and disable cookies on our website. You can configure your browser to decline some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies, you may be unable to access certain areas or features of our website. You can control the use of functionality cookies, targeting cookies, or advertising cookies by adjusting your browser settings.
8. Updates to this Policy
We reserve the right to amend this Policy unilaterally from time to time. Any changes will become effective immediately upon publication. Please check our website regularly to stay informed of the latest version of this Policy. If we make significant changes to this Policy, we will take reasonable steps to notify you in advance. Notifications may include emails (where possible), pop-up messages on our website or applications, or other appropriate methods based on the specific circumstances.
9. Contact us
If you have any questions about this Policy or how we collect and process your data, please contact our support team at [email protected].