Privacy Policy

Please email contact@allwayswithyou.com for more info.

Effective [1 May 2019]

Introduction:
Allwayswithyou’s mission is to help you keep in contact with those you love, no
matter what the circumstances. Central to this mission is our commitment to be
transparent about the data we collect about you & your family and how it is used.
This privacy policy applies when you use our services (described below). We offer
our users choices about the data we collect, use and share as described in this
privacy policy.

Allwayswithyou Limited built the Allwayswithyou platform as a commercial platform.
This service is provided by Allwayswithyou Limited and is intended for use as is. This
page is used to inform website visitors regarding our policies with the collection, use,
and disclosure of personal information for users of our service.

If you choose to use our service, then you agree to the collection and use of
information in relation to this policy. The personal information that we collect is used
for providing and improving the service. We will not use or share your information
with anyone except as described in this privacy policy. The terms used in this privacy
policy have the same meanings as in our user agreement, which is accessible at
Allwayswithyou.com unless otherwise defined in this privacy policy.

Who we are:
Allwayswithyou Limited
Sonas, Quin, Co. Clare, Ireland.
contact@allwayswithyou.com

Where do we process data:
Allwayswithyou stores and processes personal data which is physically located in
Germany.

Purpose of the processing:
Allwayswithyou processes personal data for the following purposes:
 Provision and personalisation of the Allwayswithyou service
 Direct marketing
 Monitoring of the Allwayswithyou service (e.g. web history, Apps, Cookies)
 Profiling of personal data for reporting and analytics
 Payment processing via Stripe
The legal basis for this processing is:
 Consent to deliver the Allwayswithyou serviceOur registered users share content and engage with circle of family and friends only.
Content and data is viewable only to families, friends and the Loved one.

Data we collect:
“Account Organiser” registration
To create an account you need to provide data including your name, email address
and a password. If you register for a premium service, you will need to provide
payment (e.g., credit card) and billing information.

“Friends and Family circle” registration
To create a friends and family circle you need to invite your family & friends member
to the Allwayswithyou platform via email. Access to this circle is via invitation only
from the account organiser.

“Loved one” registration
To register your Love one you will need to provide, name, year of birth, likes and
dislikes.

Payment processing details are collected via the Stripe platform

Links to Other Sites
The Allwayswithyou service enables members of the circle to share content from
various third-party websites, with the other members of the circle. Allwayswithyou
assumes you already have an existing account with the third-party platform and that
you have reviewed their privacy policies. Allwayswithyou have no control over and
assume no responsibility for the content, privacy policies, or practices of any third-
party sites or services.

Children’s Privacy
You must be at least 18 years old to create an account and engage in activities and
transactions on our digital and social media. By creating an account or engaging in
activities or transactions on our digital and social media, you affirm that you are at
least 18 years old and are fully able to enter and comply with our regular Terms of
Use and this Privacy Policy and Notice. If we are notified or learn that a child has
submitted Personal Data to us through our digital or social media, we will delete such
Personal Data.

Customer Support
We use the data (which can include your communications) to investigate, respond to
and resolve complaints and service issues (e.g., bugs, direct marketing). We do not
share personal data with third parties for their direct marketing purposes.
Recipients of the personal data:We do not share personal data with third parties.

Bank / Legal and Accountancy Contacts:
BankAIB, Bank Place, Ennis, Co ClareSolicitors &

Legal Advisors
Diarmaid Gavin - Ronan Daly Jermyn, 2 Park
Place, City Gate Park, Mahon Point, Cork. Ph.
021 4802700Accountants &

Financial Advisors
Yvonne Cohen - Complete Rational Solutions Ltd,
56 Kiltegan Park, Rochestown Road, Cork, T12
CX5.

Details of transfers to other countries:
We do not transfer to any third party.

Data retention period:
We retain your personal data for as long as your account is in existence or as
needed to provide you the Allwayswithyou services. This includes data (you, your
family circle & Loved one) provided to us and data generated or inferred from your
use of our services.

If you choose to close your Allwayswithyou account, Allwayswithyou will provide you
with the facility to download all of your data before removing the data from the
Allwayswithyou servers. Your personal data will generally stop being visible to others
on our services within 24 hours. We generally delete closed account information
within 30 days of account closure. Backup copies of logs are held for a period of
6mnths.

Cookies:
Cookies are files with a small amount of data that are commonly used as anonymous
unique identifiers. These are sent to your browser from the websites that you visit
and are stored on your device's internal memory.

The Allwayswithyou service does not use these “cookies” explicitly. However, the
application may use third party code and libraries that use “cookies” to collect
information and improve their services. You have the option to either accept or
refuse these cookies and know when a cookie is being sent to your device. If you
choose to refuse our cookies, you may not be able to use some portions of this
Service.

Analytics:We are analysing personal data to generate personalised suggestions to give the
family circle insight into what the loved one likes to view as well as insights to the
daily viewing patterns of the loved one.

Security:
We implement security safeguards designed to protect your data, such as HTTPS
and data encryption. We regularly monitor our systems for possible vulnerabilities
and attacks.

Google and Facebook Integration
We have integrated Google and Facebook with Allwayswithyou for easing login and
enabling sharing of content from those platforms on Allwayswithyou. We do not
provide Google or Facebook with any of your data. Summary of the Allwayswithyou
integration with both Google and Facebook is as follows:
I. Ease of login: Allwayswithyou allows their users to login/authenticate using
existing Google or Facebook accounts, this is performed using oAuth.
II. Sharing of images/videos/music files:
Allwayswithyou allows their users to import digital content directly from their Google or Facebook accounts via a publicly
available API. These files will be transferred from the Google/Facebook cloud to the
Allwayswithyou cloud and remain there until deleted by the user. As the
Allwayswithyou cloud is a closed infrastructure, these files will only be accessible by
the Allwayswithyou user.
Other purposes:

Legal Action:
Where necessary we will process personal data provided to us only in response to
legal action Examples of such processing would be on receipt of a formal request
under Article 23 of the General Data Protection Regulation (GDPR) where we may
be required to disclose personal data of service users to Law Enforcement
Authorities, State Customs/Taxation Authorities, or other relevant organisation.
System Logs, Maintenance, and Investigation of Data Security

Breaches:
We want to inform you that whenever you use the Allwayswithyou service, in a case
of an error in the app we collect data and information (through third party products)
on your phone called Log Data. This Log Data may include information such as your
device Internet Protocol (“IP”) address, device name, operating system version, the
configuration of the app when utilizing our Service, the time and date of your use of
the service, and other statistics.

Service Use:
We log usage data when you, your family circle and your loved one visits or
otherwise use our services, including our sites, app and platform technology, such aswhen you view or click, upload or view content. We use log-ins to identify you and
log your use.

Messages:
We collect information about you when you send, receive, or engage with messages
in connection with our services. We value your trust in providing us your personal
information, thus we use commercially acceptable means of protecting it.

Your rights:
You have the following rights in respect to the personal data that Allwayswithyou
hold on you. Please contact us at the address above in order to exercise any of
these rights:
1) The right to be informed
You have the right to receive “fair processing information”.
2) The right of access
You have the right to obtain:
 Confirmation of your personal data being processed
 Access to a copy of your personal data
 And any other supplementary information
3) The right to rectification
You have the right to have your personal data corrected if it is inaccurate or
incomplete
4) The right to erasure (includes withdrawal of consent)
You have the right to have your personal data erased, in the following
circumstances:
 You withdraw consent.
 The personal data has to be deleted to comply with a legal obligation.
 The personal data was unlawfully processed.
 Where the personal data is no longer necessary in relation to the purpose for
which it was originally collected.
 Where you object to the processing and there is no superseding legitimate
requirement to continue the processing.
 The personal data is processed in relation to the offer of “information society
services” to a child.
5) The right to restrict processing
You have the right to ‘block’ or suppress processing of personal data
6) The right to data portability
You have the right to obtain and reuse their personal data for their own purposes
across different services.
7) The right to object
You have the right to object to:
 Processing based on legitimate interests or the performance of a task in the
public interest/exercise of official authority (including profiling).
 Direct marketing (including profiling). Processing for purposes of scientific/historical research and statistics.
8) Rights in relation to automated decision making and profiling
You the right not to be subject to a decision when:
 It is based on automated processing.
 It produces a legal effect or a similarly significant effect on the data subject.
The right to complain:
If you feel that Allwayswithyou has not fulfilled its obligations under the Data
Protection Act 2018, then you have the right to lodge a complaint with the Data
Protection Commission (DPC).
The DPC offers guidance on how to make a complaint here:
https://forms.dataprotection.ie/contactAutomated decision making, including profiling:
Allwayswithyou does not carry out automated decision making/profiling:

Updates or Questions:
We may update our privacy policy from time to time and will review it at least on an
annual basis. Thus, you are advised to review this page periodically for any changes.

We will notify you of any changes by posting the new privacy policy on this page.
These changes are effective immediately after they are posted on this page.

If you have any questions or suggestions about our Privacy Policy, do not hesitate to
contact us on contact@allwayswithyou.com.

Change Log:
Rev0.6 Original document. Effective date May 1 2019 -