Privacy policy for Mobile App

Who we are

We are PronsPro, a dealership inventory management system service provider. PronsPro IM app is a tool to assist in vehicle data control, by providing the necessery tools to add, edit or, delete vehicles on your inventory. All references in this policy to "PronsPro", "our", "us" or "we" refer to PronsPro. All references in this policy to "apps" are to our apps that are available to download on mobile devices from time to time.

Our values and what this policy is for

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide to our customers and contacts, so if you have any feedback on this privacy policy, please let us know using our contact details here

Who this policy applies to

This policy applies to users of our apps and people who contact our customer support function.

What this policy contains

This privacy policy describes the following important topics relating to your information.

• Collection of your personal information and how we use it
• How and why we share your personal information with others
• How long we store your personal information
• Your rights
• Children
• Where we may transfer your personal information
• Risks and how we keep your personal information secure
• Changes to this privacy policy; and
• Further questions and how to make a complaint

Your rights to object

You have various rights in respect of our use of your personal information. Two of the fundamental rights to be aware of are that:

• you may ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
• you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.

What you need to do and your confirmation to us

Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, including downloading and using any of our apps, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

Information you should be aware of

Collection of your personal information and how we use it

What personal information we collect about you

• if you choose to use the Facebook connection functionality and depending on your Facebook privacy settings, your basic Facebook profile information.
• if you choose to use the Google connection functionality and depending on your Google privacy settings, your basic Google profile information.
• If you contact our customer support function, we will collect your e-mail address (as well as any other information you include in your correspondence with us), including any updates to any of that information.

How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

• to receive and respond to customer support enquiries we receive from you.
• to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. Even if we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
• for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
• to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
• to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

Legal basis for use of your personal information

We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

• our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of service of our apps); or
• you have provided us with your consent to do so.
• run, grow and develop our business (as well as the businesses of our group companies) including funding our business by use of advertising revenues;
• and operate, maintain and improve our apps and our marketing optimisation efforts;

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details provided in this document.

How and why we share your personal information with others

We do not share your personal information with Third parties. Any Third party data exchange with PronsPro services is done anonymously via the following platform:

• Google Analytics (Google, Inc.)

Google Analytics collect, store and use data by integrating cookies and other tracking software on our apps. The relevant data collected by these third parties includes:

• data about your device, location and use of our apps, including IP address, a unique device ID, geo-location details and your User ID that we have assigned to you;
• data which you provide to us when using our apps

We may share your personal information with our group companies where it is in our legitimate interests to do so:

• to enable them to provide customer support to you; or
• for internal administrative and management purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

We will also disclose your personal information to third parties:

• if we or any of our group companies sell or buy any business or assets (or propose to do so), or we or any of our group companies are or may be acquired, we or our group companies may disclose your personal information to the prospective seller or buyer of such business or assets, and to their legal, financial and other professional advisers, and that personal information may be one of the transferred assets; and
• if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
• in order to establish, exercise, enforce, or defend our terms of service or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
• to protect the rights, property, or safety of PronsPro, our staff, our customers or other persons.

How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Your rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at gammaplay.com@gmail.com at any time. You have the following rights:

• Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area ("EEA").
• Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
• Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact provided in this document.

• Right to data portability. You have a right to ask us to provide your personal information to a third party provider of services.
• Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

Children

You must be aged 16 or over to purchase products or services from us. Our website and services are not directed at children younger than this and we do not knowingly collect any personal information from children younger than this.

If you are aged below the age of 16 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.

Please contact us at freebug62@googlemail.com if you are aware that we may have inadvertently collected personal information from a child below the age of 16.

Where we may transfer your personal information

Your personal information will be used, stored and/or accessed by staff operating outside the United States working for us, other members of our group or suppliers, including those located in the European Union + United Kindom.

in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see https://www.privacyshield.gov/welcome); or

When we provide any personal information about you to any such non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately. These measures may include the following, as permitted in Articles 45 and 46 of the General Data Protection Regulation:

• entering into European Commission approved standard contractual arrangements with them.

Risks and how we keep your personal information secure

The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We use industry-standard practices such as encryption, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address will be encrypted, which will make it extra hard for someone to discover and use them without our authorisation. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our apps. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.

Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our apps or customer services function and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be made available to you via the privacy policy, accessible in our app. Please check back frequently to see any updates or changes to our privacy policy.

Further questions and how to make a complaint

If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact freebug62@googlemail.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.